DOT Pipeline Compliance News

January 2026 Issue

In This Issue

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PHMSA Final Rule: Class Location Change Requirements

[Docket No. PHMSA-2017-0151; Amdt. No. 192-155]

PHMSA has published a new Final Rule for operators of certain gas transmission pipelines that have a change in class location to allow integrity management principles to be applied to the affected segments in lieu of historical treatment of derate, replace or request special permits to operate.  The following table provides a summary of the new Final Rule.

Subject	Final Rule
Applicability	Section 192.611(a)(4) authorizes an IM alternative for managing class location changes that affect certain eligible gas transmission line segments in Class 3 locations.
Eligibility	Section 192.3 defines the eligible Class 3 segments that may use the IM alternative. That definition excludes segments that (1) contain bare pipe; (2) contain wrinkle bends; (3) have a longitudinal seam formed by lap welding or another method with a joint factor below 1.0; or (4) have experienced an inservice leak or rupture due to cracking on the segment or a pipe with similar characteristics within 5 miles. A segment that experiences an in-service rupture or leak from the pipe body cannot continue using the IM alternative.
Subpart O Compliance	An eligible Class 3 segment applying the IM alternative must be designated as a high consequence area and comply with the requirements in Subpart O.
Initial Programmatic Requirements	Requirements An operator must comply with certain initial programmatic requirements within 24 months to use the IM alternative. Those requirements address: (1) integrity assessments and remediation, (2) pressure testing, (3) material records verification, (4) rupture mitigation valves, (5) cathodic protection and coating, and (6) depth of cover. An operator must also provide a notification to PHMSA.
Recurring Programmatic Requirements	Requirements. An operator must comply with certain recurring programmatic requirements to use the IM alternative. Those requirements address: (1) gas quality, (2) close interval surveys, (3) patrolling, (4) leak surveys, (5) line markers, (6) class location studies, (7) shorted casings, and (8) exposed pipe and weld surface examinations.
Other Requirements	MAOP of a segment using the IM alternative may not exceed a hoop stress corresponding to 72 percent of specified minimum yield strength. An operator of an eligible Class 3 segment may use the IM alternative to restore a previously established MAOP after complying with certain uprating and initial programmatic requirements.

For a copy of the Final Rule or to learn how RCP can help operators of gas transmission lines apply these IM principles to eligible class location segments, contact Jessica Foley.

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PHMSA Issues notice of limited enforcement discretion for issuing Special Permits

Consistent with E.O. 14156, PHMSA has announced a limited exercise of enforcement discretion and statement of policy for issuing special permits in response to the national energy emergency. Specifically, OPS will refrain from taking any enforcement action against a regulated party who defers the performance of an activity that would otherwise be required under the Federal pipeline safety regulations if:

1. The regulated party demonstrates that performing the required activity would contribute to the national energy emergency by adversely impacting the transportation of energy in and through the West Coast of the United States, Northeast United States, and Alaska, including by increasing energy prices for American consumers, particularly those living on low- and fixed-incomes; reducing the domestic supply of affordable and reliable energy; or impairing the integrity and expansion of the nation’s energy infrastructure;
2. The regulated party demonstrates that deferring the performance of the required activity will not create an unreasonable risk to public safety, property, or the environment, including, if necessary, through the implementation of alternative remedial measures; and
3. The regulated party files an application for a special permit promptly, but no later than 45 days after determining that the required activity should not be performed in response to the national energy emergency.

PHMSA will prioritize the review of any application for a special permit that meets the above criteria. PHMSA will also refrain from taking any enforcement action against the party that would otherwise be subject to the applicable regulation until a final decision on the special permit is issued. Moreover, if the application for a special permit is denied, PHMSA will continue to refrain from taking any enforcement action for a reasonable period of time thereafter, so that the party who sought the waiver or exemption can take appropriate action to perform the required activity without incurring any additional enforcement risk.

Regulated parties may rely on this notice as a temporary safeguard from PHMSA regulatory enforcement as described herein. PHMSA recommends that its State partners exercise the same enforcement discretion described in this Notice. To the extent this Notice includes guidance on how regulated parties may comply with existing regulations, it does not have the force and effect of law and is not meant to bind the regulated entities in any way. Nothing herein prohibits PHMSA from rescinding this limited exercise of its enforcement discretion and pursuing an enforcement action if it determines that a significant safety issue warrants doing so. Nothing herein relieves operators from compliance with any other applicable provisions of Federal regulations or other law, and PHMSA reserves the right to exercise all of its other authorities.

RCP is positioned to assist pipeline operators who could be affected by this notice, including performing risk analysis and documenting alternative remedial measures, as well as facilitating the special permit request process.  Contact Jessica Foley for more information.

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Have a couple minutes?

Take a quick look at our new video, “A Day in the Life with TaskOp.” It shows how teams use TaskOp to keep work organized, moving, and audit ready. After watching, let us know if this type of content is helpful and what else you’d like to see us create. Your feedback helps guide what we produce next.

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Featured Service

TaskOp Highlight: Underground Gas Storage

RCP has earned a worldwide reputation for providing professional engineering services and regulatory expertise to oil and gas operators, including underground gas storage in depleted reservoirs, aquifers and salt caverns.

We have the RESOURCES, SOFTWARE and the KNOWLEDGE to assist clients with building, implementing, and improving comprehensive operational integrity management programs in response to the PHMSA rule incorporating API RP 1171/1170 v2 (Jan. 1st, 2026) on underground gas storage.

Experienced Resources

• Highly respected underground storage industry & risk management SMEs
• Professional engineering support
• Knowledgeable technical standards developers
• Regulatory expertise

Asset Management Tools

• Gap assessment protocols
• Comprehensive risk analysis program through software
  • Out-of-the-box risk model designed by RCP SMEs
  • Operator-specific risk models
• Full-featured workflow & asset management software
  • Track, verify and complete all work done on a well
  • Wellsite/valve inspections, annulus pressure, well logging, well swabbing, capital projects, etc.

Gap Analysis/Effective Evaluation

• PHMSA Final Rule: Safety of Underground Natural Gas Storage
• API RP 1171/1170 v2
• PHMSA Advisory Bulletins
• State-Specific Regulations

Process Development and Continuous Improvement

• Storage risk management plan
• Site-specific operations & integrity standards
• Key performance indicators

Risk Analysis Model

• API RP 1171 v2, Section 8
  • Out-of-the-box risk model designed by RCP SMEs
  • Configurable to client and/or state needs
  • Separate models for depleted reservoirs and caverns
• Deterministic Approach
  • SME/Documentation
  • Data (ex. Well Log)
• Captures documents used in risk analysis and sub-surface safety valve assessment tools
• Customizable queries & reporting, including a fully revamped risk analysis dashboard experience to easily see what the risk model is trying to tell you

Asset Integrity Assessment & Remediation Progress Tracking

• Asset change management
• Traceable, verifiable, and complete record management
• Audit-ready software
• Schedule and progress reporting
  • Integrity assessment and repairs
  • Regulatory inspections
  • Preventative Maintenance
  • Capital Projects
  • Well Logging
• Data capture & analysis
  • Data trends for all the inspection data you are capturing
  • Data overlays to help make better, actionable decisions
  • Well log comparison (ex. corrosion rate)
• Documentation linkage to work activity

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The Enforcement Corner

The Enforcement Corner summarizes recent PHMSA enforcement actions, indicating where PHMSA is putting its enforcement efforts and the fines they are proposing for various types of violations.

In December 2025, PHMSA issued 2 CAOs, 3 NOAs, 5 NOPVs, 1 PSO, and 3 WLs accompanied by $9,715,054 in proposed fines.

• $48,400 – §192.195(a) – Accidental Overpressure Protection
• $44,600 – §192.605(a) – Procedure Manual
• $2,576,627 – §195.452(e)(1)(viii) – IMP: Geohazards
• $2,234,400 – §195.452(i)(3) – IMP: Leak Detection
• $2,234,400 – §195.402(d)(1)(v) – Procedure Manual
• $2,576,627 – §195.420(a) – Valve Maintenance

Please note:

1. Pipeline operators may disagree in whole or in part with each proposed violation cited by PHMSA. 
2. Proposed Civil Penalties (PCP) may be reduced or eliminated before an enforcement action becomes final.
3. A Corrective Action Order (CAO) usually addresses urgent situations arising out of an accident, spill, or other significant, immediate, or imminent safety or environmental concerns.
4. A Notice of Amendment (NOA) is frequently a result of a difference of opinion regarding written procedure requirements.
5. A Notice of Proposed Safety Order (PSO) addresses pipeline integrity risks that may not constitute a hazardous facility requiring immediate corrective action (see Corrective Action Order described above), but do need to be addressed over time.
6. A Notice of Probable Violation (NOPV) is not proof that a violation actually occurred.
7. Proposed Compliance Orders (PCO) frequently document actions the pipeline operator already planned to do.
8. Warning Letter (WL) is an official notice by PHMSA that an operator needs to make improvements but that no further enforcement is proposed for those findings at this time.

RCP maintains a detailed database of all PHMSA enforcement actions dating back to 2007 and is routinely asked for data analysis of various enforcement actions. For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.

Need to respond to a PHMSA enforcement action?
Need to know if your enforcement action is an outlier, or par for the course? 
RCP maintains a detailed database of all PHMSA enforcement actions and their resolution which enables us to compare and contrast individual enforcement actions to nationwide actions and trends.  We can help put things into context to ensure an effective reply for each citation.  For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.

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Did You Know?

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Q&A Section

Do you have questions? RCP’s SMEs have the answers. Information will be posted here for questions we often get from clients or discussions we have with regulators regarding interpretations and pending regulatory deadlines.

Q:  The proposed PHMSA language states that we still have to do a post-construction coating check within 6 months. It just moved the “start date” of that 6 months from “backfill” to “in-service date.” It doesn’t look like we can avoid the coating check after construction. Check the proposed language of 192.319(d).

A: Yes, you still have to do a coating evaluation but it’s from in-service, not the date the line was buried.

Ask the Experts

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PSI Training Schedule

DATE	COURSE	FEE
Feb 24-26, 2026	DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 & 199)	$2,150
March 26, 2026	Pipeline Safety: Class Location Change Requirements	FREE WEBINAR
Apr 14-16, 2026	DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 & 199)	$2,150
May 19-21, 2026	Advanced DOT Pipeline Compliance Workshop (49 CFR 192 & 195)	$2,150
On-Demand	DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 & 199)	$2,150
On-Demand	Fundamentals of Pipeline Pressure Testing (Gas & Liquid Pipelines)	$1,200
On-Demand	Texas Pipeline Weatherization Fundamentals	$200

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You asked and we listened!

Advanced DOT Pipeline Compliance Workshop is on the calendar!

This intensive and interactive 3-day, in-person workshop is designed for those who have previously completed our DOT Pipeline Compliance Workshop and are ready to take their knowledge to the next level.

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New Workshop Alert!

Prepare Your Team for Pipeline Safety Audits with Confidence!

Our 3-day Pipeline Safety Audit Workshop is tailored for professionals responsible for the safe operation of hazardous liquid and natural gas pipelines. Designed for groups of 10-15 participants, this interactive training…

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We would welcome the opportunity to discuss our services with you.

Sincerely,

W. R. (Bill) Byrd, PE
President
RCP Inc.