DOT Pipeline Compliance News

June 2025 Issue

In This Issue

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PHMSA Rescinds ADB-2021-01

On June 13, 2025, PHMSA rescinded ADB-2021-01—and any PHMSA policy statements, letters of interpretation, guidance documents, congressional testimony, and public statements that rely on or assert the reading of the section 114 mandate expressed in ADB-2021-01.  Owners and operators of pipeline facilities should adhere to the text of section 114 of the 2020 PIPES Act and section 60108(a) of the Pipeline Safety Act in developing and implementing their inspection and maintenance plans. PHMSA and State authorities should do the same in considering the factors in section 60108(a)(2) and in exercising their inherent enforcement discretion to decide whether an operator’s inspection and maintenance plan is adequate.

Editor’s Note:
Operators should remember that they are required to comply with their O&M manual as written – even if the manual exceeds the requirements of the rule or law.  To get the full benefit of the ADB rescission, operators will need to revise their written procedures to eliminate statements which are no longer required.  RCP’s staff stand ready to assist in that effort.  Contact Jessica Foley at jfoley@rcp.com. 

Additional Information:
The full Federal Register notice is available here:
Federal Register :: Pipeline Safety: Recission of Advisory Bulletin on Section 114 of the Protecting our Infrastructure of Pipelines and Enhancing Safety Act of 2020

Section 60108 of Title 49 USC is available here:
USCODE-2023-title49-subtitleVIII-chap601-sec60108.pdf

Section 114 of the PIPES Act is available here:
Pipes Act 2020 Section 114

Our newsletter article explaining the ADB is available here:
RCP’s DOT Pipeline Compliance Newsletter – PHMSA Advisory Bulletin: Eliminating Hazardous Leaks and Minimizing Releases of Natural Gas from Pipeline Facilities

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ANPRM: Pipeline Safety: Repair Criteria for Hazardous Liquid and Gas Transmission Pipelines

[Docket No. PHMSA-2025-0019]

PHMSA published an advance notice of proposed rulemaking (ANPRM) on May 21, 2025, to gather stakeholder feedback on potential amendments to Parts 192 and 195 including repair timelines, remediation criteria, integrity management rules, and re-assessment intervals to ensure regulations maintain pace with modern technology and best practices without imposing unnecessary burdens. Additionally, PHMSA is requesting feedback pertaining to the authorization of a risk‑based approach for determining inspection intervals on in‑service breakout tanks.

The ANPRM noted that hazardous liquids and carbon dioxide repair requirements have not been substantially updated for decades, and they may not sufficiently provide for the use of advanced technology and current pipeline industry best practices. PHMSA has requested comments pertaining to:

• Anomaly categorization and remediation timelines for could affect (HCA) and non-could affect pipelines
• Alternatives to existing anomaly repair criteria and remediation timelines
• Anomaly evaluation methods in the absence of known material properties
• Adopting predicted failure pressure-based criteria for anomalies
• Repair criteria timelines for metal loss anomalies along a longitudinal seam weld for could affect (HCA) and non-could affect pipelines
• Dent evaluations and Engineering Critical Assessments
• Dents with metal loss or other interacting threats

With respect to gas transmission pipelines, PHMSA stated that gas transmission repair criteria were last revised in 2022 following the San Bruno incident; some of those changes are under litigation and PHMSA has not conducted a holistic review since. PHMSA requested comments pertaining to:

• Dents and Engineering Critical Assessments
• Engineering Critical Assessment methodologies using current industry standards
• Cost and benefits associated with Engineering Critical Assessments
• Dents with metal loss or other interacting threats
• Re-assessment for anomalies that were evaluated using Engineering Critical Assessments

For hazardous liquid breakout tanks, PHMSA has requested feedback pertaining to how tanks should be inspected and repaired, and inspection frequencies.  PHMSA asks if incorporating a risk-based inspection interval would be appropriate for breakout tanks.

Public comments are due by July 21, 2025, and PHMSA plans to hold a public meeting to supplement or to clarify the materials received.

For a copy of this ANPRM, please message Jessica Foley.

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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 May 2025, PHMSA issued 11 NOAs, 7 NOPVs, and 11 WLs accompanied by $0.00 in proposed fines.

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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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:  Does any portion of a 192.635 “Notification of Potential Rupture” require OQ training as a covered task?

A: Yes, 192.635 “Notification of Potential Rupture” implicitly requires that employes and contractors who work along the ROW (or who remotely monitor pipelines) are able to identify potential ruptures and know how to respond. This competency should be incorporated into the operator’s Operator Qualification (OQ) program, as well as into Control Room Management (CRM) training.

Ask the Experts

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Did You Know?

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PSI Training Schedule

DATE	COURSE	FEE
August 4-6, 2026	DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 & 199)	$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

WEBINAR RECORDING
Pipeline Safety: Unpacking the Class Location Change Requirements

Thank you to everyone who attended and participated in this informative webinar. The session recording is posted to our YouTube channel. Please watch, like, and subscribe to our channel!

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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.