May 2024 Issue
In This Issue
- PHMSA Extends Public Comment Period for Proposed Pipeline Safety Measures
- AMPP Releases Guide 21569-2024: A Blueprint for Corrosion Control Compliance with PHMSA Regulations
- PHMSA 49 CFR Parts 192 & 195 Periodic Updates to Final Rule
- Featured Service
- Q&A Section
- Did you know?
- The Enforcement Corner
- PSI Training Schedule
PHMSA Extends Public Comment Period for Proposed Pipeline Safety Measures
[Docket No.: PHMSA–2022–0085]
PHMSA has extended the public comment period for a notice published on March 25, 2024 (89 FR 20751), which requested feedback on proposed changes to PHMSA forms. These changes aim to gather data on the use of rupture mitigation valves and blending hydrogen gas with other natural gases in pipelines. These adjustments are intended to address Recommendation P-11-11 from the National Transportation Safety Board and track trends related to gas pipeline operations.
In response to a joint petition from trade associations, the deadline for public comments has been extended from May 24, 2024, to June 24, 2024. This extension was announced on May 3, 2024, and published in the Federal Register on May 6, 2024.
For a copy of this notice, please message Jessica Foley.
AMPP Releases Guide 21569-2024: A Blueprint for Corrosion Control Compliance with PHMSA Regulations
AMPP’s latest release, Guide 21569-2024, offers a comprehensive roadmap for pipeline operators to align with PHMSA’s revised regulations on corrosion control. Developed by industry experts, this guide provides practical strategies for compliance with enhanced safety measures, benefiting both US and international gas transmission pipeline operators. It addresses critical aspects such as integrity management, repair criteria, and cathodic protection, ushering in a new era of pipeline safety and integrity.
Click here to read more about this standard.
PHMSA 49 CFR Parts 192 & 195 Periodic Updates to Final Rule
[Docket No. PHMSA-2016-0002; Amdt. Nos. 192-135, 195-107]
In April of 2024, PHMSA sent “Pipeline Safety: Periodic Updates of Regulatory References to Technical Standards and Miscellaneous Amendments” to the Federal Register for publication of a final rule amending the Federal pipeline safety regulations to incorporate by reference all or parts of more than 20 new or updated voluntary, consensus industry technical standards (Standards Update I). This action allows pipeline operators to use current technologies, improved materials, and updated industry and management practices. Additionally, PHMSA is clarifying certain regulatory provisions and making several editorial corrections. The effective date of this final rule will be 60 days from the date of publication in the Federal Register.
For a copy of the final rule, please message Jessica Foley
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
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: To clarify, has there been a final approved and implemented requirement for Management of Change processes for DISTRIBUTION companies?
A: No, this was published in the Notice of Proposed Rulemaking, but has not yet been discussed within the Gas Pipeline Advisory Committees (GPAC). That must occur prior to publication of any final rule.
Ask the Experts
Do you have a question for the experts at RCP? Submit your question using this form. If your question is selected for a future newsletter, you will be eligible for a gift of your choice from RCP’s online Store.
Upcoming Deadlines:
- The deadline to submit written comments in response to PHMSA’s forthcoming NPRM on Pipeline Safety: Safety of Gas Distribution Pipeline and Other Pipeline Safety Initiatives will be 60 days from the date of publication in the Federal Register. Comments may be filed at https://www.regulations.gov/ Docket No. PHMSA-2021-0046.
- And as a reminder, the “Stay of Enforcement” does not mean regulators don’t expect work toward getting compliance activities in place can be ignored.
If we can help, contact Jessica Foley.
Did you know?
Natural gas is critical to maintaining electric reliability in the U.S. As the largest source of electricity in the United States, natural gas accounted for nearly 40% of the kilowatt hours of electricity produced in the U.S. in 2022. Some power plants use natural gas to power steam boilers, combustion turbines, or both, which then generate the electricity which is carried through the power grid long distances to residential and commercial buildings and industrial facilities. The United States currently has 2,077 natural gas-fired power plants. However, the Energy Information Administration (EIA) expects that the U.S. will add 10 natural gas-fired power plants with 1.8 GW of capacity in 2024. Read more: https://ingaa.org/role-of-pipelines-in-reliability/
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 March 2024, PHMSA issued 7 NOAs, 7 NOPVs, and 6 WLs accompanied by $353,300 in proposed fines. Significant proposed fines were attributed to the following code sections:
- $34,200 49 CFR 195.446(c)(3) Control Room Management
- $33,500 49 CFR 195.446(c)(4) Control Room Management
- $33,500 49 CFR 195.446(e)(4) Control Room Management
- $33,500 49 CFR 195.446(h)(1) Control Room Management
- $1,800 49 CFR 195.505(b) Operator Qualification
- $39,400 49 CFR 195.446(c)(4) Overpressure Safety Devices
- $137,600 49 CFR 195.446(c)(4) Procedure Manual
- $39,800 49 CFR 195.446(c)(4) Drug Testing
Please note:
- Pipeline operators may disagree in whole or in part with each proposed violation cited by PHMSA.
- Proposed Civil Penalties (PCP) may be reduced or eliminated before an enforcement action becomes final.
- 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.
- A Notice of Amendment (NOA) is frequently a result of a difference of opinion regarding written procedure requirements.
- A Notice of Proposed Safety Order (NOPSO) 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.
- A Notice of Probable Violation (NOPV) is not proof that a violation actually occurred.
- Proposed Compliance Orders (PCO) frequently document actions the pipeline operator already planned to do.
- 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.
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!
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.
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…
On-Site Training Request
We have conducted on-site training for oil and gas companies for over 25 years and can provide customized workshops for companies with groups of five or more.
We would welcome the opportunity to discuss our services with you.
Sincerely,
W. R. (Bill) Byrd, PE
President
RCP Inc.