DOT Pipeline Compliance News

November 2023 Issue

In This Issue

National Pipeline Mapping System (NPMS) Phase 0 for Breakout Tanks 

The approaching NPMS Phase 0 deadline, set for June 2024, marks an important moment for operators in the energy and infrastructure sector. This deadline requires operators to submit vital data regarding breakout tanks, which are integral to the management of hazardous liquids within our energy infrastructure. Furthermore, pipeline data, such as pipeline diameter, which was optional before, is now mandated for submission. The deadlines for pipeline data are March 15 for gas pipelines and June 15 for liquid pipelines. 

The inclusion of breakout tanks within NPMS Phase 0 is a significant shift toward enhanced safety, greater regulatory transparency, and increased oversight. This mandatory reporting requirement for both breakout tanks and pipeline data will empower regulatory agencies to uphold safety standards, respond promptly to incidents, and bolster emergency preparedness. Operators will need to adapt to these new reporting mandates, ultimately contributing to the overall safety and resilience of our nation’s energy infrastructure. 

To speak with an SME for assistance with this new standard, contact Jessica Foley

Underwater Inspection Procedures & Inspection Interval Risk Model Updates

As a reminder, this is a good time to evaluate your pipelines in the waters of the Gulf of Mexico and see if their risk profiles have changed. It has been a quiet year for hurricanes this year, but it has been a busy year for several of the other hazards for underwater pipelines. RCP’s proprietary Underwater Inspection Interval Risk Model analyzes key operator information as well as National Oceanic and Atmospheric Administration charts, state game and fisheries department maps and published project information for additional hazards and associated risks. 

For more information on RCP’s Underwater Inspection Procedure or Inspection Interval Risk Model, contact Jessica Foley.

Alabama GPS Rules for Operators

Alabama Public Service Commission has incorporated a new regulation (900-7-15 (GPS Rule 15)) concerning calibration of testing and equipment. The regulation requires natural gas and hazardous liquid pipeline operators to make sure all equipment used to verify regulatory compliance is properly calibrated on a timely basis. This includes equipment used in construction, operation, maintenance of pipelines and facilities if the equipment is used to gather correct readings/ measurements and determine safety levels. The rule requires calibration to follow manufacturer’s recommended instructions and lists instances when it must be considered. If the equipment is sent to a facility for calibration, it must be one that is approved by the manufacturer. Individuals performing calibration must be properly trained. Regulation further requires calibration procedures / processes to be incorporated into the Operations and Maintenance (O&M) Plan. Calibration records must include the reason from regulation that required the calibration (Rule 900-7-15(3)) and verification of calibration. Maintain these records for a minimum of 10 years. 

For a copy of the administrative code, contact Jessica Foley

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 September 2023, PHMSA issued 2 NOAs, 6 NOPVs, and 4 WLs accompanied by $445,000 in proposed fines. Significant proposed fines were attributed to the following code sections: 

  • $39,100 49 CFR 192.631(c)(3) Control Room Management 
  • $36,100 49 CFR 192.631(c)(4) Control Room Management 
  • $39,100 49 CFR 192.631(h) Control Room Management 
  • $83,000 49 CFR 192.631(j)(1) Control Room Management 
  • $17,100 49 CFR 195.402(a) Procedure Manual 
  • $18,600 49 CFR 195.402(c)(7) Control Room Management 
  • $20,400 49 CFR 195.440(b) Public Awareness 
  • $39,100 49 CFR 195.446(h)(6) Control Room Management 
  • $81,900 49 CFR 195.452(l)(1)(ii) Integrity Management 
  • $20,400 49 CFR 195.505(b) Operator Qualification 
  • $50,200 49 CFR 195.588(b)(4)(iii) Direct Assessments 

Please note: 

  1. Pipeline operators may disagree in whole or in part with each proposed violation cited by PHMSA.  
  1. Proposed Civil Penalties (PCP) may be reduced or eliminated before an enforcement action becomes final. 
  1. 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. 
  1. A Notice of Amendment (NOA) is frequently a result of a difference of opinion regarding written procedure requirements. 
  1. 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. 
  1. A Notice of Probable Violation (NOPV) is not proof that a violation actually occurred. 
  1. Proposed Compliance Orders (PCO) frequently document actions the pipeline operator already planned to do. 
  1. 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.

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, interpretations and pending regulatory deadlines.

Q:  Our company purchased a pipeline asset from another company, and hired the technicians that worked for the previous operator.  Can our company use the previous operator’s OQ qualifications for those employees? 

A: No. These employees will need to be requalified under your company’s OQ program, even if they are doing the same tasks they did for the previous operator.

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 have 60 days from the date of publication in the Federal Register.  Comments may be filed at 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?

Customer Efficiency Program Efficiency Program  

DID YOU KNOW? About consumer efficiency programs…  

  • Whether it is decreasing emissions, preserving natural resources, or ensuring reasonable utility bills, the efficient use of energy will be critical in these goals.  
  • Residential customers might be able to get a rebate when switching to a tankless natural gas water heater.  If appropriate for the homeowner based on need and house design, tankless natural gas water heaters, also known as demand-type or instantaneous water heaters, provide hot water only as it is needed. They don’t produce the standby energy losses associated with storage water heaters, which can save money.   
  • If new space heating equipment is needed, APGA member utilities may be able to provide a rebate for a natural gas furnace or boiler.  With efficient natural gas space heating equipment, the homeowner can benefit from improved comfort, increased value of their home and property, contributions to a cleaner environment, and more for their money with lower heating bills.  
  • Many APGA member gas systems offer rebates to add insulation to their customers’ home attics. Upgrading the insulation in a home attic is one of the most cost-effective ways to increase comfort, lower heating bills, and improve a home’s energy efficiency.  
  • Homeowners can save money on heating bills by simply resetting the thermostat when asleep or away, and this can be done automatically without sacrificing comfort by installing an automatic setback or programmable thermostat.  A programmable thermostat can adjust the times you turn on the heating according to a pre-set schedule.   
  • To help their customers have energy efficient homes, APGA members may be able to cover the cost of a programmable thermostat and the expense of installing it. Some APGA members may also help properly dispose of old thermostats that may contain mercury.  
  • Natural gas is an affordable and reliable domestic resource that is nearly three times as efficient when used directly inside the home as when it is used to generate electricity.   


Pipeline Pigging & Integrity Management Conference
February 12-16, 2024 | George R. Brown Convention Center | Houston, TX 

The Pipeline Pigging and Integrity Management Conference (PPIM) in Houston, Texas, serves as a pivotal gathering for professionals in the pipeline industry. This annual event brings together experts, engineers, and industry leaders to discuss the latest advancements and best practices in pipeline integrity, maintenance, and inspection. Attendees can expect insightful presentations, interactive discussions, and access to cutting-edge technologies aimed at ensuring the safe and efficient operation of pipelines. PPIM in Houston serves as a hub for networking, knowledge exchange, and collaboration, playing a crucial role in shaping the future of pipeline integrity management.

Click here to register to attend PPIM.

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


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