November 2024 Issue
In This Issue
- PHMSA Advisory Bulletin: Identification and Evaluation of Potential Hard Spots – In-line Inspection Tools and Analysis
- Upcoming PAC Meeting
- API Introduces New Contractor Assessment Program to Enhance Pipeline Safety
- Featured Service
- The Enforcement Corner
- Q&A Section
- Did you know?
- 2026 Conference News
- PSI Training Schedule
PHMSA Advisory Bulletin: Identification and Evaluation of Potential Hard Spots – In-line Inspection Tools and Analysis
[Docket No. PHMSA-2024-0176]
On November 18, 2024, PHMSA published an advisory bulletin in the Federal Register urging pipeline owners and operators to assess their pipeline systems for potential “hard spots” in the pipe body. These hard spots, which originate during the plate and pipe manufacturing process, may present a broader risk to pipeline integrity than previously understood. Recent data, including findings from incident investigations, suggest that pipelines manufactured prior to 1970 are particularly susceptible to this issue.
Hard spots—localized areas of material weakness—can compromise pipeline integrity when exposed to interacting threats such as coating degradation, soil chemistry changes, and increased hydrogen exposure. Over time, these factors can lead to hydrogen-induced cracking, further endangering pipeline safety.
To mitigate these risks, pipeline owners and operators should take the following actions:
- Expand Hard Spot Threat Evaluations: Extend the evaluation of hard spot susceptibility to all pipelines manufactured prior to 1970, regardless of the manufacturer.
- Leverage In-line Inspection Technology: Collect and analyze data from magnetic flux leakage (MFL) in-line inspection tools to identify potential hard spots.
- Adopt Industry Best Practices: Follow established industry standards and best practices when analyzing in-line inspection data to accurately assess pipeline condition and risks.
By proactively addressing the presence of hard spots, pipeline operators can better safeguard the long-term integrity and safety of their systems.
For a copy of the advisory bulletin, please message Jessica Foley.
Upcoming PAC Meeting
PHMSA is planning a virtual Pipeline Advisory Committee (PAC) meeting on January 16, 2025, at 10:30 am. The meeting will cover both the Liquid Pipeline Advisory Committee (LPAC) and the Gas Pipeline Advisory Committee (GPAC). Key topics include updates on the Standards Update II and the LNG (Liquefied Natural Gas) Cost Recovery Notice of Proposed Rulemakings (NPRMs), which may impact pipeline safety regulations.
Contact Jessica Foley if you’d like to sign up for updates or receive further details as they become available.
API Introduces New Contractor Assessment Program to Enhance Pipeline Safety
On October 30, 2024, the American Petroleum Institute (API) announced the launch of its new Pipeline Safety Management System (SMS) Contractor Safety Assessment Program. This initiative builds upon the success of the previously introduced Pipeline SMS: A Contractor’s Guide and its associated tools. Developed in collaboration with the Distribution Contractors Association, the program is designed to help contractors meet safety management system (SMS) standards while aligning with the priorities of pipeline operators. It provides contractors with direct access to experienced safety professionals, who will offer tailored feedback to enhance their safety management practices and improve alignment with operator expectations, ultimately advancing safety industrywide.
“The API Pipeline SMS Contractor Safety Assessment Program represents a critical next step in our ongoing commitment to strengthening pipeline safety,” said Anchal Liddar, API’s Senior Vice President of Global Industry Services. “By standardizing safety management practices and fostering deeper collaboration between contractors and operators, we are helping to reduce risks and enhance safety across the entire pipeline supply chain.”
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
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 2024, PHMSA issued 1 CAO, 1 NOA, and 1 NOPV accompanied by $246,800 in proposed fines. Significant proposed fines were attributed to the following code sections:
- $39,100 – §191.22(c)(1)(i) – National Registry
- $149,700 – §192.5(b)(3)(ii) – Class Locations
- $58,000 – §192.705(c) – ROW Patrols
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 (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.
- 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.
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: How can TaskOp help an Operator prepare for an audit?
A: The TaskOp Audit module can streamline your audit preparation by isolating data relevant to the auditor’s specific questions. It organizes and presents this data in a clear, digital format, which helps reduce the time required for the audit. This targeted approach ensures that you can quickly and efficiently provide all the necessary information, making the audit process smoother and more efficient.
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?
Did You Know? RCP’s Version 2.0 of its TaskOp Underground Storage Reservoir Risk Module is officially live!
Developed in response to the release of API 1171’s 2nd Version, RCP has added a number of new, premium features, including robust threat interaction tables, to enable users to comply with the new recommended practices being introduced.
Click here to learn more.
2026 Conference News
Pipeline Pigging & Integrity Management
January 19-22, 2026 | George R. Brown Convention Center | Houston, TX
Since 1989, attendance at the annual PPIM Conference and Exhibition in Houston has grown from a few hundred to more than 4,000, including a commercial exhibition that began with a handful of specialized solution-providers and which now involves more than 190 companies and industry organizations from more than 25 countries.
Click here to register for PPIM 2026.
PSI Training Schedule
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DATE |
COURSE | FEE |
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Advanced DOT Pipeline Compliance Workshop -SOLD OUT- (49 CFR 192 & 195) |
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DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 & 199) |
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| 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 |
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.