September 2025 Issue
In This Issue
PHMSA to Hold a Public Meeting to Discuss Pipeline Data
PHMSA has announced a public meeting to discuss how data collected from pipeline operators can be used to improve pipeline and public safety. Discussion topics include how data collected by PHMSA is currently used by stakeholders, displayed on the PHMSA website, and used to generate pipeline safety performance measures. PHMSA is also interested in identifying data that is collected but not used by any stakeholders, as well as data that should be collected but is not. The meeting will be recorded but there will not be a live webcast.
The public meeting on pipeline data will be held on Thursday, September 18, 2025, from 8:00 a.m. to
5:00 p.m. CST, and Friday, September 19, 2025, from 8:00 a.m. to 5:00 p.m. CST. The recordings from this meeting will be available after the meeting on the registration site. Click here to visit the registration site and to see more information about this meeting.
Regulatory Watch: Key Dates & Deadlines
Welcome to Regulatory Watch! In this monthly update, we’ll keep you informed on proposed rule comment periods, effective dates, and upcoming deadlines for various compliance requirements.
Have questions about an upcoming deadline? Please reach out to Jessica Foley for assistance!
Featured Service
TaskOp Highlight: MOC Module
TaskOp, RCP’s reliable Workflow & Asset Management Application, features a fully integrated Management of Change (MOC) module. Designed to meet the requirements of 49 CFR 192, 195, and PHMSA’s RIN2, Gas Mega Rule regulations as documented in § 192.13, this module allows users to electronically oversee their company’s management of change process.
TaskOp’s MOC module was built to manage the following aspects of any MOC process:
- Scalable approval process, with designated alternates
- Tracking of MOCs through a step-by-step process flow
- Set automatic notifications to key personnel for each process step
- Allows MOC Coordinator to track real time updates and progress of MOC
- Provides checks and balances for modifications of process to ensure MOC security
- Comprehensive documentation of change (TVC)
TaskOp’s MOC module was specifically designed to provide ease of use while being flexible and scalable, offering robust customization options to meet increasing regulatory requirements. This module ensures a consistent and reliable experience throughout any MOC process.
If your goal is a streamlined and accessible MOC process, look no further than TaskOp’s MOC module.
From 49 CFR 192.13: “For pipeline segments other than those covered in subpart O of this part, this management of change process must be implemented by February 26, 2024. The requirements of this paragraph (d) do not apply to gas gathering pipelines.”
To learn more about the TaskOp MOC module, click the link below to schedule a demo.
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.
InIn July 2025, PHMSA issued 10 NOAs, 6 NOPVs, and 3 WLs accompanied by $62,900 in proposed fines.
- $62,900 – §194.7(b) – Operating Restrictions/Interim Authorization
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: 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
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 Edition, 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.
2025 Conference News
APGA Operations Conference 2025
October 21-October 23, 2025 | Sheraton Hotel Charlotte | Charlotte, NC
This event typically attracts over 250 natural gas distribution industry professionals from more than 70 public gas systems to learn about topics such as PHMSA’s Natural Gas Distribution Infrastructure Safety and Modernization Grant Program, methane emission mitigation strategies, and new technology along with an exhibitor hall.
Click here to register for APGA’s Operations Conference.
2025 PSI Training Schedule
| DATE | COURSE | LOCATION |
| Nov 18-20, 2025 |
Advanced DOT Pipeline Compliance Workshop (49 CFR 192 and 195) |
Houston, TX |
| Jan 27-29, 2026 |
DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 and 199) |
Houston, TX |
| On-Demand |
DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 and 199) |
Online |
| On-Demand |
Fundamentals of Pipeline Pressure Testing
(Gas & Liquid Pipelines) |
Online |
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.