September 2026 Issue
In This Issue
- PHMSA to Share Research on Improving Corrosion Control for Aboveground Storage Tanks
- PHMSA Interpretation Request Raises Part 192 Classification Question
- Advancing AI in Energy: EnergyAI 2026 Comes to Houston
- Q&A Section
- The Enforcement Corner
- Regulatory Watch: Key Dates & Deadlines
- Featured Service
- Did You Know?
- 2026 Conference News
PHMSA to Share Research on Improving Corrosion Control for Aboveground Storage Tanks
PHMSA will hold a virtual public meeting on September 16, 2026, at 11:00 a.m. ET to present the results of agency-funded research focused on tank foundation and floor designs and improved corrosion control.
The research evaluated different tank foundations, bottom designs, and corrosion control equipment to identify methods and best practices for:
- Monitoring and controlling corrosion
- Detecting leaks
- Preventing damage caused by leaks
- Improving the safety and reliability of breakout tanks and other aboveground storage tanks
The project is intended to help establish clearer practices for the design and maintenance of aboveground storage tanks while improving their safety, reliability, and service life.
Interested parties can register and access the meeting agenda through PHMSA’s Public Meetings Registration page. PHMSA has also made the project’s final report and additional research information available through its Pipeline Safety Research & Development Program.
PHMSA Interpretation Request Raises Part 192 Classification Question
PHMSA has been called on to clarify a familiar pipeline jurisdiction question: When does a pipeline stop being regulated in transportation and become customer-owned piping?
Martin Operating Partnership has requested a formal interpretation involving a 1.8-mile natural gas line in Odessa, Texas. The Railroad Commission of Texas currently treats the line as transmission, but Martin argues that it falls outside 49 CFR Part 192 because it is downstream of the customer sales meter and carries gas solely for Martin’s own consumption.
The facts make the question particularly interesting. The line serves a single industrial facility, operates at 20 psig or less, has no downstream customers or delivery points, and does not resell or redistribute gas.
Martin has asked PHMSA to determine that the segment is customer-owned consumption piping and therefore not subject to Part 192. If PHMSA disagrees, Martin is asking for an alternative determination that the line is a distribution service line rather than a transmission line.
PHMSA’s response could offer useful clarification for operators facing similar questions about customer meters, industrial laterals, large-volume customers, and the boundaries of Part 192 jurisdiction.
Advancing AI in Energy: EnergyAI 2026 Comes to Houston
Artificial intelligence is quickly moving from experimentation to real-world application across the energy industry. On September 28, 2026, the EnergyAI Users Group Annual Conference will bring together engineers, data scientists, technology leaders, and energy professionals at the Thompson Houston for a full day focused on how AI is actually being deployed and scaled across oil and gas operations.
The program moves beyond the AI hype to explore practical applications, challenges, and lessons learned. Sessions will cover topics including agentic AI, autonomous field operations, enterprise AI governance, workforce adoption, asset integrity, infrastructure, and the technology needed to scale AI across energy organizations.
Speakers and panelists will represent organizations including ExxonMobil, Chevron, Shell, Aramco Americas, Halliburton, SLB, NOV, NVIDIA, Google, Dell Technologies, DataRobot, Cloudera, Wood, Booz Allen Hamilton, and others.
A few topics on the agenda include:
- Moving AI projects from pilot programs into production
- Agentic AI in drilling, completions, and production
- Responsible AI governance and enterprise adoption
- Using AI to improve industrial operations and planning
- AI applications across downstream, infrastructure, and asset integrity
- The data, computing, and technology infrastructure required for the next generation of energy AI
EnergyAI Users Group Annual Conference
September 28, 2026 | All Day
Thompson Houston
1717 Allen Parkway, Houston, TX 77019
For energy professionals evaluating where AI can deliver meaningful operational value, the conference offers an opportunity to hear directly from the companies and practitioners already putting these technologies to work.
Learn more and register: EnergyAI 2026 Conference
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: If a contractor has their own OQ program, is the pipeline operator still responsible for verifying their qualifications?
A: Yes. The operator is responsible for ensuring that anyone performing a covered task on its pipeline is qualified under the operator’s OQ program requirements. If a contractor uses their own OQ program, the operator must verify that it satisfies the operator’s requirements and document the contractor’s qualifications.
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:
- 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.
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 August 2026, PHMSA issued 2 CAOs, 1 WL, and 2 NOPVs accompanied by $29,700 in proposed fines.
- $29,700 § 192.616(c) Public Awareness
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.
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.
Final Rule Stage
| Final Rule | Regulatory Agenda | Federal Register Document |
| Safety of Gas Distribution Pipelines and Other Pipeline Safety Initiatives | 2137-AF53 | PHMSA-2021-0046 |
| Coastal Ecological Unusually Sensitive Areas | 2137-AF31 | PHMSA-2017-0152, Amdt. No. 195-104 |
| Gas Pipeline Leak Detection and Repair | 2137-AF51 | PHMSA-2021-0039 |
| Cost Recovery for Siting Reviews for LNG Facilities | 2137-AF61 | PHMSA-2022-0118 |
Sprint I
To further the Administration’s deregulatory policies, PHMSA has published in today’s Federal Register twenty-eight (28) separate rulemaking actions affecting the pipeline safety regulations (PSR; Parts 190-199). Click here to access the documents.
| Pipeline Safety: Rationalize Special Permit Conditions | PHMSA proposes to amend its special permit procedures to ensure permit conditions are directly tied to the specific pipeline safety regulations being waived. | NPRM | 49 CFR Part 190 |
| Pipeline Safety: Rationalize Calculation of Regulatory Filing and Compliance Deadlines | PHMSA will clarify that regulatory filing and compliance deadlines falling on weekends or Federal holidays automatically move to the next business day. | DFR | 49 CFR Part 190 |
| Pipeline Safety: Adjust Annual Report Filing Timelines | PHMSA will amend annual reporting requirements to move the gas pipeline annual report submission deadline from March to June. | DFR | 49 CFR Part 191 |
| Pipeline Safety: Property Damage Definition for Incident Reporting | PHMSA will clarify incident reporting property damage calculations for gas pipelines and update hazardous liquid accident reporting thresholds using inflation-adjusted criteria. | DFR | 49 CFR Parts 191 & 195 |
| Pipeline Safety: Exception for In-Plant Piping Systems | PHMSA proposes to clarify that in-plant piping systems are not subject to federal pipeline safety regulations. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Codify Enforcement Discretion on Incidental Gathering Lines | PHMSA proposes to codify enforcement discretion clarifying that restrictions on the historical incidental gathering line exemption apply only to newly constructed lines. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Eliminate Burdensome Coating Assessment Deadlines | PHMSA proposes to replace prescriptive deadlines for coating damage assessments and remediation with a requirement that activities be completed before the pipeline is placed in service. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Atmospheric Corrosion Reassessment for Pipeline Replacements | PHMSA proposes to remove the 3-year reassessment interval following replacement of atmospheric corrosion defects and allow use of the standard 5-year reassessment interval. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Harmonize Class Change Pressure Test Requirements | PHMSA proposes to reduce the minimum pressure test duration following certain class location changes from 8 hours to 4 hours, aligning with existing Subpart J requirements. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Clarify MAOP Reconfirmation Testing Records | PHMSA will issue a technical correction clarifying that operators may use pre-1970s pressure test records when reconfirming MAOP under §192.624. | Final Rule | 49 CFR Part 192 |
| Pipeline Safety: Remote Sensing Technologies for ROW Patrols | PHMSA will explicitly allow right-of-way patrols to be conducted using unmanned aircraft systems, satellites, and other remote sensing technologies. | DFR | 49 CFR Parts 192 & 195 |
| Pipeline Safety: Technical Standards Updates and Amendments | PHMSA will update incorporated standards and make technical amendments in response to an industry petition for reconsideration. | Final Rule | 49 CFR Part 192 |
| Pipeline Safety Program: Update of Standards Incorporated by Reference | PHMSA issued multiple direct final rules updating incorporated industry consensus standards used throughout Parts 192 and 195, replacing outdated editions with current versions. | Multiple DFRs | 49 CFR Parts 192 & 195 |
Sprint II
The following is a summary of the 40 rulemakings that PHMSA published in the Federal Register on April 24, 2026. If any adverse comment is received to a DFR PHMSA must rescind the rule and repropose. Click here to access the documents.
| Pipeline Safety and Hazardous Materials Safety: Amendments to PHMSA Procedural Regulations | PHMSA proposed miscellaneous amendments to procedural regulations governing informal rulemaking for both pipeline safety and hazardous materials programs. | NPRM | 49 CFR Part 190 |
| Pipeline Safety: Interpretation Request Procedures | PHMSA amended interpretation procedures to require publication of interpretation requests on its website and provide an opportunity for public comment. | Final Rule | 49 CFR Part 190 |
| Pipeline Safety: Declaratory Order Procedures | PHMSA established formal procedures for issuing declaratory orders through a new section in Part 190. | Final Rule | 49 CFR Part 190 |
| Pipeline Safety: Consent Orders | PHMSA clarified that consent agreements may be used to resolve enforcement actions, including cases involving civil penalties. | Final Rule | 49 CFR Part 190 |
| Pipeline Safety: Adjustment to OPID Notifications for Construction | PHMSA proposed adjusting the inflation-based threshold that triggers OPID notifications for certain construction and facility modification activities. | NPRM | 49 CFR Part 191 |
| Pipeline Safety: Eliminating Limitations on Welders and Welding Operators | PHMSA proposed allowing welders qualified through non-destructive testing methods to perform compressor station welding activities currently subject to additional restrictions. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Material Properties Verification During MAOP Reconfirmation | PHMSA proposed clarifying that material testing at pressure test manifold sites is not required when traceable, verifiable, and complete material records already exist. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Electronic Retention of Part 194 Response Plans | PHMSA amended regulations to allow operators to maintain electronic copies of response plans instead of paper copies. | DFR | 49 CFR Part 194 |
| Pipeline Safety: Remote Monitoring of Rectifiers | PHMSA proposed allowing remote monitoring technologies for rectifiers used in external corrosion control programs. | NPRM | 49 CFR Part 195 |
| Pipeline Safety: Clarifying Hazardous Liquid High-Consequence Area Designations | PHMSA amended HCA guidance to clarify spill considerations in agricultural fields and reorganize threat identification guidance. | DFR | 49 CFR Part 195 |
| Pipeline Safety: Timeframe to Make Rupture-Mitigation Valves Operational | PHMSA proposed extending the deadline for placing rupture-mitigation valves into operation from 14 days to 90 days after a pipeline enters service. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Hazardous Liquid Valve Maintenance Schedule | PHMSA proposed allowing operators to implement risk-based valve maintenance schedules, subject to a maximum inspection interval of one year. | NPRM | 49 CFR Part 195 |
| Pipeline Safety: Property Damage Definition for Incident Reporting | PHMSA proposes revising property damage thresholds for reportable gas and hazardous liquid pipeline incidents and clarifying applicability to telephonic notifications. | NPRM | 49 CFR Parts 192 & 195 |
| Pipeline Safety: Remote Sensing Technologies for ROW Patrols | PHMSA proposes clarifying that unmanned aerial systems, satellites, and other remote-sensing technologies may be used to satisfy right-of-way patrol requirements. | NPRM | 49 CFR Parts 192 & 195 |
| Pipeline Safety: Adjust Annual Report and NPMS Filing Timelines | PHMSA proposes extending annual report and NPMS submission deadlines for gas pipeline and storage operators to June 15 each year. | NPRM | 49 CFR Part 191 |
| Pipeline Safety: Editorial Corrections and Clarifications | PHMSA issued multiple final rules correcting editorial errors, updating references, removing obsolete submission methods, and improving regulatory clarity. | Final Rules | Various |
| Pipeline Safety: Update of Standards Incorporated by Reference | PHMSA issued multiple direct final rules updating incorporated industry consensus standards, including NFPA, ASTM, MSS, NACE, and ASME standards. | Multiple DFRs | 49 CFR Parts 192 & 195 |
Have questions about an upcoming deadline? Please reach out to Jessica Foley for assistance!
Featured Service
CorrosionIQ is a complete corrosion compliance and integrity management platform for pipeline operators.
From cathodic protection monitoring and CIS surveys to remediation tracking and compliance reporting, CorrosionIQ brings every component of your corrosion program together in a single system.
Collect data, manage inspections, track corrective actions, analyze trends, and demonstrate compliance with confidence.
Everything Your Corrosion Program Needs
CorrosionIQ covers the full corrosion lifecycle:
- Corrosion Work Management
- Cathodic Protection Monitoring
- CIS, DCVG, ACVG & ACCA Surveys
- Corrosion Remediation Tracking
- Corrosion Analytics & Reporting
- Dynamic Alignment Sheets
- GIS Mapping & Spatial Analysis
- Mobile Data Collection
- Compliance Documentation & Audit Support
Whether you’re managing transmission, gathering, distribution, hazardous liquid, or underground storage assets, CorrosionIQ provides a single source of truth for your entire corrosion program—helping your team spend less time managing data and more time protecting pipeline integrity.
Built for Pipeline Compliance
CorrosionIQ supports corrosion control requirements under 49 CFR Part 192 and 49 CFR Part 195, including:
- Cathodic protection (§192.463, §192.465, §195.573)
- Internal corrosion control (§§192.475–192.476, §195.579)
- Atmospheric inspections (§192.481, §195.583)
- External corrosion control (§§192.451–192.459, §§195.551–195.559)
- Integrity management programs (§§192.907–192.951, §195.452)
- Inline inspection and direct assessment (§192.921, §192.923, §195.452)
- Anomaly evaluation and repair (§192.933, §195.452)
- Reassessment intervals (§192.939, §195.452)
- Recordkeeping and documentation (§192.491, §195.589)
All requirements are tracked, scheduled, and documented in one place.
Why It Works
Most corrosion programs are spread across multiple systems. CorrosionIQ brings everything together so your team can:
- See the full picture
- Identify risk earlier
- Manage work in one place
- Reduce manual effort
- Stay compliant without the scramble
Did You Know?
The U.S. has more than 3.3 million miles of regulated pipelines. That’s enough pipeline to circle the Earth more than 130 times.
2026 Conference News
GPA Midstream Convention
September 20-23, 2026 | San Antonio Marriott Rivercenter on the River Walk | San Antonio, TX
This gathering is the ultimate destination for more than 1,800 midstream professionals from around the world. It’s your chance to connect, collaborate, and explore the latest industry trends and innovations.
Whether you’re an entry-level engineer, a seasoned technical expert, or a C-suite executive, the GPA Midstream Convention has something for everyone. Our diverse attendees hail from leading operating and supplier companies, ensuring a rich exchange of ideas and opportunities.
Click here to register for this event.
We’re Speaking!
Be sure to attend Chris McLaren’s presentation:
DOT Regulatory Update: PHMSA Priorities, Enforcement Trends, and the PIPES Act of 2026/ PHMSA and RRC Enforcement Trends and Updates
Monday, September 21 at 1PM
We would welcome the opportunity to discuss our services with you.
Sincerely,
W. R. (Bill) Byrd, PE
President
RCP Inc.