September 2026 Issue
In This Issue
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.
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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.
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.
Conference News
PPIM 2027
January 25-28 | George R. Brown Convention Center | Houston, TX
The 39th International Pipeline Pigging & Integrity Management Conference (PPIM) will take place at the George R. Brown Convention Center in Houston. The event brings together pipeline operators, engineers, and industry professionals to explore advancements in pipeline inspection, integrity management, risk assessment, and emerging technologies. Attendees can participate in technical presentations, training courses, and an exhibition showcasing the latest industry solutions.
Click here to register for this event.
We would welcome the opportunity to discuss our services with you.
Sincerely,
W. R. (Bill) Byrd, PE
President
RCP Inc.