PHMSA Proposes Updates to Breakout Tank Inspection Requirements

[Docket No. PHMSA-2025-1271]

PHMSA has published a Notice of Proposed Rulemaking (NPRM) that would update the agency’s breakout tank inspection regulations under 49 CFR Part 195. The proposal would incorporate the 5th Edition of API Standard 653, replacing the currently referenced 3rd Edition, and would authorize operators to use Risk-Based Inspection (RBI) procedures when establishing inspection intervals for in-service breakout tanks.

A key feature of the proposal is the ability for operators to extend internal inspection intervals based on a documented RBI assessment. PHMSA is proposing a maximum interval of 20 years for an initial internal inspection and 25 years for subsequent inspections when supported by an RBI analysis. Operators choosing this approach would be required to maintain records supporting the assessment and identify RBI-managed tanks in annual reporting and NPMS submissions.

PHMSA estimates the proposed changes could save the industry between approximately $25 million and $150 million annually by reducing unnecessary internal inspections while maintaining safety through risk-informed decision-making. The agency is accepting comments on the proposal for 60 days following publication in the Federal Register.

Please message Jessica Foley for a copy of this NPRM.

PHMSA Clarifies MAOP Restoration Timeline Under Class Location Change Rule

[Docket No. PHMSA-2017-0151]

PHMSA has issued a technical correction to its January 14, 2026, final rule on Class Location Change requirements in 49 CFR §192.611.

The original rule allows operators to use an Integrity Management (IM) alternative to confirm or restore Maximum Allowable Operating Pressure (MAOP) on eligible gas transmission pipeline segments impacted by a class location change.

This latest action does not change the rule. It simply clarifies when the 24-month compliance timeline begins for MAOP restorations.

What Changed?

For operators restoring MAOP under the IM alternative, PHMSA confirms that the 24-month deadline runs from:

  • The effective date of the final rule, or
  • The date the operator decides to initiate the MAOP restoration,

whichever is later.

The correction makes clear that the decision date to restore MAOP is treated as the class location change date for purposes of starting the compliance clock.

Why This Matters for Pipeline Operators

This clarification removes ambiguity for both engineering and compliance teams.

If a Class 3 gas transmission segment was previously pressure-reduced due to a class location change, and you are now considering restoring MAOP using the IM alternative:

  • Your 24-month window starts when you formally decide to move forward with restoration (if later than the rule’s effective date).
  • There are no new technical requirements.
  • PHMSA confirms there are no additional compliance costs.

Practical Takeaway

For operators managing gas transmission pipelines, MAOP restoration, and integrity management programs, documentation matters.

Make sure your internal records clearly establish the date the MAOP restoration decision is made. That date now drives your compliance timeline under §192.611.

This correction provides regulatory clarity—not new obligations—but it reinforces the importance of coordination between engineering, regulatory, and administrative teams when planning MAOP restoration activities.

Please message Jessica Foley for a copy of this rule change.

PHMSA Names Thomas Correll as Associate Administrator for Pipeline Safety

PHMSA has named Thomas (Tom) Correll as its new Associate Administrator for Pipeline Safety. Correll brings more than 30 years of experience in pipeline safety, integrity management, environmental compliance, and risk management.

Prior to joining PHMSA, Correll served as Vice President of Pipeline Safety and Risk at Northern Natural Gas, where he led compliance and integrity management programs for a major interstate natural gas pipeline system. His experience includes PHMSA compliance, environmental permitting, engineering oversight, and large-scale infrastructure projects.

Correll’s appointment places an experienced pipeline industry leader at the helm of PHMSA’s pipeline safety program. Operators will be watching closely to see how his extensive background in pipeline operations and regulatory compliance influences the agency’s future priorities and initiatives.

Click here to access the official announcement from PHMSA.

PHMSA Releases Major Wave of Rulemakings

On April 24, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a sweeping set of 40 rulemakings to the Federal Register, including a mix of Final Rules, Direct Final Rules (DFRs), and Notices of Proposed Rulemaking (NPRMs) covering a wide range of pipeline safety topics.

The actions span multiple sections of the Federal Pipeline Safety Regulations and address subjects including:

  • Annual report and NPMS filing deadlines
  • MAOP reconfirmation requirements
  • Part 194 response plans
  • Remote sensing technologies for ROW patrols
  • Valve maintenance and rupture mitigation timelines
  • Corrosion control and remote monitoring
  • Hazardous liquid HCA designations
  • Updates to standards incorporated by reference

Among the releases were 15 Final Rules, several Direct Final Rules updating industry consensus standards, and numerous NPRMs that could significantly impact future compliance obligations for operators.

Several of the rulemakings were previously issued as Direct Final Rules but were rescinded after receiving adverse comments and have now been reproposed through the standard NPRM process.

Separately, PHMSA has submitted an NPRM to the Office of Management and Budget (OMB) regarding the Risk-Based Inspection Process for breakout tanks under American Petroleum Institute Standard 653. The proposal has reportedly been under OMB review since early April and is expected to publish soon.

Please message Jessica Foley for a breakdown of the various rulemakings.

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The Enforcement Corner

Enforcement SnapshotJune 2026
Reporting Period: May 2026
$673,930Proposed penalties
14Reported enforcement actions
5Listed violations

CAO: 1   NOA: 3   WL: 4   NOPV: 6  

Review the cited regulations, proposed penalties, and year-to-date enforcement trends in the complete report.

View Full Enforcement Report →

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 valve is remotely controlled, does it automatically meet the requirements for a rupture mitigation valve (RMV)?

A: No. While many RMVs are remotely controlled, simply having remote operation capability does not make a valve compliant. The valve must meet the applicable location, functionality, and closure-time requirements specified in the regulations.

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.

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Ongoing Resources

These articles are maintained and updated as new information becomes available.

Regulatory Watch: Key Dates & Deadlines

REGULATORY SNAPSHOT Last updated November 3, 2026
38Tracked regulations
8Proposed / DFR
18Final rules

Track PHMSA rulemaking, regulatory stages, and important compliance deadlines in RCP's Regulatory Watch.

View Full Regulatory Watch →
Last Updated: October 2026

Conference News

Jan252027

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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.…

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Event Details

Last Updated: November 2026

PSI Training Schedule

Date Training Course Price Registration
Nov 17 – Nov 19, 2026 DOT Pipeline Compliance Workshop $2,150 SOLD OUT
Feb 16 – Feb 18, 2027 Pipeline Safety Audit Training $2,150 Register →
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WEBINAR RECORDING!
Unpacking the Key Updates in API RP 1170 & 1171, 2nd Edition

RCP and the Pipeline Safety Institute offered a free webinar exploring the 2nd Editions of API RP 1170, Design and Operation of Solution-mined Salt Caverns Used for Natural Gas Storage and API RP 1171, Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs. Thank you to everyone who attended and participated in this informative webinar. The session recording is posted to our YouTube channel. Please watch, like, and subscribe to our channel!

WEBINAR RECORDING
Pipeline Safety: Unpacking the Class Location Change Requirements

Thank you to everyone who attended and participated in this informative webinar. The session recording is posted to our YouTube channel. Please watch, like, and subscribe to our channel!

New Workshop Alert!

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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,

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President
RCP Inc.