Quarterly Performance Review Meeting on The Cooperative Agreement “Better Understanding of Mechanical Damage in Pipelines”

RSPA, along with GTI, invite the pipeline industry, in-line inspection ("smart pig") vendors, and the general public to a quarterly performance review meeting to report on progress with this research titled "Better Understanding of Mechanical Damage in Pipelines" on Thursday, September 27, 2001, beginning at 9 a.m. and ending around noon at the Sheraton Buckhead Hotel, 3405 Lenox Road, NE., Atlanta, GA. Attendance at this meeting is open to all and does not require advance registration or advance notice to RSPA. This work is being managed by GTI and performed by Battelle Memorial Institute (Battelle), along with the Southwest Research Institute (SwRI). The meeting will cover a review of the overall project plan, the status of the contract tasks, progress made during the past quarter, and projected activity for the next quarter.

RSPA wants the pipeline industry and especially that segment of the pipeline industry involved with in-line inspection to be aware of the status of this research. The meetings allow disclosure of the results to interested parties and provide an opportunity for interested parties to ask questions concerning the research. Each of the semi-annual meetings will be announced in the Federal Register at least two weeks prior to the meeting. The quarterly performance review meetings held between the semi-annual meetings described above will be held in conjunction with GTI/PRCI Technical Committee meetings.

This research continues work that DOT supported at Battelle to improve in-line inspection of mechanical damage and more closely coordinates work that GTI is supporting at Southwest Research Institute to develop critical assessment criteria based on these NDE measurements. This program extends the work conducted under the RSPA-funded contract "Detection of Mechanical Damage in Pipelines" by looking at the circumferential magnetic flux leakage field instead of the traditional axial field and extends the critical assessment criteria research to work with full scale samples that are being used for MFL measurements. The goal of the research is to evaluate and develop techniques for assessing pipeline metal loss, mechanical damage, and cracks using circumferential MFL. These techniques are expected to complement the techniques used for axial MFL systems.

The research will extend the failure assessment methodology for mechanically damaged pipes to include the influence of local cold working due to the gouging/denting process on the pipe's remaining life. The program will combine full scale tests and MFL monitoring of pipes, laboratory tests and elastic-plastic finite element analyses to develop a validated methodology for determining the remaining life of a damaged pipe. The SwRI research will complement the work at Battelle in developing criteria for characterizing mechanical damage found through in-line inspection.

FOR FURTHER INFORMATION CONTACT: Lloyd W. Ulrich, Agreement Officer's Technical Representative, Office of Pipeline Safety, telephone: (202) 366-4556, FAX: (202) 366-4566, e-mail: lloyd.ulrich@rspa.dot.gov. You may also contact Harvey Haines, Principal Investigator, GTI, telephone: (847) 768-0891, FAX: (847) 768-0501, e-mail: harvey.haines@gastechnology.org.

PREP Guideline Revisions

The National Schedule Coordinating Committee (USCG, EPA, MMS and OPS) has completed draft revisions to the National Preparedness for Response Exercise Program (PREP) Guidelines. The current draft is available on RCP's website HERE. The committee is in the process of publishing another Federal Register Notice which will extend the comment period till the end of September. Public review and comment of these proposed changes is invited. Comment directly to the docket which is accessible at http://dms.dot.gov (docket # is 7514). No public workshop has been scheduled at this point pending response to the proposed changes.

Service Reminder : RCP has developed dozens of oil spill response plans, for small oil and gas producers up to some of the largest facilities in the world. We also provide a PREP drill coordination and tracking service. Contact Mr. Ron McCoy at Ron@your-rcp.com, (713-655-8080) to discuss these services in more detail.

Upcoming RCP Seminars

RCP will conduct a 2 day workshop on DOT Pipeline Regulations on September 18th and 19th in Houston. This workshop will present an overview of all the current DOT regulations for pipeline operators, including recent regulatory initiatives such as operator qualification and pipeline integrity management. It will be followed by a half day workshop on September 20th dedicated to OPA-90 oil spill response planning for DOT pipelines. Both of these workshops are suitable for personnel who need a general introduction to DOT pipeline regulatory requirements. Additional information is available on our website HERE.

Pending Audits?

Has the DOT notified you of a pending audit? RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency's latest standards.

Meeting Notification-Technical Hazardous Liquid Pipeline Safety Standards Advisory Committee

The Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC) will meet on Monday, August 13, 2001 from 10:00 a.m. to 12:00 p.m. to discuss comments received and vote on Section 195.452(h) of the final rule for Pipeline Integrity Management in High Consequence Areas (Hazardous Liquid Operators With 500 or More Miles of Pipeline), as published on December 1, 2000. The THLPSSC will also discuss and vote on the proposed rule "Pipeline Integrity in High Consequence Areas (Hazardous Liquid Pipelines With 500 Miles or Less of Pipeline)," which was published on March 25, 2001 (66 FR 15821). A copy of the proposed rule can be found on the Internet-OPS Docket Management System http://dms.dot.gov (Docket Number 7408).

The THLPSSC is a statutorily mandated advisory committee that advises RSPA's OPS on proposed safety standards and other safety policies for hazardous liquid pipelines. The committee consists of 15 members-five each representing government, industry, and the public. Members of the public may attend the meeting in person at the Department of Transportation, Nassif Building, Room 7128, 400 Seventh Street, SW, Washington, DC 20590. Due to limited space, anyone wishing to attend or participate should notify Juan Carlos Martinez, at (202) 366-1933, not later than July 30, 2001. FOR FURTHER INFORMATION CONTACT: Cheryl Whetsel, OPS, (202) 366-4431 or Richard Huriaux, OPS, (202) 366-4565.

Acquiring a pipeline?

RCP can provide due diligence audits to help you ensure that potential compliance issues have been addressed before the sale is final.

RSPA Pipeline Integrity Management Workshops

As compliance deadlines approach for OPS's first integrity management rule (see RCP's December, 2000 newsletter)HERE, OPS is hosting two workshops to promote a better understanding of the new requirements, and to discuss compliance approaches operators are applying to various aspects of the rule. OPS will host additional workshops if needed.

The first workshop will be on August 7-8, 2001, from 8:30 a.m. to 5 p.m., at the DoubleTree Hotel Post Oak, 2001 Post Oak Boulevard, Houston, Texas, 77056, 713-961-9300 or 800-566-5216. Click HERE for the agenda. The second workshop will be on October 10-11, from 8:30 a.m. to 5 p.m., at the Renaissance Houston Hotel, 6 Greenway Plaza East, Houston, Texas, 77046, 713-629-1200 or 800-Hotels-1. No later than September 12, 2001, rooms may be reserved within a block identified as "DOT/IMP Public Meeting Block".

Each workshop will be two days long, and will cover the same topics. On Day 1, OPS will familiarize participants with the new requirements, and present and seek comments on the approach OPS plans to use for achieving compliance. On Day 2, OPS will provide a forum for participants to share and discuss noteworthy integrity management practices that achieve compliance with the rule. Via the presentations, OPS hopes to encourage a peer-to-peer exchange among operators of innovative approaches being developed to enhance pipeline integrity and comply with the rule. Each presentation will be followed by an open discussion among meeting participants. Based on these discussions, OPS will kick-off development of an on-line forum that will enable continued exchanges between federal and state regulators, representatives of public interest and environmental organizations, the pipeline industry, and other interested parties about noteworthy practices.

FOR FURTHER INFORMATION CONTACT: Beth Callsen, tel: 202-366-4572; E-mail: beth.callsen@rspa.dot.gov. For event planning purposes, please let Ms. Callsen know if you will attend. Also notify Ms. Callsen if you are interested in being a presenter on Day 2 of one or both of the workshops (note – DOT is only looking for pipeline operators to make presentations – not consultants).

EPA Issues Corrections to Oil and Gas NESHAP

On June 17, 1999, EPA issued the national emission standards for hazardous air pollutants (NESHAP) from Oil and Natural Gas Production Facilities and the national emission standards for hazardous air pollutants from Natural Gas Transmission and Storage Facilities (Oil and Gas NESHAP) (64 FR 32610). The Oil and Gas NESHAP require new and existing major sources to control emissions of hazardous air pollutants (HAP) to the level reflecting application of the maximum achievable control technology (MACT). On June 28, 2001, EPA issued technical corrections that clarify intent and correct errors in the Oil and Gas NESHAP. These corrections become effective June 29, 2001. These editorial, cross-referencing and clarifying corrections are minor in nature and are noncontroversial. However, they do contain clarifications of jurisdiction that could be important to the gas transmission industry. The corrections document is available on the Technology Transfer Network (TTN) at http://www.epa.gov/ttn/oarpg.

Natural Resource Damage Assessments – Proposed Rule Revisions

On July 30, 2001, the National Oceanic and Atmospheric Administration (NOAA) proposed amendments to their Natural Resource Damage Assessment rule in 15 CFR 990. The proposal addresses issues from a recent court ruling, and includes some clarifying and technical amendments in other parts of the regulation. This rule will affect companies that are held responsible for natural resource damages for oil and other hazardous substance spills, including liquid pipeline operators and dock operators. The entire notice can be downloaded from RCP's website HERE.

In the event of a discharge or substantial threat of a discharge of oil (incident), the Oil Pollution Act of 1990 (OPA-90), provides that federal, state, Indian tribal, and/or foreign natural resource trustees assess natural resource damages and develop and implement a plan for the restoration, rehabilitation, replacement, or acquisition of the equivalent, of the injured natural resources and their services under their trusteeship. Congress directed the National Oceanic and Atmospheric Administration (NOAA) to promulgate regulations for the assessment of natural resource damages resulting from an incident (OPA section 1006(e)(1)). NOAA promulgated final regulations on January 5, 1996 (see 61 FR 440), codified at 15 CFR Part 990.

Under these OPA regulations, trustees conduct natural resource damage assessments in the open, with responsible parties and the public involved in the planning process to achieve restoration more quickly, decrease transaction costs, and avoid litigation. These restoration plans form the basis of claims for natural resource damages. Under the natural resource damage assessment regulation, trustees then present a demand comprised of the final restoration plan to responsible parties for funding or implementation.

Help Wanted

Know someone with regulatory expertise who is interested in full or part time work? Our recruiting coordinator would be glad to get their resume! Have them sent to chandra@your-rcp.com, or FAX to 713-655-8083.

Ongoing Resources

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

Last Updated: October 2026

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.

2137-AF63Proposed Rule Stage

Administrative Rulemaking Regulatory Procedures

Proposed
Final
Implementation
Regulatory Agenda2137-AF63
Federal Register DocumentPHMSA-2026-1555
Regulatory WatchImplementation Stage

All Liquid HCA segments capable of ILI § 195.452(n)

Proposed
Final
ImplementationJul 2, 2040
Regulatory AgendaNot available
Federal Register DocumentNot available
2137-AF45Proposed Rule Stage

Amendments to Liquefied Natural Gas Facilities

Proposed
Final
Implementation
Regulatory Agenda2137-AF45
Federal Register DocumentPHMSA-2019-0091
2137-AF61Final Rule Stage

Cost Recovery for Siting Reviews for LNG Facilities

Proposed
Final
Implementation
Regulatory Agenda2137-AF61
Federal Register DocumentPHMSA-2022-0118
2137-AF51Final Rule Stage

Gas Pipeline Leak Detection and Repair

Proposed
Final
Implementation
Regulatory Agenda2137-AF51
Federal Register DocumentPHMSA-2021-0039
Regulatory WatchImplementation Stage

Gas Transmission: Assessments Outside HCAs § 192.710

Proposed
Final
ImplementationJul 3, 2034
Regulatory AgendaNot available
Federal Register DocumentNot available
2137-AF37Proposed Rule Stage

Oil Spill Response Plans, Accident Notifications, Inspections and Investigations and other Miscellaneous Pipeline Safety Changes

Proposed
Final
Implementation
Regulatory Agenda2137-AF37
Federal Register DocumentPHMSA-2018-0047
2137-AF52Proposed Rule Stage

Pipeline Operational Status

Proposed
Final
Implementation
Regulatory Agenda2137-AF52
Federal Register DocumentNA
2137-AF44Proposed Rule Stage

Repair Criteria for Gas and Hazardous Liquid Pipelines

Proposed
Public comments ClosedCloses Sep 8, 2026
Final
Implementation
Regulatory Agenda2137-AF44
Federal Register DocumentPHMSA-2025-0019
2137-AF60Proposed Rule Stage

Safety of Carbon Dioxide and Hazardous Liquid Pipelines

Proposed
Final
Implementation
Regulatory Agenda2137-AF60
Federal Register DocumentNA
2137-AF53Final Rule Stage

Safety of Gas Distribution Pipelines and Other Pipeline Safety Initiatives

Proposed
Final
Implementation
Regulatory Agenda2137-AF53
Federal Register DocumentPHMSA-2021-0046

Sprint I & II Update

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.

Rulemaking Description Stage Code
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

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.

Rulemaking Description Stage Code
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!

Last Updated: October 2026

PSI Training Schedule

[rcp_psi_training]

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!

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.

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