Spotlight on: Joel Kohler
La Department of Natural Resources, Office of Pipeline Safety
Mr. Joel E. Kohler began with the Department of Natural Resources in 1983 and was employed for 6 ½ years as the Sole Engineer with the State Mineral Board staff. He later worked for 3 years as Chief of Pipeline Operations with the Office of Conservation. He held the position of Chief of Pipeline Safety from March of 1993 to October 1997 at which time he was promoted to Assistant Director of the Pipeline Division.
Mr. Kohler is a native of St. Landry Parish. He attended LSU in Baton Rouge where he received a Bachelors of Science in Petroleum Engineering in 1982. He is licensed as a Professional Engineer in both Petroleum Engineering and Environmental Engineering.
He represents Louisiana on the National Association of Pipeline Safety Representatives (NAPSR) where he is presently the National NAPSR Vice-Chairperson and is slotted for the position of National NAPSR Chairperson in year 2000. He also participates in numerous National committees and performance review teams.
He is an avid supporter of and participates in various charity drives and functions, in addition to assisting in his children's school functions and sporting events. If he has any spare time he likes to do a little fishing and hunting.
Is your oil or gas pipeline system due for a DOT inspection? RCP, Inc. can provide confidential internal auditing to help ensure that your facility is up to the agency's latest standards.
Year 2000 Random Drug Testing
In the November 30, 1999 Federal Register Vol. 64, No. 229 p.66788, RSPA announced that the minimum random drug testing rate for the pipeline industry will be maintained at 25 percent of the covered employees for the period of January 1, 2000, through December 31, 2000. Remember that your MIS reports are due to the Office of Pipeline Safety, Research and Special Programs Administration, DPS-23, Room 7128, 400 7th Street SW., Washington, DC 20590, not later than March 15 each calendar year.
Operator Qualification
Once again this month, we will evaluate a task with the 4-part test as required by the Operator Qualification Rule. As we discussed last month, it is not always an easy decision when deciding whether or not a task is covered.
Is repairing a pipeline leak a covered task?
What do you think about these questions? Please email your comments on this or other tasks that you would like to have included in future newsletters to tdhollowell@your-rcp.com.
Too many big fat plans hogging all your shelf space? Too much information, but too hard to find what you need? Ask RCP about putting all the information you need on a CD-ROM. Thousands of pages of information – all in a simple point-and-click format. Everything can be searched for specific words in a moment. And think of the trees you will save!
Pipeline Safety: Safety and Environmental Protection
Pipeline Safety: Enhanced Safety and Environmental Protection for Gas Transmission and Hazardous Liquid Pipelines in High Consequence Areas
Don't forget that written comments considering the need for additional safety and environmental regulations for gas transmission lines and hazardous liquid pipelines in high-density population areas, waters where a substantial likelihood of commercial navigation exists, and areas unusually sensitive to environmental damage must be submitted to the Dockets Facility by December 20, 1999.
Need to permit a new facility? RCP's expert staff can handle the entire permitting process. We have decades of experience with all types of permitting and authorizations, and have professional engineering registrations throughout the Gulf Coast.
Operator Qualification Comments
Ken Vanover with Mobil responded to our questions in last month's newsletter concerning flyover inspections and the Operator Qualification rule, stating that an operator should consider the spirit of the rule when making an interpretation. The routine flyover inspections are very valuable in assisting the operator with identification of pipeline problems, and should be considered within the scope of the operator qualification rule.
Oil Spill Worse Case Discharge
RCP is currently working to develop more precise methods to estimate the worst case discharge (WCD) for long oil pipelines. The default method is to assume the entire volume of oil in the pipeline between block valves is lost during a worst case discharge spill. However, numerous factors can have a significant impact on the volume of oil that could actually leak from a damaged pipeline – including pipeline diameter, pipe elevation profile, oil compressibility, and pipeline wall thickness versus operating pressure. If you would like to participate in development of this WCD calculation methodology, please contact Bill Byrd at wrbyrd@your-rcp.com.
System Integrity Inspection (SII) Pilot Program
The Office of Pipeline Safety (OPS) has completed an initial screening of three candidate companies for the System Integrity Inspection (SII) Pilot Program – Conoco Pipe Line Company, El Paso Natural Gas Company, and Portland Pipe Line Corporation. The System Integrity Inspection (SII) Pilot Program is designed to test whether a more broad-based examination of an operator's safety and pipeline integrity programs, including many areas not currently considered during a typical inspection, will improve performance. Although OPS will continue to require an operator's compliance with the pipeline safety regulations, under the SII approach, an SII Team (composed of OPS and interstate agency personnel) will work cooperatively with the operator to address pipeline system integrity issues, including areas that the regulations may not address. Before making its final selection of SII Pilot Program participants, OPS invites public comment on any aspect of a candidate company's participation in the SII Pilot Program. Each company's Application Letter is available via an internet-accessible information system that can be reached through the OPS web site at http://ops.dot.gov. This web site contains descriptive information about the SII Pilot Program, frequently asked questions and answers, and access to program-related documents. OPS will announce its selections of SII Pilot Program participants through the web site. After selection, information on a company's performance will be available through this site. The SII web site also supports OPS's on-going communication and outreach efforts by providing an opportunity for the public to communicate directly to OPS using the "Feedback" feature on the web site. OPS welcomes comments and input throughout the SII Pilot Program. The full Federal Register notice concerning this program is available on RCP's website at
http://www.your-rcp.com/PipelineIntegrityProgram.htm
Visit Regulatory Compliance Partners on the Web at
or give us a call at 1-888-RCP-X-YES to see what we can do for you.
These articles are maintained and updated as new information becomes available.
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.
Administrative Rulemaking Regulatory Procedures
All Liquid HCA segments capable of ILI § 195.452(n)
Amendments to Liquefied Natural Gas Facilities
Breakout Tank
Coastal Ecological Unusually Sensitive Areas
Cost Recovery for Siting Reviews for LNG Facilities
Gas Pipeline Leak Detection and Repair
Gas Transmission: Assessments Outside HCAs § 192.710
Oil Spill Response Plans, Accident Notifications, Inspections and Investigations and other Miscellaneous Pipeline Safety Changes
Pipeline Operational Status
Repair Criteria for Gas and Hazardous Liquid Pipelines
Safety of Carbon Dioxide and Hazardous Liquid Pipelines
Safety of Gas Distribution Pipelines and Other Pipeline Safety Initiatives
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!
Regulatory Watch
RCP Regulatory Rulemaking Report | Updated October 17, 2026
This report reflects published Regulatory Watch records maintained by RCP. Dates and references are displayed only where entered.
Proposed (7)
| Rulemaking | Reference | Milestones |
|---|---|---|
| Administrative Rulemaking Regulatory ProceduresProposed |
RIN: 2137-AF63
Federal Register: PHMSA-2026-1555
|
No dates recorded |
| Amendments to Liquefied Natural Gas FacilitiesProposed |
RIN: 2137-AF45
Federal Register: PHMSA-2019-0091
|
No dates recorded |
| Breakout TankProposed |
RIN: 2137-AG22
Federal Register: PHMSA-2025-1271
|
No dates recorded |
| Oil Spill Response Plans, Accident Notifications, Inspections and Investigations and other Miscellaneous Pipeline Safety ChangesProposed |
RIN: 2137-AF37
Federal Register: PHMSA-2018-0047
|
No dates recorded |
| Pipeline Operational StatusProposed |
RIN: 2137-AF52
Federal Register: NA
|
No dates recorded |
| Repair Criteria for Gas and Hazardous Liquid PipelinesProposed |
RIN: 2137-AF44
Federal Register: PHMSA-2025-0019
|
Comments close: Sep 8, 2026 |
| Safety of Carbon Dioxide and Hazardous Liquid PipelinesProposed |
RIN: 2137-AF60
Federal Register: NA
|
No dates recorded |
Final (4)
| Rulemaking | Reference | Milestones |
|---|---|---|
| Coastal Ecological Unusually Sensitive AreasFinal |
RIN: 2137-AF31
Federal Register: PHMSA-2017-0152, Amdt. No. 195-104
|
No dates recorded |
| Cost Recovery for Siting Reviews for LNG FacilitiesFinal |
RIN: 2137-AF61
Federal Register: PHMSA-2022-0118
|
No dates recorded |
| Gas Pipeline Leak Detection and RepairFinal |
RIN: 2137-AF51
Federal Register: PHMSA-2021-0039
|
No dates recorded |
| Safety of Gas Distribution Pipelines and Other Pipeline Safety InitiativesFinal |
RIN: 2137-AF53
Federal Register: PHMSA-2021-0046
|
No dates recorded |
Implementation (2)
| Rulemaking | Reference | Milestones |
|---|---|---|
| All Liquid HCA segments capable of ILI § 195.452(n)Implementation |
RIN: Not available
Federal Register: Not available
|
Effective / implementation date: Jul 2, 2040 |
| Gas Transmission: Assessments Outside HCAs § 192.710Implementation |
RIN: Not available
Federal Register: Not available
|
Comments close: Sep 8, 2026 Effective / implementation date: Jul 3, 2034 |
Conference News
Pipeline Pigging and Integrity Management Conference
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.…
RCP Team Attending
Heather RoarkSales & Marketing Coordinator
Jessica FoleyVice President🎤 Featured Presentations
Topic to be determined

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 → |
| Feb 23 – Feb 25, 2027 | Advanced Pipeline Risk Assessment Workshop | $2,150 | Register → |
| Mar 23 – Mar 25, 2027 | DOT Pipeline Compliance Workshop | $2,150 | Register → |
WEBINAR RECORDING!
Unpacking the Key Updates in API RP 1170 & 1171, 2nd Edition
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!
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.
Season’s Greetings from RCP!
RCP would like to thank our valued clients for a wonderful year. We appreciate the opportunities you have given us to serve as your Professional Engineers, Regulatory Experts, and Trusted Partners. We look forward to working with you on even more projects in the years ahead. Best wishes for the holiday season and the New Year, from your friends at RCP.
Sincerely,
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W. R. (Bill) Byrd, PE
President
RCP Inc.
- Spotlight on: Joel Kohler
- Year 2000 Random Drug Testing
- Operator Qualification
- Pipeline Safety: Safety and Environmental Protection
- Operator Qualification Comments
- Oil Spill Worse Case Discharge
- System Integrity Inspection (SII) Pilot Program
- Ongoing Resources
- Regulatory Watch: Key Dates & Deadlines
- Conference News
- PSI Training Schedule


