PHMSA Advisory Bulletin – Integrity Issue Regarding Microalloyed High Grade Line Pipe

[Docket No. PHMSA-2009-0148]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued Advisory Bulletin, ADB-09-01, “Pipeline Safety: Potential Low and Variable Yield and Tensile Strength and Chemical Composition Properties in High Strength Line Pipe” to owners and operators of natural gas pipeline and hazardous liquid pipeline systems. This advisory bulletin pertains to microalloyed high strength line pipe grades, generally Grade X-70 and above.

The Federal pipeline safety regulations in 49 CFR Parts 192 and 195 require operators of natural gas transmission, gas distribution, and hazardous liquids pipeline systems to use pipe manufactured by a listed specification in the design of pipelines in accordance with Sec. 192.7, 192.55 (a), 192.105, and Sec. 195.3, 195.106, and 195.112. Tests that have been conducted on line pipe that has been installed in pipeline systems have shown that some of the pipe material has yield strengths, tensile strengths, and/or chemical compositions that do not meet the requirements of the American Petroleum Institute, Specification for Line Pipe–5L, (API 5L), for PSL 2 and the specified pipe grade. PHMSA recently reviewed metallurgical testing results from several recent projects indicating pipe joints produced from plate or coil from the same heat may exhibit variable chemical and mechanical properties by as much as 15% lower than the strength values specified by the pipe manufacturer.

PHMSA wants to ensure that owners and operators of recently constructed pipeline systems are aware of the need to investigate whether their pipelines contain joints of pipe that do not meet minimum specification requirements.

For more information or a copy of ADB-09-01, contact Jessica Roger.

MMS NTL 2009-G14 Functional Responsibility of MMS Regulations

The Minerals Management Service (MMS) issued a Notice to Lessees (NTL) which updates the regulatory citations, primary functional responsibilities, and contact information for various MMS regulations, including those regulations that apply to pipeline operators on the Offshore Continental Shelf (OCS). It lists the regulatory citations and subject matter of the MMS regulations and provides the organizational office in the MMS Gulf of Mexico OCS Region (GOMR) with primary responsibility for the various functions and requirements contained therein.

NTL 2009-G14 is effective May 21, 2009 and supersedes NTL 2000-G03. For a copy of NTL 2009-G14, contact Jessica Roger.

Gas Distribution Leak Management System

Do you know what leak surveys are pending in the next 30 days and which ones are overdue?

Do you know exactly how many and what type of leaks are active on your system?

Do you know what leaks are scheduled for repair or re-survey next week?

Do you have a tool that manages and analyzes the data you will need for DIMP implementation?

Does your GIS system maintain survey, leak & repair history attributes?

How long will it take you to aggregate the leak data for the DOT Annual Report or Texas PS-95?

If you are interested in a tool that can give you the answers to these questions, contact Jessica Roger to schedule an online demonstration.

PHMSA Appoints State Damage Prevention Coordinator

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) has selected Annmarie Robertson, Pipeline Safety Manager for Indiana and the NAPSR Chairperson, as their State Damage Prevention Coordinator. Annmarie will report to Steve Fischer, the program manager. She will work with the PHMSA rulemaking staff on the Advance Notice of Proposed Rulemaking for federal excavation damage enforcement. She also will work with Zach Barrett’s group to support state regulators in improving damage prevention programs. Annmarie had much success with the recently passed Indiana damage prevention legislation. Michael Thompson, Pipeline Safety Chief for Oregon, is now the NAPSR chairman.

PHMSA Updates Integrity Management Notification FAQ’s

PHMSA has updated two FAQ’s relating to integrity management reporting requirements. For gas transmission, FAQ #97 was updated. For liquid pipelines, FAQ #12.1 was updated.

FAQ #97 (gas transmission pipelines)

Question: What types of notifications are required by the rule?

Answer: The notifications required by the rule are:

  • Substantial change to program implementation or significant change to schedule for carrying out elements. (Within 30 days of adoption). The notification should include a description of the changes and the basis on which they were made.
  • Inability to meet remediation deadlines in the rule and unable to reduce pressure (When operator determines schedules cannot be met). A description of defects/repairs needed, reason for delay, why pressure can’t be reduced, basis for concluding delay won’t jeopardize health or environment, schedule for repair, other mitigative actions planned should be included.
  • Use of technology other than in-line inspection, Direct Assessment, or pressure testing for conducting assessments. (180 days prior to assessment). The operator should provide a description of the "other technology", its basis for concluding that the method will result in equivalent understanding of pipe condition, and its schedule for assessment.

In addition, all notifications must include information about the pipe segments and HCAs involved.

  • Pressure reduction imposed as a result of IM anomalies extends for more than 365 days. The notification must explain the reasons for the delay and justify that the continued pressure reduction will not jeopardize the integrity of the pipeline.

FAQ #12.1 (hazardous liquid pipelines)

12.1 What types of notifications are required by the rule?

The notifications required by the rule are:

Circumstance/Type

Deadline for Submittal

Information Required

Inability to meet remediation deadlines in the rule and unable to reduce pressure

When operator determines schedules cannot be met

Description of defects/repairs needed, reason for delay, why pressure can’t be reduced, basis for concluding delay won’t jeopardize health or environment, schedule for repair, other mitigative actions planned

Pressure reduction will exceed 365 days

When pressure reduction exceeds 365 days

Reasons for the delay, description of additional remedial actions

Use of technology other than in-line inspection, pressure testing, or external corrosion direct assessment for conducting assessments

90 days prior to assessment

Description of “other technology”, basis for concluding equivalent understanding of pipe condition, schedule for assessment

Variance from 5-year re-assessment interval (unavailable technology)

180 days before end of 5-year interval

Date and method of last assessment, reason why required interval cannot be met, interim evaluation of pipe integrity, schedule for assessment

Variance from 5-year re-assessment interval (engineering basis)

270 days before end of 5-year interval

Date and method of last assessment, proposed new retest interval, actions that will provide equivalent understanding of pipe condition, summary of engineering basis

In addition, all notifications must include information about the pipe segments and HCAs involved.

The on-line integrity management notification system is also being used to allow operators to submit notification of their intent to move biofuels in their pipelines. These notifications are not required by regulation. PHMSA has asked that operators voluntarily notify when they intend to use their pipelines for biofuel transportation.

PHMSA Announces THLPSSC and TPSSC Appointments

PHMSA has announced the rosters of government, industry and public representatives that will serve on the Technical Hazardous Liquid Pipeline Safety Standards Committee and the Technical Pipeline Safety Standards Committee. These committees meet at least twice yearly to review and to report on proposed Federal pipeline safety standards submitted to it by the Department of Transportation. The committees provide peer reviews of all proposed pipeline safety rules to assure technical feasibility, reasonableness, cost-effectiveness and practicability. They also evaluate cost-benefit analysis and risk assessment information on each proposal.

Technical Hazardous Liquid Pipeline Safety Standards Committee:

  • John S. Bresland – U.S. Chemical Safety and Hazard Investigation Board (CSB)
  • Elmer P. Danenberger – U.S. Department of Interior Minerals Management Service
  • Drue Pearce – Alaska Natural Gas Transportation Projects
  • Larry J. Davied – Magellan Midstream Partners, L.P.
  • Denise M. Hamsher – Enbridge (USA) Pipeline
  • Orville B. Harris – Longhorn Partners Pipeline, LP
  • Craig O. Pierson – Marathon Ashland Pipe Line LLC
  • Larry M. Shelton – Buckeye Partners LP
  • Timothy P. Butters – City of Fairfax Virginia
  • Geraldine E. Edens – Counsel, McKenna, Long, & Aldridge, LLP
  • Richard B. Kuprewicz – Accufacts, Incorporated
  • Lisa M. Parker – Parker Horn Company
  • Carl M. Weimer – Pipeline Safety Trust

Technical Pipeline Safety Standards Committee:

  • Drue Pearce – – Alaska Natural Gas Transportation Projects
  • Lisa P. Edgar – Florida Public Utilities Commissioner
  • Berne L. Mosley – Federal Energy Regulatory Commission
  • Donald J. Stursma – Iowa Utilities Board
  • Michael R. Comstock – City of Mesa, Arizona
  • J. Andrew Drake – Spectra Energy
  • Jeryl L. Mohn – Panhandle Energy
  • James F. Wunderlin – Southwest Gas Corporation
  • Peter G. Terranova – UGI Utilities, Incorporated
  • Richard E. Feigel – Hartford Steam Boiler
  • Theodore C. Lemoff – National Fire Protection Association
  • Richard F. Pervarski – Virginia Utility Protection Services, LLC
  • Paul S. Rothman – The Port Authority of New York and New Jersey
  • Alan R. Shuman – Georgia State Fire Marshal

Georgia Damage Prevention Regulations – Revision

The State of Georgia has revised its damage prevention regulations in:

  • Title 515 – Georgia Public Service Commission;
  • Chapter 9 – Safe Installation and Operation of Natural Gas Transmission and Distribution Systems;
  • Rule 3 – Enforcement Procedures Governing Gas Pipeline Safety;
  • 9-3 Enforcement Procedures Governing Gas Pipeline Safety

Section 515-9-3-.14 "Utilities Protection Center" and the new Section 515-9-3-.15 "Damage Prevention" require that all Owners and/or Operators of a buried utility facility in Georgia shall be a member of the State-wide Utilities Protection Center, and that all Owners and/or Operators of a buried utility facility in Georgia shall comply in all respects, with Title 25, Chapter 9 of the Official Code of Georgia Annotated. The previous regulations only required that gas distribution systems comply with those requirements.

Government/Industry Pipeline R&D; Forum June 24-25, 2009

Government/Industry Pipeline R&D; Forum

June 24-25, 2009

The Government/Industry Pipeline R&D; Forum will be in Crystal City, Virginia June 24 – 25, 2009. This event is organized through a strong research enterprise between the Pipeline and Hazardous Materials Safety Administration, other State and Federal agencies and with North American natural gas and hazardous liquid pipeline operators. The forum will bring government and industry pipeline stakeholders together for the following purpose(s):

  • Develop a consensus agenda of technical gaps & challenges for future R&D;
  • Identify both short and long term research objectives for liquid/gas and transmission and gas distribution pipelines;
  • Conduct basic road mapping on identified technical gaps so solicited research is addressing the need effectively; and
  • Provide details of the ultimate research goals so appropriate end users are factored into project scopes.

Pre-forum registration closes June 19. Click here for a draft agenda, registration and hotel information. The agenda will be updated weekly as the date approaches.

RCP Presentations at the AGA Conference

The AGA Operations Conference and Biennial Exhibition was held on May 19 – 21 at the David L. Lawrence Convention Center in Pittsburgh, PA. Over 1300 industry employees attended the Operations Conference, Committee Meetings and Exhibition.

During the Distribution & Transmission Engineering Session 23, Larry Decker, presented his paper on calculating Maximum Allowable Operating Pressure (MAOP) for changing pipeline conditions. This presentation focused on lessons learned from calculating MAOP, including: what the regulations require for MAOP analysis, what the critical/non-critical data are to justify current MAOP, the MAOP formula decision tree and best practices for maintaining MAOP data. (Request a copy)

RCP representatives were at the Biennial Exhibition to demonstrate our extremely popular Leak Tracking System. There is nothing on the market like this web-based tool that effectively manages leak survey, inspection, repair and evaluation work flow all while providing a great tool to comply with upcoming DIMP requirements. If you were unable to attend, or missed the demonstration, contact Jessica Roger for a demo or more information.

Save the Dates!

If you were unable to attend our June 2 & 3 workshop, the next workshop will be held on

October 6 & 7 (Tuesday & Wednesday) – Houston, TX

Visit our Seminars webpage for updates & registration information.

FERC Workshop on Pipeline Siting and Stakeholder Involvement

The June 2nd edition of the Federal Register contained a notice that the Pipeline Siting and Stakeholder Involvement Workshop would be webcast. The workshop was held on June 1, 2009, and included a Case study of CenterPoint Energy's Carthage to Perryville Pipeline Project, presented by Debbie Ristig (CenterPoint Energy's Vice President Engineering and Compliance); and a Stakeholder Outreach Panel Discussion.

The recording is available online for the next 3 months at: http://www.capitolconnection.gmu.edu/ferc/060109/ferc060109.htm.

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 WatchImplementation Stage

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

Proposed
Final
ImplementationJul 2, 2040
2137-AF45Proposed Rule Stage

Amendments to Liquefied Natural Gas Facilities

Proposed
Final
Implementation
2137-AF61Final Rule Stage

Cost Recovery for Siting Reviews for LNG Facilities

Proposed
Final
Implementation
2137-AF51Final Rule Stage

Gas Pipeline Leak Detection and Repair

Proposed
Final
Implementation
Regulatory WatchImplementation Stage

Gas Transmission: Assessments Outside HCAs § 192.710

Proposed
Final
ImplementationJul 1, 2034
2137-AF37Proposed Rule Stage

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

Proposed
Final
Implementation
2137-AF52Proposed Rule Stage

Pipeline Operational Status

Proposed
Final
Implementation
2137-AF44Proposed Rule Stage

Repair Criteria for Gas and Hazardous Liquid Pipelines

Proposed
Public comments ClosedCloses Sep 8, 2026
Final
Implementation
2137-AF60Proposed Rule Stage

Safety of Carbon Dioxide and Hazardous Liquid Pipelines

Proposed
Final
Implementation
2137-AF53Final Rule Stage

Safety of Gas Distribution Pipelines and Other Pipeline Safety Initiatives

Proposed
Final
Implementation

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

Conference News

Jan252027

Pipeline Pigging and Integrity Management Conference

▦ January 25, 2027 – January 28, 2027⌖ 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.…

ExhibitingBooth 524
RCP Team Attending
Heather RoarkHeather RoarkSales & Marketing Coordinator
Jessica FoleyJessica FoleyVice President
Featured Presentations
Chris McLaren
Chris McLarenExecutive Consultant
October 27, 2026 at 7:30 AM
Event Details
Last Updated: October 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 →
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

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.