Texas Railroad Commission Adopts New Rule Requiring Integrity Management Plans

The Texas Railroad Commission Adopts New Rule Requiring Integrity Management Plans for Natural Gas and Hazardous Liquids Pipelines:

On April 10, 2001, the Texas Railroad Commission (TRRC) issued new regulations requiring integrity management plans for all natural gas and hazardous liquids pipelines within the state. The rule includes changes to the draft rule published in the Texas Register on November 24, 2000 and will be in 16 TAC Chapter 8 entitled "Pipeline Safety Regulations." Operators with both intrastate and interstate pipelines may use an assessment plan developed for interstate facilities provided that the interstate plan meets the requirements of the new § 8.101.

The rule requires Operators to develop pipeline integrity assessment and management plans for all intrastate transmission and gathering lines subject to 49 CFR 192 or 49 CFR 195. Each Operator's plan must be completed by February 1, 2002 on a system-by-system or segment within each system basis. An Operator may select either a "risk based" or a "prescriptive plan" assessment approach. The rule requires Operators to utilize either hydrostatic testing or in-line inspection for integrity assessments or to have TRRC's prior approval before using an alternative integrity assessment method such as direct assessment. Reassessment requirements and treatment of offshore segments are also addressed in the rule. Operators must notify the TRRC when the plan is complete and then TRRC staff has 185 days to either accept the plan or determine which sections are not in compliance.

If an Operator selects the "risk based" assessment approach, 50% of the initial integrity assessments must be completed by January 1, 2006 with the balance complete by January 1, 2011. The Operator must perform a risk analysis for each segment that considers such factors as population density, prior in-line inspection results, consequences of a leak or failure, previous leak history, etc. The Operator then ranks the results of the risk analyses and performs its first integrity assessments on those segments having the greatest risk

For Operators electing the "prescriptive plan", the rule contains tables that identify by service, pipe size and location the deadlines for making initial integrity assessments. Certain specified initial assessments must be complete by January 1, 2006 with all other initial assessments finished by January 1, 2011.

Upcoming RCP Seminars

RCP will conduct a 2 day workshop on DOT Pipeline Regulations on May 15 and 16th 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 May 17th 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.

Due to a delay in mailing the registration materials for this seminar, the early registration discount is being extended to May 4th, 2001.

RCP will repeat our 2 day workshop on Pipeline Integrity Management on July 17 and 18th in Houston. This workshop presents a detailed analysis of the recent federal Pipeline Integrity Management regulation and the management programs / elements that it requires. We will also review recent state initiatives / proposed rules on pipeline integrity management. On the 18th we will discuss various methods of actually conducting a risk assessment for pipeline segments, and will work though several hands-on examples. We received very positive feedback from the Pipeline Integrity Management workshop that we conducted in March, and expect the July session to fill up rapidly. Additional information is available on our website HERE.

Drug Testing Regulations – Proposed Changes

On April 30, 2001, the Office of Pipeline Safety proposed to conform the pipeline facility drug and alcohol testing regulations with corresponding DOT regulations (Procedures for Transportation Workplace Drug and Alcohol Testing Programs). They also proposed miscellaneous changes to the pipeline facility drug and alcohol testing regulations to make them easier to apply and understand. The proposals are intended to ensure the pipeline facility drug and alcohol testing regulations are clear and consistent with the DOT regulations. The proposed rule can be downloaded from RCP's website HERE. FOR FURTHER INFORMATION CONTACT: L. M. Furrow by phone at 202-366-4559, by fax at 202-366-4566, by mail at U.S. Department of Transportation, 400 Seventh Street, SW., Washington, DC, 20590, or by e-mail at buck.furrow@rspa.dot.gov.

States Are Increasing Their Roles in Pipeline Safety Issues

States are becoming more aware of pipeline safety issues and are moving to assert their authority on safety issues. Some examples of this growing trend are identified below;

* State of Washington. The State Legislature passed and sent to the Governor for his signature on April 19, 2001 legislation funding a new pipeline safety program. The legislation requires interstate pipelines to pay for an inspection and monitoring program for pipelines transporting hazardous liquids. The program will fund four inspectors who will have responsibilities for both new and existing interstate systems.

* State of Texas.(See article above) The Texas Railroad Commission issued on April 10, 2001 regulations requiring integrity management plans for intrastate gathering and transmission lines subject to 49 CFR 192 or 49 CFR 195. The new rule can be found in 16 TAC chapter 8. Initial plans must be complete by February 1, 2002 and maintained in an on-going manner thereafter.

* State of Florida. The Florida Public Service Commission is preparing safety rules for intrastate natural gas pipelines. These rules will likely contain provisions for integrity management, leak surveys, odorization of gas, installation of pipeline valves, corrosion control and other related issues. The timing for issuing the new rules has not been determined.

API Operator Qualification Conference II

The API 2001 Operator Qualification Conference II is scheduled to take place at the Sheraton Baton Rouge on the 30th and 31st of May 2001. This conference is of particular importance not just because it affords opportunities to those who could not attend the February conference, but also because regulatory deadlines are just ahead. Pipeline operators must have a written qualification plan by April 27, 2001. And by October 2002, no person may perform a covered task on a pipeline unless the company has evidence that the person is qualified to perform that task. Consequently this conference is indeed a watershed for the pipeline industry. Workshop and seminar topics will include the covered tasks in API Pub 1161 and additional sub-tasks not included in Pub 1161. Participants will discuss the audited OQ plans with the auditors who reviewed the plans, as well as Learn what it takes for contractors and owners to work together to succeed with operator qualification. For more information on the conference please log on to http://www.api.org/training/Conferences/OQconference/.

Editor's Note: I look forward to meeting you at the conference!

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.

USA Identification and Mapping Contract

On April 13, 2001, the U.S. Department of Transportation (DOT) announced the award of a five-year, $5 million contract to Research Planning, Inc. (RPI) of Columbia, S.C., to complete the identification and mapping of unusually sensitive areas (USAs). RPI will finish gathering drinking water and ecological data from state agencies and other sources in order to map USAs. The maps will be made available through the Research and Special Programs Administration's (RSPA) Office of Pipeline Safety web site at http://www.npms.rspa.dot.gov/default.htm.

The USA identification and mapping will assist operators in complying with the Department's hazardous liquid pipeline integrity management requirements. Under these rules, which are effective May 29, 2001, pipeline operators must assess, repair, and make other improvements to their hazardous liquid pipelines that could affect unusually sensitive or populated areas.

Editor's note: USA mapping may not be completed by the end of this year. However, each operator of more than 500 miles of hazardous liquid pipelines must still complete their identification of pipeline segments which are in or could affect High Consequence Areas (including USAs) by December 31, 2001. OPS has indicated that operators should just use the USA data as it is available. But operators will be expected to ensure that all populated areas and navigable waters are properly identified in their plans by the December 31, 2001 deadline.

Colonial Tops U.S. Pipelines for Safety, Protecting Environment

Colonial Pipeline swept the top awards for environmental stewardship and worker safety at the API (American Petroleum Institute) Pipeline Conference in San Antonio, and was presented a special Distinguished Performance Award for distinguished performance among the nation's larger pipeline companies. Atlanta-based Colonial operates 5,500 miles of liquid petroleum pipelines from Houston to New York. "Colonial's performance and this award epitomizes the finest in pipeline company operations," said George M. Rootes, chairman of API's Pipeline Committee. "It is particularly noteworthy that Colonial won both the safety and environment awards. It shows consistency and that the company is an across-the-board performer."

API is the largest oil and gas industry trade association, representing more that 400 companies. In judging the Distinguished Performance Award, API compared companies' safety and environmental records as well as their record of accomplishment in proactively enhancing public safety, environmental and safety performance, and in community outreach. The occupational safety award recognizes that Colonial, which carries 20 percent of all liquid petroleum product consumed in the United States, has worked more than two million hours without an accident that caused a lost workday. In capturing the environmental award, Colonial experienced no product releases during 2000 that met the Department of Transportation's minimum volume requirements for reporting.

"Our first priority, everyday, is being safe," said Dave Lemmon, Colonial's President and CEO. "We have made this commitment to the public, to our owners and to the government regulators who share our goal of protecting workers' safety and the environment." Bill Scott, Senior Vice President and Chief Operations Officer said Colonial derives its safety and environmental goals from the commitment the company has to spill-free error-free operations. "We are honored by the recognition," Scott said. "We measure ourselves by whether we meet public expectations for environmental protection and safe operations. This responsibility required constant vigilance on the part of every Colonial employee to sustain this level of safety."

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.

Reader question of the month

In the case of a huge organization, how do they organize compliance management and educate all employees? Are there any good examples regarding (industry omitted) companies? In our company, each division has a lot of regulations and rules, but we are not centralized. I have the task to organize compliance management.

Mr. (name omitted),

Having been responsible for compliance management systems in a large company myself, I have given this topic a lot of thought. I believe the essential elements of a large corporate compliance management system are:

1. Survey – identify all the requirements that apply to the activity / organization (EPA regulations x, y, and z; OSHA regulations a, b, and c, etc.)

2. Organize – develop compliance programs that address the requirements identified during step 1 above. This includes forms, procedures, checklists, filing systems, and guidance manuals as appropriate.

3. Train – develop and conduct training programs for the people who will be required to understand and follow the applicable requirements.

4. Audit – conduct periodic audits of the operations and compliance programs to ensure that the compliance programs are working as desired.

5. Consult – have knowledgeable experts available to answer questions as they arise. These people typically reside at the headquarters level, or could be outside consultants (such as ourselves).

6. Monitor – since the rules are constantly changing, someone (normally the experts in step 5 above) must continually monitor the rules to ensure that the compliance programs are kept up to date. For example, the Department of Transportation rules for pipelines in the US are changed once a month on average. EPA and other agency rules change at least that often.

7. Influence – In the US, companies are given the opportunity to influence new and proposed rules. Most companies do not spend any time or effort in doing this, but they should. The major corporations are willing to spend the time and effort (and $s) to work with the regulatory agencies up-front to ensure that new rules are acceptable from the company's standpoint.

I hope this has been helpful. I have some specific examples of how to organize and conduct each of the steps identified above. We have developed the nationwide compliance manual for a large US pipeline system, and are currently working with other companies on their compliance programs. Please contact me if you need any assistance in developing a compliance process for your company – especially for facilities in the US.

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.

Visit Regulatory Compliance Partners on the Web at

http://www.your-rcp.com

or call us at 1-888-RCP-X-YES to see what we can do for you.

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

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
Topic to be determined
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.

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