Historic Pipelines

As part of its pipeline authorization process, FERC takes into account the effect that issuing such authorizations has on historic properties. In some pipeline projects, historic properties simply cannot be avoided because the existing natural gas pipelines and related pipeline facilities are themselves listed, or eligible for listing, in the National Register of Historic Places (“historic natural gas pipelines”). Natural gas pipelines and related pipeline facilities may be historic due to such things as their particular design and engineering features, or their association with important national or regional historic events and well-known persons. On October 19, 2001, the Advisory Council on Historic Preservation proposed a Program Comment to streamline the historic preservation review process for projects involving historic natural gas pipelines. The full text of the proposal is available on RCP’s website at 66 FR 53198 10-19-01 Historic Pipelines.pdf. Note that comments are due on or before November 9, 2001.

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.

New OPS Pipeline Integrity Website

The Office of Pipeline Safety recently announced their new website dedicated to Pipeline Integrity Management issues. It is located at http://primis.rspa.dot.gov/iim/. We are sure that you will want to bookmark this site for future reference. As described in OPS’s notice concerning this new site: This web site provides information about OPS’s new Rule on Pipeline Integrity Management in High Consequence Areas for Hazardous Liquid Operators (49 CFR 195.452). The site provides information on the basic steps required for operator compliance with these new requirements. It also contains several useful resources, such as the rule and preamble text, a glossary of terminology, and a fact sheet summarizing the key requirements. This site is highly interconnected to assist users in locating information on a particular subject. For example, the major clauses in the rule all contain links to a set of “Frequently Asked Questions” that provide additional guidance and interpretation of the specific requirements.

The Frequently Asked Questions on this web site include the questions raised by participants at the August Integrity Management workshop. We had planned to discuss these issues at the October workshop. Since this workshop was cancelled for security reasons, our web site is now our primary vehicle for communicating this information.

Editor’s note: Our hats go off to OPS for getting this site up and running, and with such useful information, in the midst of very trying times in our nation’s Capitol. Great job!

IMP 500 Mile Criteria

Do you own or operate 500 miles of hazardous liquid pipeline? The answer may surprise you! The new OPS Implementing Integrity Management website (see article) contains the following Q&As; from the August Integrity Management workshop, concerning how the “500 mile” criteria should be applied when determining if the “Large Liquid” PIM rule applies to a pipeline operator:

Q – What is meant by “operator who owns or operates a total of 500 or more miles of pipeline” in 195.452 (a)? For example, if a large operator who operates more than 500 miles of pipeline also owns a small percentage of a small pipeline (less than 500 miles) that is operated by a different organization – does that smaller operator have to comply with the large operator rule – even if its O&M; manual, management processes, etc. are totally separate from the large operator?

A – The current rule applies to operators who own or operate a total of 500 or more miles of pipeline. This means that if an operator also is part owner of another pipeline operating company, the mileage of that other company is included in determining whether or not the 500 mile criteria is met. If the total pipeline mileage is equal to or greater than 500 miles, then the requirements of the current rule apply to both companies’ pipeline systems – even if they have totally distinct O&M; manuals, etc.

Q – If the operator of a small pipeline system (i.e. less than 500 miles) is partially owned by a large operator (i.e., one who operates more than 500 miles of pipeline), who is responsible for preparing the Baseline Assessment Plan and complying with the provisions of this rule – the operator, or the company that is part owner?

A – The operator is required to comply with OPS regulations, and thus is responsible for preparing a Baseline Assessment Plan that meets all of the requirements in 195.452 (c). Operators may use outside resources, including adopting management plans prepared by parent companies, but that does not relieve the operator of responsibility for having an acceptable plan.

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.

Olympic Pipeline Franchise Agreement

The Bellingham City Council has approved a new 10-year franchise agreement between Bellingham and Olympic Pipe Line Co. A franchise is a legal agreement that is technically required to permit a utility company to operate within the city. Key features of the agreement include:

  • a $50,000-a-year fee that the company will pay to cover the city's costs in making sure the pipeline is operated safely.
  • a requirement that pipeline operators notify the city of significant incidents in pipeline operations, such as leaks and spills, or when pressure limits are exceeded.
  • a requirement to move a section of pipeline to a deeper location under Whatcom Creek.
  • a requirement to notify the city 10 days in advance of any alterations or significant testing or repair work on the pipeline on city property.
  • granting rights to the city to inspect pipeline testing results.
  • annual meetings between city and company officials to discuss emergency procedures.
  • a requirement for the company to maintain a $100 million insurance policy to protect the city from any liability in future accidents.

New contact information

Our president, Bill Byrd, recently got a new cell phone with a different number. If you have the old one, it won't work anymore. Call any of our offices to get the new number if you need it.

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.

Proposed Rule Stage

2137-AF37Proposed Rule Stage

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

2137-AF52Proposed Rule Stage

Pipeline Operational Status

2137-AF60Proposed Rule Stage

Safety of Carbon Dioxide and Hazardous Liquid Pipelines

Final Rule Stage

2137-AF53Final Rule Stage

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!

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.