Do you have questions? RCP’s SMEs have the answers. Information will be posted here for questions we often get from clients or discussions we have with regulators regarding interpretations and pending regulatory deadlines.
Q: The proposed PHMSA language states that we still have to do a post construction coating check within 6 months. It just moved the “start date” of that 6 months from “backfill” to “in-service date”. It doesn’t look like we can avoid the coating check after construction. Check the proposed language of 192.319(d)
A: Yes, you still have to do a coating evaluation but it’s from in-service, not the date the line was buried.
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Upcoming Deadlines:
- The deadline to submit written comments in response to PHMSA’s forthcoming NPRM on Pipeline Safety: Safety of Gas Distribution Pipeline and Other Pipeline Safety Initiatives will be 60 days from the date of publication in the Federal Register. Comments may be filed at https://www.regulations.gov/ Docket No. PHMSA-2021-0046.
- And as a reminder, the “Stay of Enforcement” does not mean regulators don’t expect work toward getting compliance activities in place can be ignored.
If we can help, contact Jessica Foley.