PHMSA has updated the Gas IMP FAQ’s with the following:
FAQ-237: Effect on piping installed after effective date
Question: When must the baseline assessment be completed for piping installed after the effective date of the rule?
Answer: Any newly-constructed gas transmission pipeline placed into service after the effective date of the integrity management rule, February 14, 2004, is considered “newly-installed” for purposes of the rule. Therefore, the baseline assessment on such piping is not due until 10 years following the installation of the pipeline. The same applies to pipe in covered segments that operators replace. In this case, the operator may credit this mileage as “assessed” for determining compliance with the 50% progress milestone. The ten-year due date for conducting the baseline assessment for new pipe would also apply to pipe replaced under this circumstance. This does not, however, relieve the operator of requirements to conduct tests required under other provisions of Part 192 associated with placing pipeline into service.