In This Issue

Q&A Section

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, including interpretations and pending regulatory deadlines.

Q:  I am replacing pipeline segments by installing new pipe in a pipe rack to allow for a major highway reconstruction. If I have the pipeline segments welded in a shop, installed in a new pipe rack and then delivered to the site, does the welding have to be done by an OQ qualified welder or is certified welder sufficient?

A:  PHMSA regulations related to retention of records of materials, construction and testing of any regulated pipeline segments regardless of where the work is actually completed, in a shop or in the field, are required. The welder would have to be qualified in accordance with a qualified welding procedure applicable to the materials and those records must be retained as well.

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Upcoming Deadlines:

  • The deadline to submit comments in response to PHMSA’s NPRM: Pipeline Safety: Gas Pipeline Leak Detection and Repair must be filed by August 16, 2023. The originally published closing date for comments was July 17, but PHMSA has extended the period an additional thirty days. Comments may be filed at Docket No. PHMSA-2021-0039.
  • 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.