Frequently-Asked Question FAQ #171

FAQ-171: Merging small HCAs into one

Question: If Method 2 is being used to identify HCAs, can multiple adjacent HCAs be merged to create a single segment?

Answer: The rule addresses only pipeline in high consequence areas. Operators may, at their discretion, include in their integrity management programs additional pipeline segments, such as small non-HCA segments separating HCAs that are near each other, since it may be easier to manage assessments over the single, longer length of pipeline. OPS will evaluate compliance with the rule, including its requirement to complete assessment of 50% of covered mileage by December 17, 2007, considering only mileage determined to be in HCAs in accordance with the criteria in the rule.

These Frequently Asked Questions (FAQs) are intended to clarify, explain, and promote better understanding of the pipeline integrity management rules. These FAQs are not substantive rules and do not create rights, assign duties, or impose new obligations not outlined in the existing integrity management regulations and standards. Requests for informal interpretations regarding the applicability of one or more of the pipeline integrity management rules to a specific situation may be submitted to PHMSA in accordance with 49 C.F.R. § 190.11.

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