Comment from Anonymous

PHMSA, how can the proposed changes to Part 192.319(d) and (f) and Part 192.461(f) and (h) save costs to operators? The proposed changes to these code sections are more likely to add costs to the overall pipeline project if the operator does not conduct the coating surveys and repair prior to completing finish clean-up on the construction project. An ongoing pipeline construction project would already have the needed permits for soil excavation and backfill. The added cost would be due to added move-in and move-out costs of the equipment and construction personnel repairing the pipeline external coating. Also, the deletion in Part 192.319(d) of "Promptly after a ditch for an onshore steel transmission line is backfilled" may cause non-steel, mains and some gathering lines to be applicable to this Code section. The usage of the word "Promptly" and "but not later than 6 months after placing the pipeline in service" gives the operator flexibility in conducting the coating survey and still stresses the importance of this survey for public safety. PHMSA is proposing to update Part 192.319(f) by deleting "and apply for any necessary permits within 6 months of completing the assessment that identified the deficiency" in the current regulation. The proposed Part 192.319(f) leaves a loophole in not requiring the operator to submit for any required permits in a certain time period – within 6 months of completing the assessment. Damaged external coating can be caused be rock or equipment denting and gouges to a pipeline and can lead to further corrosion, which all of these items are a public safety hazard and should be remediated quickly. Review comments for Part 192.461(f) and (h) are like the above review and comments to Part 192.319(d) and (f) since the proposed regulation changes are the same in the notice. PHMSA is requested to not make the noticed Part 192.319(d) and (f) changes and Part 192.461(f) and (h) changes to the current Code. The information provided about the need for making these changes is misleading and incorrect as explained above.