Comment from Anonymous

PHMSA in this docket 2025-0116, what is the definition of a short segment of pipe or pipeline to only be tested for 4-hours instead of 8-hours to meet Part 192.611(a)(1)? What makes it impractical to conduct an 8-hour pressure test and how must an operator document it being "impractical"? What would be the maximum allowed pipeline segment length? Would the pipeline segment need to have a valve or other fabrication and/or less than XX feet of pipe (say less than 60 feet of pipe and 3 or 4 girth welds or less, with the 3 or 4 girth welds non-destructively tested) to be deemed by Part 192.505 to determine an 8-hour test impractical and to authorize the use of a 4-hour, post-installation pressure test? Would the pressure test records need to meet Part 192.517 for the 4-hour pressure test? If a valve, fabrication or short piece of pipe cannot be tested in-the-ditch for 8-hours, why can it not be tested near the ditch or at a close-by fabrication yard or manufacturing facility (for a valve) for 8-hours and inspected prior to and after installing it in the ditch? PHMSA must define for public comment prior to making this change the following: what makes it "impractical" for an operator to conduct an 8-hour pressure test, what is the definition of a short pipeline segment, what can't the test be conducted outside and/or near the ditch for 8-hours and inspected prior to, during and after the pressure test and after installation in the ditch.