FAQ-183: Notification for changing HCA ID methods
Question: If an operator initially selects method 1 to identify HCAs and later changes to method 2 for the same portion of its system, does this constitute a change in IMP that needs to be communicated to OPS/state?
Answer: Not necessarily. A change in the method for determining HCAs would not, by itself, be considered a substantial change requiring notification under 192.909(b). If the change results in a significant change in the amount of system mileage that is determined to be HCA (e.g., 25% change), a notification should be submitted.
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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