Can the identification of segments that can affect HCAs be refined after the December 31, 2001, (or November 18, 2002, as appropriate) deadline?
PHMSA Pipeline Safety recognizes that some operators used methods with conservative assumptions in identifying which pipeline segments can affect HCAs to meet the initial compliance deadline. Refinement of these segments, potentially changing the boundaries of identified segments, may occur as more detailed analyses are performed later. This refinement process could result in a conclusion that some segments (or portions of segments) identified by the deadline cannot, in fact, affect an HCA. PHMSA Pipeline Safety expects operators to document their justification for any such elimination of an identified segment, and may review the technical basis for these changes during inspections. The refinement process could also result in identification of new segments that can affect HCAs, not included in those identified initially. PHMSA Pipeline Safety would not consider failure to identify such segments by the deadline to be a noncompliance unless there is a pattern demonstrating significant we
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