The proposed rule requires that an operator know its system. Must an operator excavate simply to gather information about parts of its system where it may not now have complete knowledge?

No. Operators should gather the information that they have available, and which may now reside in different locations or be the responsibility of different groups within the company, to develop an understanding of their pipeline systems. Part of this development should include identifying information that is not now known, but which could be useful in understanding the performance of the pipeline and in analyzing its risk.

Operators should then use opportunities that arise, such as where pipelines must be excavated for other reasons, to collect additional information to complete their understanding of the pipeline system. Operators should also assure that records are maintained for any future additions or changes to the system. Over time, PHMSA expects that operator understanding of their pipeline systems will improve, and the quality of their risk analyses will improve along with their understanding.

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