This week’s Pipeliners Podcast episode features Keith Coyle discussing the PHMSA Mega Rule part 3 and what changes it is going to make in the industry.
In this episode, you will learn when the rule goes into effect and how to get an extension as an operator, how the new rule changes some key industry definitions, as well as changes to part 192.
The Mega Rule Part 3 Show Notes, Links, and Insider Terms:
- Keith Coyle is a Shareholder and attorney with the law firm of Babst Calland. Mr. Coyle is a member of the firm’s Washington, D.C. office and a Shareholder in the Pipeline and HazMat Safety practice. Connect with Keith Coyle on LinkedIn.
- Babst Calland’s Energy and Natural Resources attorneys work collaboratively across legal disciplines to serve the needs of energy companies across the United States. Based in Washington, D.C., the Firm’s Pipeline and Hazardous Materials Safety practice represents clients on all types of pipeline safety and hazardous materials transportation matters.
- Mega Rule – The rule, initiated over 10 years ago, expands the definition of a “regulated” gas gathering pipeline that is more than 50 years old. It will—for the first time—apply federal pipeline safety regulations to tens of thousands of miles of unregulated gas gathering pipelines. The mega rule part 3 has been completed but is not yet implemented.
- Part 192 prescribes minimum safety requirements for pipeline facilities and the transportation of gas, including pipeline facilities and the transportation of gas within the limits of the outer continental shelf
- PHMSA (Pipeline And Hazardous Materials Safety Administration) protects people and the environment by advancing the safe transportation of energy and other hazardous materials that are essential to our daily lives. To do this, the agency establishes national policy, sets and enforces standards, educates, and conducts research to prevent incidents. They prepare the public and first responders to reduce consequences if an incident does occur.
- Natural Gas Pipeline Safety Act of 1968 (Pipeline Safety Act) was authorized by the Secretary of Transportation to prescribe safety standards for the transportation of natural and other gas by pipeline, and for other purposes.
- NTSB (National Transportation Safety Board) is a U.S. government agency responsible for the safe transportation through Aviation, Highway, Marine, Railroad, and Pipeline. The entity investigates transportation incidents and accidents and makes recommendations for safety improvements.
- The San Bruno or PG&E Incident in September 2010 refers to a ruptured pipeline operated by the Pacific Gas & Electric Company. The rupture created a crater near San Bruno, California, caused an explosion after natural gas was released and ignited, and resulted in fires that caused loss of life and property.
- The Gas Gathering Rule (Safety of Gas Transmission and Gathering Pipelines) was initiated in 2016 when PHMSA issued a notice seeking comments on changes to the pipeline safety regulations for gas transmission and gathering pipelines. The proposed rulemaking advanced through various stages before being published as a final rule in November 2021.
- Valve and Rupture Rule is a newly updated PHMSA regulation. This rule establishes requirements for rupture-mitigation valves, such as spacing, maintenance and inspection, and risk analysis. The final rule also requires operators of gas and hazardous liquid pipelines to contact 9-1-1 emergency call centers immediately upon notification of a potential rupture and conduct post-rupture investigations and reviews.
- The eCFR (Electronic Code of Federal Regulations) is a continuously updated online version of the CFR.
- Gathering Lines transport gases and liquids from the commodity’s source – like rock formations located far below the drilling site – to a processing facility, refinery or a transmission line. Types include Type A and Type B.
- Type A: Metallic and the MAOP is more than 20% of SYMS, or non-metallic and MAOP is more than 125 psig.
- NACE is an international organization dedicated to protecting people, assets, and the environment from the adverse effects of corrosion.
- Internal Corrosion Direct Assessment is a process an operator uses to identify areas along the pipeline where fluid or other electrolyte introduced during normal operation or by an upset condition may reside, and then focuses direct examination on the locations in covered segments where internal corrosion is most likely to exist.
- Stress Corrosion Cracking Direct Assessment is a process to assess a covered pipe segment for the presence of SCC primarily by systematically gathering and analyzing excavation data for pipe having similar operational characteristics and residing in a similar physical environment.
- External Corrosion Control Direct Assessment is a structured process that improves safety by assessing and reducing the impact of external corrosion on pipeline integrity.
- HCA (High-Consequence Areas) are defined by PHMSA as a potential impact zone that contains 20 or more structures intended for human occupancy or an identified site. PHMSA identifies how pipeline operators must identify, prioritize, assess, evaluate, repair, and validate the integrity of gas transmission pipelines that could, in the event of a leak or failure, affect HCAs.
- SME (Subject Matter Experts) specialize in providing skilled field and technical services to support your company’s natural gas pipeline systems, including transmission, distribution, and storage
- PIPES Act of 2020 addresses pipeline safety and infrastructure with respect to natural gas and hazardous liquid pipelines. It authorizes appropriations through FY2023 for specified pipelines safety programs under the Pipelines Safety Improvement Act of 2002 and related enactments.
The Mega Rule Part 3 Full Episode Transcript:
Russel Treat: Welcome to “The Pipeliners Podcast, Episode 252,” sponsored by Gas Certification Institute. Providing standard operating procedures, training, and software tools for custody transfer, measurement, and field operations professionals. Find out more about GCI at gascertification.com.
Announcer: The Pipeliners Podcast, where professionals, Bubba geeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations. And now your host, Russel Treat.
Russel: Thanks for listening to The Pipeliners Podcast. I appreciate you taking the time, and to show appreciation, we give away a customized YETI tumbler to one listener every episode. This week, our winner is Cindy Smith with Mountain West Pipeline. Congratulations, Cindy. Your Yeti’s on its way.
To learn how you can win this signature prize, stick around until the end of the episode. This week, Keith Coyle with Babst Calland returns to talk to us about the most recent Gas Mega Rule part 3.
Hey, Keith. Welcome back to The Pipeliners Podcast.
Keith Coyle: Thanks for having me on again, Russel. This is probably one of the more fun things that I do. If it was up to me, I’d be podcasting with you every day instead of doing my real job, so thanks again for having me on.
Russel: That’s awesome. I have to warn the listeners, because every time we bring you on, it’s because PHMSA continues to be the gift that keeps on giving. We’re going to walk through another new rule that’s making its way through the final stages of becoming law. Welcome back, and we’ll share the news.
Keith: This being my business, we tend to get a lot of phone calls from people with problems. If I’m doing a podcast, I’m probably talking about some regulatory change or other things that’s down the road. Nature of the beast.
Russel: Exactly. We’re here to talk about the Mega Rule part 3 and the final set of rule changes that are coming down the pike. I think PHMSA calls it REN2, just how they broke things up, but it’s actually the Mega Rule part 3 to actually become finalized.
Keith: PHMSA just issued the last final rule in a series of three rules that were collectively known as the Mega Rule.
The first final rule, PHMSA issued that back in October of 2019. That rulemaking focused on some congressional mandates for gas transmission lines that were included in the 2011 reauthorization of the Pipeline Safety Act and also addressed some related NTSB recommendations from the San Bruno, California, gas transmission line incident.
That was part one of the Mega Rule. Then part two of the Mega Rule came out back in November of 2021. That was a final rule that established new safety standards and reporting requirements for onshore gas gathering lines.
This is the third in the series of final rules. This final rule primarily addresses outstanding changes that were originally proposed as part of the Mega Rule back in 2016. The focus is primarily changes to the regulations for gas transmission lines. Some of these changes complement the changes that were made to the rules back in the first part of the Mega Rule.
There are other topics that are addressed that are standalone changes to part 192, not necessarily things that complement the changes that were addressed in the October of 2019 final rule.
Russel: If you think about it, there’s been a very large amount of change in the rule in the last couple of years. We’ve got this rule, we’ve got the gas gathering rule. We just had the Valve and Rupture mitigation rule. I saw another notice, which is a housekeeping item, but PHMSA is in the process of finalizing some stuff around standards incorporated by reference.
That’s good. I’m glad they’re doing it. That’s overdue, but it’s just a lot of change.
Keith: I think that’s right. We had this period a few years ago where we were sitting around waiting for change. There were a few years where there wasn’t a lot going on. There were some big rules that had been proposed, like this Mega Rule, but it took a while for those proposed rulemakings to work their way through the system.
Now, we’ve got change coming at us, it seems like every day, almost.
Russel: Yeah, it does seem that way.
Keith: The pace of change has been so quick lately that we have new rules that are being published that have to incorporate other changes made in new rules that were recently published that aren’t yet actually effective in 192.
It creates this situation where you’re not necessarily seeing how all of these changes have evolved into the regulations themselves. We probably won’t see that until all of these rules go into effect, but the pace of change has made things difficult to get your arms around everything that’s been going on lately.
Russel: I would say, too, that when we talked about the Valve Rule last time, and we were talking about how it’s scattered throughout the code, it’s not in one area. Some of the stuff we’re going to talk about today’s the same thing. It’s a little challenging for operators to really understand holistically what they need to be doing.
Keith: You’ll see, even in the language of this rule, the challenge that that created for the rule drafters over at PHMSA, because they have to incorporate language into this rule that addresses changes made in the Valve Rule, for instance, that aren’t yet reflected in the code.
It creates a challenge for the rule writers who have to do good rule drafting. It creates challenges for the compliance people who go online and take a look at part 192. They see rule text, but then you’ll see a bunch of links in there that say, “Amendment effective as of XYZ date.”
It’s signaling that we have a lot of change that’s gone on, but all of that change hasn’t necessarily sorted itself out yet. I think we’ll probably have a better sense of what 192 is going to look like, at least for a little while, maybe a year from now in terms of rule text.
I think we’ll probably spend as much time as PHMSA spent developing the Mega Rule getting a real sense of how everything is going to apply in the real world in terms of implementation and compliance. I think that will take years to shake itself out.
Russel: I would absolutely agree with that. I think the thing that I would be recommending to pipeline operators right now is that they try to get something put together around what the rule’s going to look like when all this is finalized and start working on it now because it’s going to affect a lot of things.
They’re going to have to review a lot of internal policy, procedure, and practice to make sure that they’re addressing all the things they need to address.
Keith: That’s one of the things about having these rules that get published, but they don’t go into effect for a couple of months. It gives operators a chance to get an idea of what’s coming, to organize their affairs, to start to make revisions to plans and procedures so that they’re ready for how the rule is going to be implemented when it does go into effect.
For this rule, for instance, it was published a couple of days ago, but the amendments that are included in this rule won’t actually go into effect until May of next year.
Operators – I totally agree with what you’re saying – they should be using the next several months to get their house in order so that they’re ready for May of 2023 well in advance of when the rules are actually going to change.
Russel: Let’s dive in a little bit to the details, Keith. What is the general content of this rule? When was it published, and when does it become effective?
Keith: On the process side, the rule was published in the Federal Register on August 24th, and the effective date of the final rule is May 24th of 2023. We’ve talked about this on the show before. The effective date of a final rule is when you will actually see the amendments that are included in the public document that’s published in the federal register.
That’s when you’ll see those changes show up in the Code of Federal Regulations. May 24th of next year is when, if you go to the online ECFR, you will see all of the amendments that PHMSA included in the final rule that was published a few days ago.
In terms of the nature of the changes, I agree with your assessment. There are changes that are scattered throughout 192. A bunch of topics are addressed. We have new definitions. We have some new industry standards that are incorporated by reference. We have some new requirements for gas transmission line operators dealing with particular subjects.
Things like new repair criteria, new corrosion control requirements. One of the things that is worth noting, for the most part, these changes should not affect gathering line operators. Most of the provisions, PHMSA was pretty clear in providing exceptions or language stating that they didn’t intend to have those applied to gathering.
Now, that doesn’t apply across the board. There are some provisions that apply to type A gathering, and then there are some provisions where PHMSA made clear that some of the changes wouldn’t apply to distribution as well. From a high level perspective, I would say, agree with your assessment.
Like the Valve Rule, a lot of changes sprinkled throughout 192 addressing what I would say more, just a variety of different topics.
Russel: What’s in this rule? What are some of the key changes?
Keith: In terms of the definitions, we do have some new terms that are defined for purposes of 192. We’ve got a new definition for the distribution center. We’ve got a change to a definition for transmission line.
I would encourage operators to take a look at those because the definitions that are included in this rule are ones that are going to apply throughout part 192 unless there’s some other specific limitations or restrictions.
Just make sure, when you’re taking a look at those new definitions, you’re thinking that these defined terms and the definitions that go with it, are going to run throughout 192.
Russel: Give me a little bit more detail about that. How are those terms being modified?
Keith: For example, there’s a new definition for a distribution center. This was a topic that, much discussed, I think primarily from a lot of the gas distribution side about wanting to have a definition for distribution center. That term has been used in the 192 code for decades, but there never really was a definition in 192 for it. PHMSA included some explicit criteria in the definition now for what qualifies as a distribution center.
For the new transmission line definition, what PHMSA did was modify the longstanding definition that’s been included in 192 for decades. It added a provision there that addresses, allows operators to voluntarily designate pipelines as transmission lines. That was something that came up during the advisory committee process as wanting to provide operators with the discretion to define something as a transmission.
Russel: They wanted to have something governed by a higher set of requirements. Then they can say, “I’m going to designate this transmission,” and then it’s governed by a higher set of requirements.
Keith: Yeah, there might be. A good example of that would be, let’s say, for instance, a transmission line operator has a farm tap that’s delivering gas to a customer. My understanding, at least under the language of this rule, is there had been a debate for a while about whether and to what extent that farm tap piping would need to be characterized as gas distribution piping.
I do think, at least given the language that’s included in the final rule, maybe there’s an ability for operators now to just basically say, “I’m voluntarily defining that line as transmission,” which might make sense for that operator because you don’t want to have random distribution segments when your primary or your core business is gas transmission service.
Russel: They can actually lower their operating costs by maintaining to a higher standard, just because of the consistency of it.
Keith: And I think, make things simpler. Again, if your core business is gas transmission, all things being equal, you would prefer not to have to worry so much about developing separate standalone procedures for a gas distribution operator.
That’s not really what you do, and the piping you’re dealing with is generally pretty short. Then there were some other definitions that were put in there to accommodate other specific changes that PHMSA was making in this rule to requirements for corrosion control, things like that.
In terms of, from things that jumped out at me, are those two provisions dealing with the distribution center definition and the transmission line definition as some at least interesting changes that I saw in the definitions.
Russel: You mentioned that there’s some new standards being incorporated by reference. Can you give us an overview of what that is?
Keith: Yeah, there are going to be some NACE standards that are going to be incorporated by reference. Those NACE standards address the performance of direct assessments and indirect assessments. I think there are three NACE standards that are going to be incorporated by reference into 192.7.
We’ve talked about this before. Make sure, when you’re looking at rules dealing with standards that are incorporated by reference, a couple of things that are important to remember. Only the specific editions that are incorporated by reference are the ones that are approved for use under 192.
For instance, one of the NACE standards they incorporate by reference deals with stress corrosion cracking direct assessment. Make sure you’re working with the right edition of the standard, and also, remember that the incorporation by reference is only for purposes of the regulations that are specifically listed in 192.7.
Some of the key standards that are incorporated by reference are NACE standards dealing with internal corrosion direct assessment, stress corrosion cracking direct assessment, and external corrosion control direct assessment. These are standards that weren’t in existence when PHMSA originally issued the integrity management rules back in the early 2000s.
They’re incorporating those by reference in this rule.
Russel: That’s actually one of the things. I was talking about that earlier. I just saw a notice from PHMSA about their update. It didn’t have any details of what they were doing, but there’s been a lot of conversation for some time that they needed to do housekeeping and administrative action.
There’s some of those standards that are incorporated by reference that are frankly quite out of date.
Keith: Yeah, that’s a problem that we often run into. I’m a big proponent of incorporating industry standards by reference. I think they’re great documents. I think the committees that make those standards are populated by some really smart people who know what they’re doing.
I think it’s a very good thing that PHMSA does incorporate standards by reference. There’s a lag, definitely a lag, in getting the most current editions of those standards into the code.
PHMSA does have concerns with provisions and certain editions of standards. There’s a dance that goes on in terms of “Are they going to incorporate the newest edition? If they are, are they going to override certain provisions?” Fair point on needing to get more modern versions of standards IBRed, I think that would be a good thing.
Russel: For sure. Just moving on, what are some of the other things that are in this rule?
Keith: There is a new requirement to have a management of change process implemented by February of 2024, for all gas transmission lines. That’s a new requirement. There has been a management of change process incorporated into integrity management rules for pipelines and HCAs. That’s been in effect for quite a while.
This is extending that management of change process to gas transmission lines that aren’t subject to gas transmission integrity management under subpart O. That’s a big change. The implementation deadline, as I mentioned, is February of 2024.
There is a mechanism that’s recognized in the regulation for an operator to seek an extension of that February 2024 deadline of up to a year. You need to follow this 90-day-notice-and-no-objection process that’s included in the rule. I would take a look at that provision, get a sense of how difficult it is going to be for you to implement the management of the change process. Do you think you’re going to need some more time?
If you do, make sure you get that request within that 90-day prior window. Some other changes in that 90 day notice and no objection process. There are several provisions in this rule and in previous rules that allow operators to use that process.
If you take a look at the rule text for that, there’s a lot of laundry on that line right now. There’s just a really long list of regulations where you can use that notification and no objection process. It’s expanded quite a bit over the course of the series of the Mega Rule stuff, and even some of the stuff in the Valve Rule.
Take a look at that and get your arms around which of these regulations can I seek that kind of relief under that 90-day provision? The list is pretty long. Then some of the other new requirements that are probably worth pointing out, a lot of changes to the corrosion control requirements, both for external corrosion and internal corrosion.
I would categorize them in the bucket of more robust criteria in those regulations and some new deadlines for when remediation activities need to be conducted. I would say more robust corrosion control, and some deadlines that you need to be aware of that maybe weren’t in the regulations before.
Then another big change in this rule was changes to the repair criteria. Two primary components to those changes. One is extending some of the integrity management like repair criteria to pipelines that aren’t in high consequence areas.
Then also, within the integrity management rules themselves, changing the criteria that are used in the repair requirements to more explicit. That’s a big change. A lot of the changes to the repair criteria are things that complement the changes that were included in the first part of the Mega Rule.
Then beyond that, there were some other changes to the integrity management rules in subpart O, provisions relating to threat identification, performing indirect assessment. A lot of things to chew on. It changes throughout the code.
Russel: One of the things you said about all this is that this is a technical rule, not so much of a policy rule. Can you elaborate a little bit about what you mean by that?
Keith: When I read through this rule, the first thing that became apparent to me was…I was well outside my swim lane on a lot of this stuff in terms of very detailed, in the weeds stuff relating to corrosion control and repair criteria, and all that.
My simple legal mind was like, “This is very detailed stuff that SMEs who have a lot more experience on these technical issues should try to get a handle on.” I noticed that in the back and forth in the rule discussion itself.
We’ve been dealing with some rules like the regulations for gathering lines, some big policy decisions about what should be regulated. Even if these pipelines are regulated, what core requirements should apply?
More big picture stuff about jurisdiction and what rules should apply, this rule was a little more technical, in the weeds, NACE standard stuff, like wall thickness things and repair criteria. I’m like, there was not as much policy there, a lot more technical stuff.
Russel: I think, too, that what’s interesting about a rulemaking like this is it’s really more the SMEs digging in and working with PHMSA in the rulemaking process around “What do we need to do to implement new technology, new approaches, and make sure that that works within the regulatory framework?”
Versus, “What’s covered, and how is it covered? This is like, if it’s covered, how are we actually going to do this work?”
Keith: Right. You’re drilling deep into the weeds here, like provisions and NACE standards, technical reports, research, analysis. I’m not sure what PHMSA would say, but I have a sense that PHMSA would–they feel very comfortable talking about the technical stuff. I think that comes through in this rule.
I think the industry feels very comfortable talking about technical stuff, too. Maybe it’s better for everybody’s sanity if we stick to the technical rules, where the lawyers don’t understand it, as opposed to some of these other ones, where we tend to meddle in these big policy decisions and stuff like that.
Maybe the advice for the regulators, if you keep it so technical that the simple minded lawyers don’t understand, it’s probably better for everybody.
Russel: Yeah, that’s actually funny, Keith. One of the things I’ve certainly learned by doing this podcast and talking to all these people who are experts in their various domains is that we all have those areas that we can operate in and we’re really comfortable, and we all have those areas where we can have the conversation and understand.
We all have those areas where we put our hand up and go, “I’m not really qualified to participate in this conversation.” [laughs]
Keith: Yeah, right. The challenge for me is, even when I’m in one of those areas, regulating myself to make sure I don’t open my mouth too far, because I’ll be prone to step in it.
Russel: I think that’s true for all of us. I guess one of the things that I’m taking away from our conversation here is I really need to have a number of podcasts with some SMEs that can dig as deep into these rule changes and talk about the details.
Keith: I would definitely support, just the repair criteria stuff, I’m sure you get more than a couple of experts to talk about those things and the corrosion control stuff. That stuff is very difficult in the weeds, challenging things. Then just to understand the practical implications of it.
How does this affect an operator out in the field who’s getting data back? What kinds of things are they going to have to repair now that they didn’t have to repair in the past? I think for podcast material, you’re going to have a lot. You’re going to have a lot of technical people looking to get on Russel’s show, so they can talk about their pet issue.
Russel: We just recently crossed over 250 episodes. I’ve said this many times along this journey, that you would think that, after this many episodes, you’ve covered it all. I’m here to tell you, it’s impossible because, by the time you think you’ve gotten the way around the block and covered it all, they’ve changed things. You need to do it again. [laughs]
Keith: Yeah. For the lawyers, like I was saying before, they’ve made changes on top of changes on top of changes that aren’t effective. It is, and that’s, I think for me, anyways, in terms of the practice of doing what I’m doing, it’s really challenging. It keeps me engaged.
It’s very interesting, even on stuff like the super technical stuff, where I’m way outside my comfort zone. I really appreciate when PHMSA and the technical people take the time to explain it in a way where even somebody like me can understand what’s going on.
I think in this rule, they did a really good job of that, to be quite honest. I thought the way they laid out the content and the changes that they were proposing was very accessible. They did a good job of walking through all of the back and forths at the advisory committee.
Sometimes, it’s hard to condense all of that discussion, particularly when we had as many meetings on the rule as we had with this advisory committee process. Kudos to my former colleagues over at PHMSA for doing some very good work, taking some very complicated issues, and writing it in a way, where a very simple mind could understand it.
Russel: [laughs] Simple mind, I don’t know that I’d frame it that way. Just the nature of our business is it’s very technical, with a lot of narrow technical domains. None of us can be an expert in all of it. It’s impossible.
One of the goals of this whole podcast thing is just trying to help people all get on the same page so that we can all have the conversation more effectively across those domains.
Look, as I’m listening to this, one of the questions that’s up for me I want to ask is, are we done? Have we gotten to the point where the backlog of rulemakings at PHMSA is cleared, and it might be quiet for a while, or is there more coming?
Keith: I think this final rule definitely closes out a long running chapter of rulemaking work. The Mega Rule part 3 means that the Mega Rule is done. I do think we’re going to have a little bit of time here to take a breath and wait for some of these rule changes to get reflected in the code and start to be implemented on the ground.
We do have some other rulemakings in the queue. Now, unlike this rule, we won’t have final rules for some of those bigger rulemakings coming out. The next phase in the rulemaking process are proposed rules. A couple of the ones that we’d want to keep on our radar are the gas pipeline leak detection and repair rule.
We do have some rules related to changes to the requirements for gas distribution lines in the queue. Then we have a rulemaking related to the class location requirements that’s in the queue, but we should have a little bit of time here to take our breath, at least with respect to final rules with big, impactful changes on the gas transmission gathering side.
Hopefully, that calms down for a little bit, and then we can shift back into starting up the next set of rules in the queue.
PHMSA has this PIPES Act rulemaking chart that they’ve had up for several years. I took a look at it this morning getting ready for the show, there’s not as many rules on that chart as there used to be. Let me just say that.
A lot of those ones deal with congressional mandates from 2016 and 2020, not ones from 2011 or earlier. Again, kudos to my colleagues over at PHMSA for getting the chart done. That’s big picture stuff.
Russel: That’s helpful. Listen, man, it’s great to have you on, as always. Every time I listen to you, I’m like, “Oh, my gosh, I’ve got all this homework I need to do to understand what’s going on.” I appreciate that. That’s what I like about you, Keith.
Keith: As I said at the opening of the show, I’d rather be talking to you every day of the week and twice on Sunday than doing most of the stuff I do. Not to offend my clients. I love all my clients equally, but this stuff is really fun. Doing the prep for these shows, I really enjoy it. It’s a different medium for me. You always ask great questions that are fun.
Russel: I appreciate that, Keith. I like having you available, because whenever one of these rules comes out, I know I’ve got somebody I can go to that’s going to be able to wade through all the details and keep me up to speed on what’s going on. It’s mutual. I appreciate you, bud.
Keith: Thanks again. Keep up the great work with the show. Get all those technical experts on “who can clean up the mess I just made in explaining this rule?” Until we chat again.
Russel: All right, thanks, Keith. Have a good one.
Keith: You, too, buddy.
Russel: I hope you enjoyed this week’s episode of The Pipeliners Podcast and our conversation with Keith. Just a reminder before you go. You should register to win our customized Pipeliners Podcast Yeti tumbler. Simply visit PipelinePodcastNetwork.com/Wi and enter yourself in the drawing.
Russel: If you have ideas, questions, or topics you’d be interested in, please let me know, either on the Contact Us page at PipelinePodcastNetwork.com, or you can reach out to me on LinkedIn. Thanks for listening. I’ll talk to you next week.
Transcription by CastingWords