This week’s Pipeliners Podcast episode features returning guest Keith Coyle, of Babst Calland, discussing the recent PHMSA NOPR (notice of proposed rulemaking) that deals primarily with changes to the gas distribution line regulations.

In this episode, you will learn about the rulemaking process, what makes this one so unique, and how Congress is involved.

Gas Distribution NOPR Show Notes, Links, and Insider Terms

• Read the Pipeline Safety Alert from Babst Calland
• 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.
• PHMSA (Pipeline and Hazardous Materials Safety Administration) is responsible for providing pipeline safety oversight through regulatory rule-making, NTSB recommendations, and other important functions to protect people and the environment through the safe transportation of energy and other hazardous materials.
• Leak Detection and Repair (LDAR) is the process by which oil and gas, chemical, and/or petrochemical equipment is monitored for the location and volume of unintended leaks
• Gas Hazardous Leak according to PHMSA is any release of gas from a pipeline that is uncontrolled, that could be an existing probable or future hazard to a person’s property or the environment, or that is or can be discovered using equipment sites, sound, smell, or touch.
• LPAC (Liquid Pipeline Advisory Committee) and GPAC (Gas Pipeline Advisory Committee) are statutorily mandated advisory committees that advise PHMSA on proposed gas pipeline and hazardous liquid pipeline safety standards, respectively, and their associated risk assessments. The committees consist of 15 members with membership evenly divided among Federal and State governments, the regulated industry, and the general public. The committees advise PHMSA on the technical feasibility, reasonableness, cost-effectiveness, and practicability of each proposed pipeline safety standard.
• Notice of Proposed Rulemaking (NPRM) is a stage in the rulemaking process that happens before an agency adopts a final regulation. It is like the first draft of a regulation and gives the public an idea of what is to come.
• Protecting Our Infrastructure of Pipelines and Enhancing Safety (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 pipeline safety programs under the Pipeline Safety Improvement Act of 2002 and related enactments.
• The Merrimack Valley gas explosion in Massachusetts in September 2018 was the result of excessive pressure build-up in a natural gas pipeline owned by Columbia Gas that led to a series of explosions and fires. 
• NTSB (National Transportation Safety Board) is a U.S. government agency responsible for the safety of the nation’s major transportation systems: Aviation, Highway, Marine, Railroad, and Pipeline. The entity investigates incidents and accidents involving transportation and also makes recommendations for safety improvements.
• 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. 
• Downstream means the direction and area the product is traveling toward. It can also mean the process involved in converting oil and gas into the finished product, including refining crude oil into gasoline, natural gas liquids, diesel, and a variety of other energy sources. The closer an oil and gas company is to the process of providing consumers with petroleum products, the further downstream the company is said to be.
• Gathering Lines are pipelines that transport natural gas from production facilities to a transmission line or distribution main lines.
• 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.
• Total Calculated Volume (TCV) is the total volume of all petroleum liquids and sediment and water, corrected by the appropriate volume correction factor (Ctl) for the observed temperature and API gravity, relative density, or density to a standard temperature.
• Rupture Mitigation Valve (RMV) is any automatic shut off or remote-controlled valve that an operator uses to minimize the volume of gas released to mitigate the consequences of a rupture.
• A risk assessment is a process of identifying potential hazards and analyzing the eventualities if a hazard occurs. This procedure consists of three steps: Hazard identification: identify internal and external hazards, and risk factors that have the potential to cause harm.

Gas Distribution NOPR Full Episode Transcript

Russel Treat: Welcome to the “Pipeliners Podcast,” episode 301, sponsored by EnerSys Corporation, providers of POEMS, the Pipeline Operations Excellence Management System, compliance and operations software for pipeline control center to address control room management, SCADA, and audit readiness. Find out more about POEMS at EnersysCorp.com.

Announcer: The Pipeliners Podcast, where professionals, bubba geeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations.

Now your host, Russel Treat.

Russel: Thanks for listening to the Pipeliners Podcast. I appreciate you taking the time, and to show that appreciation, we give away a customized YETI tumbler to one listener every episode. This week our winner is Tony Minutillo with MPLX. Congratulations Tony, your YETI is on its way. To learn how you can win this prize, stick around till the end of the episode.

This week. Keith Coyle is back to join us, to talk to us about the recently released Gas Distribution Notice of Proposed Rulemaking from PHMSA. Keith, welcome back to the Pipeliners Podcast.

Keith Coyle: Hey Russel, it’s good to be on again. I hope you had a nice Labor Day weekend and the summer went well for you, and I’m happy to be back.

Russel: It’s been hot. That’s what I can say about the summer in Houston, Texas. It’s been hot. Of course, everybody’s talking like it’s never been hot before, but it has been hot before. It’s just hot again.

Keith: I feel like if you live in Texas or Arizona, it’s a little hard to complain about the heat. You kind of come to that hazard.

Russel: No. We earned the right to complain about the heat in Texas.

Keith: Fair enough, fair enough.

Russel: Hey, I brought you on to talk about rulemaking again. The last time we talked, we said we didn’t expect much for a while, and it’s been a while. Now we just had a big one drop and there’s one controversial one in the mix. We need to talk a little bit about the gas leak detection repair rule, and then we need to talk about this new distribution rule that just dropped. Where would you like to start?

Keith: I guess it was back in May, where we talked about the leak detection and repair rule, that rulemaking proposal. That was a pretty significant proposed rule, the comments just went in. I took a look at the docket this morning. Believe it or not, PHMSA is showing more than 34,000 comments were received on that rule. They’ve posted more than 26,000 comments.

A lot of work went into preparing comments on that rule. PHMSA is anticipating having a Gas Pipeline Advisory Committee meeting to review the proposed rule in November. A lot of significant development on that proposed rule and more to be said on that at a later date.

Russel: 34,000 comments. Just for the listeners’ benefit, how does that compare to the quantity of comments on other PHMSA rulemakings? What would be typical?

Keith: I’ve never seen anything even remotely close to that. It’s usually not high enough that I bother to count. Maybe it’s a couple hundred comments. I was popping in and out of the docket while we were developing some industry comments. I started to see some significant numbers. I was like, “Wow, there’s a lot of interest in this proposed rule.”

I went and double checked this morning. 34,000 comments went in. A little more than 26,000 have been posted. Going to need a lot of caffeine over at the agency. They’re going to be doing a lot of reading between now and November. We’ll see what happens.

Russel: That’s almost 100 fold what you typically expect to see. It’s crazy.

Keith: As they say, hopefully, they’ve got their reading glasses over at PHMSA, and they’ve got a lot of coffee coming in. They’re going to be reading a lot of comments over the next few months.

Russel: No doubt. Let’s talk about the pre-publication of the NPRM on the gas distribution stuff. Why don’t you walk us through the background for that rulemaking?

Keith: A couple of weeks ago, PHMSA released a pre-publication version of a new proposed rule that deals primarily with changes to the gas distribution line regulations. The primary driver for the proposed rule are several provisions from the 2020 PIPES Act. There was a title in the 2020 PIPES Act that dealt specifically with some statutory changes related to gas distribution lines.

Most of those changes, in fact I think all of them, were directly in response to an incident that occurred in the Merrimack Valley of Massachusetts in September of 2018. The incident was a significant overpressure event on a gas distribution system.

There was a fatality, 22 injuries requiring hospitalization, damage to more than 130 structures, and nearly 11,000 customers lost gas service as a result of the incident. A very significant event that happened a few years ago.

There was a National Transportation Safety Board investigation of the incident, and NTSB issued some recommendations. Eventually, Congress stepped in as well on the 2020 Pipes Act and put some additional mandates into the Pipeline Safety Act directing PHMSA to take certain actions.

Russel: I recall that event rather well, and I recall what was in, at least, a preliminary NTSB report regarding what led to it.

It was really an engineering and project planning failure, is how I would characterize that because they were replacing cast iron line with more modern, reliable line and they failed to properly locate and account for a sensing line and address that correctly as they were affecting their repairs. Basically, it caused the gas system to open wide open.

Keith: Yeah, that’s right. The company was doing a cast iron main replacement project, which is a good thing. NTSB, PHMSA, state regulators have been encouraging gas distribution operators to take action to replace vintage pipe, things like cast iron that are known to have issues, particularly over time.

NTSB focused its investigation on some issues related to project planning and oversight of the construction. You’re correct that there was an issue with a sensing line that was not properly addressed during the main replacement project.

The sensing line thought that the system needed more gas. It put a whole lot of gas into the system, and that ended up over-pressing the downstream portions of the system, including the portions that went into customer homes. That was really what caused all the significant adverse consequences that followed from the event.

Russel: Can you go walk us through what’s in the rulemaking?

Keith: At a very high level, as I said at the beginning, most of the changes deal with issues related to gas distribution systems, changes in regulations related to overpressure protection, emergency response, and gas distribution integrity management. There are, I’d say, two other types of changes that are also included in the role that affect all regulated pipelines or most all regulated pipelines.

PHMSA is also proposing an amendment related to inspection of gas pipeline construction. This was a rulemaking change that PHMSA had actually considered back in 2015 in another rulemaking proceeding. They put it on pause for a while. Now, in this proposed rule, they’re looking to go back forward with that proposal.

Then there’s some other changes that PHMSA is proposing to address a recent court decision that the US Court of Appeals for the District of Columbia Circuit issued in litigation related to the Rupture Mitigation Valve Rule. The court vacated the requirements in that role related to gathering lines, and PHMSA is proposing to add some of those requirements back in in this rulemaking process.

From a really high level, most of the changes are things related to the regulations for gas distribution lines, focusing on the three core topics of overpressure protection, enhanced emergency response requirements, and changes to the regulations for gas distribution integrity management.

Russel: This is interesting to me because many of the other rulemakings, at least in my experience, have been more focused on technical matters. Meaning, issues related to the pipe itself or how you’re running smart pigs or those types of things.

Where a fair part of this rule is more organizational matters, more human factor matters related to design, testing, record keeping, inspection, those kinds of things. It’s a little bit different in that way, at least in my experience. Would you agree with that assessment?

Keith: I think a lot of these changes in this rulemaking are directly driven by congressional mandates from the 2020 Pipes Act. There were several statutory requirements that Congress amended where they directed PHMSA to go out and issue rules that were specific to this incident, and the causes and contributing factors that NTSB identified for this incident.

I do think the NTSB did focus on issues related to planning and oversight of the construction project. Things like availability of records, understanding the design of the system, making sure you’re fully taking account of how the system will operate when you’re engaging in these types of projects.

Then another sort of significant aspect of the congressional mandates and the rulemaking itself relates to emergency response. The NTSB report identified shortcomings in the emergency response plan that the operator implemented in response to the incident.

Things like communicating with first responders, local government officials, getting information out to the public so that people knew more in real time what was happening. Obviously, one of the challenges that pipeline companies face when they have these kinds of events is there’s a whole lot going on and it can be difficult at times to get your arms wrapped around everything.

You’re trying to deploy personnel to the site of the event to make sure everything’s under control, you’re trying to handle the operation of the system. In this case, you had a lot of customer complaints coming in response to the event, and then on top of that, you’re also trying to manage your interaction with all the other first responders and officials that have a role to play in these events.

It’s a complicated process. It’s definitely not something that’s easy and it’s not something that you have to deal with every day. I think a lot of the changes that Congress wanted PHMSA to pursue and that you’ll see in this rulemaking are designed to tighten up the emergency response requirements for these types of events.

Russel: Yeah, that seems to be thematic. Certainly there’s been a lot of attention on that. It comes out of some of the other rulemakings and incidents. In fact, I’ve done some podcasts on some of the challenges of implementing some of the requirements that have been mandated.

I would say when I first read the initial incident report, and I’m walking through it, the thing that struck me about it is that an engineer with proper experience properly involved in the project should have headed this off.

Because it was very clear, as you walk through the details, an engineer should have been asking questions and running things out to ensure that this overpressure didn’t happen. There should have been mechanisms in place or oversight in place to make sure that it didn’t happen.

What I will say too, is particularly on these very old systems where you’re – a very old kind of relative concept or relative statement – but particularly on older systems where the people who put those systems in or are familiar with them are no longer with the company, this becomes really challenging.

Keith: Yeah, I think with record keeping, you have the loss of institutional knowledge when those people move on to different positions or are no longer in the workforce. That’s when the issues related to record keeping become more impactful, particularly for these much, much older systems.

When you’re dealing with early 20th century, late 19th century pipeline networks, and some of the older gas distribution systems in the country, we just didn’t have the record keeping practices that we have today. We didn’t have the technology that provided for ease of retention of records.

One of the things that is targeted in this rule is to have gas distribution operators set up a system for acquiring and maintaining traceable, verifiable, and complete records to document the characteristics of their system, particularly with respect to issues concerning pressure control, because that was one of the causal factors in this event.

The proposed rule is allowing gas distribution operators to collect those “TVC records” over time. Through an opportunistic approach I think that’s the right way to do it. To impose a universal TVC record keeping obligation and go out and get all these records at once for these older systems, it wouldn’t be feasible, the challenge would be overwhelming.

Then one of the other issues that you talked about was making sure that there are qualified people who are involved in evaluating construction projects to make sure that they’re thinking through how things might affect the system during those projects, including the potential for over-pressurizing the system.

That’s another thing that this rule of one of the proposals would require that type of evaluation for these construction projects, so that someone is thinking about a potential concern that might arise during the project itself.

Russel: Yeah, absolutely true. There’s still no substitute for experience and good analytical thinking, both in the design and in the construction processes. Those are hard to regulate, but critical to have the kind of safety effectiveness we’re looking for.

I guess that’s the point I’m trying to make is what’s in this rule and what you’re being asked to do, which all makes sense, but there’s still another part of that, which is the experience and engineering judgment piece that is very hard to quantify.

Keith: Yeah, the human element is always involved in these kinds of incidents. Typically, there’s usually not one thing that causes an incident on this scale. It’s usually a combination of factors. In this scenario, there were inherent flaws or inherent problems in the design of the system.

Then there were human issues, how people reacted to the incident and also how the project itself was executed.

Russel: Yeah, because the project was designed, then shelved, and then restarted meaning that the people doing the construction were not the people involved with the design. That always creates additional challenges.

Keith: Yeah, hindsight’s 20/20 in this business. Everybody would always get it right if we knew what we know now looking back. One of the things that always comes from events like this is everybody tries to learn from the mistakes that happened whether they’re attributable to human factors, design issues, things that people didn’t realize at the time.

One of the things the NTSB pointed to was that the system design wasn’t necessarily in violation of any rule or regulation. It was just that the regulation itself didn’t contemplate or address the possibility for a single mode of failure in that design setup, and then when you had that single mode of failure, the knockoff effects of it.

One of the other changes that PHMSA is proposing in this rule is to better account for overpressure protection and the design of low pressure distribution systems to head off that problem in the future.

Russel: For those that are working on that problem. It’s non-trivial for sure.

Keith: Yeah.

Russel: Let’s walk through the specifics, Keith of what’s in the rule.

Keith: We just touched on there are some proposed changes to the design requirements for low pressure gas distribution systems, to better account for overpressure protection and the design of those systems. Another change that the agency is proposing is to modify the record keeping requirements that apply to test records for pipelines that operate below 100 PSIG, for service lines or for plastic lines.

Those types of tests right now are only subject to a five year record retention period. PHMSA is proposing to extend that record retention period to the life of the pipeline and also to require operators to include more information in those types of records. Two other significant areas of change in this proposed rule are changes to the operation and maintenance manual requirements for gas distribution operators, and also some changes related in the O&M manual requirements for all pipeline operators.

A lot of this stuff on the gas distribution side are updates to account for the risk of over pressurization events, and then some of the other changes that apply more broadly are dealing with how operators respond to emergencies including in their emergency response plans. This is one of the areas where the rule goes outside of just a distribution specific rule.

We talked a little bit about the TVC record keeping proposal that would have operators go out and either maintain the records that they have on the characteristics of their systems that are critical for pressure control, but also to opportunistically obtain those records over time.

Another change that we already touched on is to have this evaluation of construction projects to identify potential activities that could result in overpressure events, particularly for regulator stations.

Two other things that I’ll quickly touch on. Then I’ll open the floor to some more questions. There are some changes to the maintenance requirements for testing that needs to be done to return disconnected service lines to service.

One other significant area is changes to the Distribution Integrity Management Program requirements, insertion of additional criteria into the distribution IM regulations to specifically account for the factors that caused the Merrimack Valley event.

Russel: I want to run all the way back up to where you started when you were talking about design. This is interesting to me.

The primary design requirement, the way that I would summarize it is that the regulator is saying, for pressure regulator stations that serve the low pressure distribution, meaning going from the regulator to the house, basically, they’re looking for redundant methods of overpressure protection, not a single method of overpressure protection.

Then they’re also adding the requirement that operators should be remotely monitoring gas pressure near the location where the overpressure protection exists.

That all makes very good sense, why you would want to do that, in that it certainly gives you an enhanced level of safety, but both of those are non-trivial, particularly for the smaller public gas operators, very non trivial. I expect there to be a fair amount of robust technical comment to that. It’ll be interesting to see how that plays out.

Keith: I think these changes are focused on the regulator stations, not necessarily the regulator equipment before it comes into the home, but more the stations that are a little bit farther up in the system…

Russel: That’s exactly right.

It’s where they’re taking the 120, 125 PSI gas down to 10, 15 PSI.

Keith: Yeah. They’re stepping down the pressure to get it into a system before delivery to customers. This was one of the causal factors that the NTSB identified in this incident that the regulator station, again, the way it was designed was permissible under the current regulations.

What they wanted to make sure was that if there was a failure, such as what occurred during the Merrimack Valley incident, that there’d be a backup at the regulator station to control the pressure to make sure that what you had happened here where the system pumped a lot of additional gas into the downstream network where that wouldn’t happen.

You either have to have some kind of setup there to make sure that that single mode of failure won’t lead to the same type of event as what happened here.

Russel: The challenge is these regulators are, so when the pressure on the system that they’re regulating drops, they’re designed to open and feed more gas.

Keith: Exactly.

Russel: In the case of the Merrimack incident, what occurred is they had disconnected some of the line where the sensing cable was going, but other parts of the line were still connected to homes as they were executing these changes. The sensing line was saying no pressure, and yet they were feeding gas into this other system.

That is not a normal operation. That’s an abnormal operation because of the construction and change that’s in the process of occurring. While I think the regulation changes make sense from a safety improvement standpoint, I’d expect to see a lot of technical comments because implementing what’s being asked for is just nontrivial.

Keith: Yeah, I think there’ll be engineering challenges that the technical people who are far smarter on these things than I am, will hopefully go back to PHMSA and try to point out some areas in the role that might need change.

I do know consistent with some of the previous rulemakings, PHMSA, at least in some of these provisions, is authorizing a 90 day prior notice and no objection process if an operator is proposing an alternative to what is prescribed in the rule.

I can’t recall precisely if that process applies to these design requirements, but I do know there are some other provisions in the rule where if an operator wants to use an alternative approach, they can provide one of those prior notices to PHMSA and to the state regulators to try to use a different method or technology.

Russel: I probably should get an expert in this on the podcast to talk to this issue specifically. I do think you have to unpack the design build requirements here, because in the case of sensing no pressure because you’re pulling a pipe out, it’s not something you would find in normal operations.

Then how do you account for that in standard station design? It’s an interesting question. Anyway, I’ll leave it there. My engineering geek is coming out, Keith. I apologize.

Keith: Yeah. I’m clearly drowning as your engineering comes out. I’m diving for the legal life preserver here. I’m looking for some out man now.

Russel: Sometimes I feel like I need to do that because you return the favor the other way around.

Keith: Yeah, just to remind me who the boss is and who’s running this podcast.

Russel: That’s not what it’s about, Keith. Come on now.

Keith: No. One other thing I wanted to point out about this rule, because it’s near and dear to my heart. There are some other changes that PHMSA is proposing to address our recent court decision that came down from the U. S. Court of Appeals for the District of Columbia Circuit.

There was a judicial challenge to PHMSA’s rupture mitigation valve requirements, particularly as they apply to gathering lines. In May of this year, the DC circuit granted the petition for judicial review and vacated those requirements from the RMV Rule for gathering lines.

A couple of months, actually, it was earlier this month or back in August, PHMSA issued another final rule that made certain changes to 192 to address the court’s decision. When a court vacates the provisions in the final rule, they’re saying they’re invalidating those provisions. They no longer have legal effect, but when a court issues a decision invalidating a statute or regulation, the statute or regulation doesn’t go away. It’s still on the books.

The only way the statute or regulation goes away is if Congress amends the statute or the regulator amends the rule that has been invalidated by the court. In early August, PHMSA issued another rule that basically acknowledged the DC Circuit’s decision and removed the provisions from the RMV rule for gathering lines.

Then, in this rule, not to totally spin your head, PHMSA is going back and removing some of the changes that it had adopted earlier this month in response to the court decision. A lot of back and forth related to that DC Circuit decision.

We had the court invalidating some rules, PHMSA issuing a rule to acknowledge that those rules had been invalidated, and now PHMSA is proposing to restore some of the provisions that it eliminated just last month, so they’ve been very busy in response to that decision.

Russel: No doubt. There’s been a fair amount of, I’d say, industry pushback to certain aspects of the last set of rulemaking, particularly as they apply to gathering. The gathering world views some of these requirements as onus.

Keith: The DC Circuit decision specifically ruled that the agency had violated basically the Administrative Procedure Act and the Pipeline Safety Act by failing to comply with the cost benefit requirements in the Pipeline Safety Act.

In the rupture mitigation valve rule, there were two primary arguments. One was that PHMSA had exceeded its statutory authority by applying those requirements to gathering lines.

The court did not agree with that argument, but the court did agree that PHMSA had failed to comply with the rulemaking requirements because, under the Pipeline Safety Act, PHMSA is required to prepare a proposed and final version of what’s known as a risk assessment.

In that risk assessment, the agency is supposed to consider the cost benefits and other impacts from its rulemaking proposals. In the rupture mitigation of rulemaking, there were no references at all to gathering lines and the proposed rulemaking or the proposed risk assessment.

Gatherers came to the rulemaking process and said, “Wait a minute. You’ve got some rulemaking changes here that might require gathering line operators to install these rupture mitigation valves. You haven’t analyzed the cost benefits or other impacts of that.” The agency went ahead and tried to apply those requirements to gathering lines in the final rule despite that fact.

The court, on review, agreed with the industry challengers and said, “No, this is a requirement in the statute. The agency needs to meet its statutory obligations to consider the cost benefits and other impacts of these rulemaking proposals. When it fails to do that, that’s a serious error.” The court struck down those provisions as applied to gathering lines.

Russel: I would expect PHMSA to go back through that process, do that analysis, and I would expect further rulemaking to come.

Keith: Yeah, we’ll see. In the distribution rule, PHMSA, according to the NPRM, they’re not trying to require rupture mitigation valves for gathering lines in this proceeding. They have proposed to eliminate some of the exceptions, still working through what that might mean.

I do think more focus on cost benefit issues from the industry side has been a theme. You’ll see that in the comments on the LDAR rule in addition to what you might see in the comments of this rulemaking.

I know for the gathering industry, in particular, it’s been a concern over the course of the past several rulemakings. The statute requires what the statute requires. The agency needs to do these analyses. That was one of the key points that came out of the DC Circuit decision.

Russel: Keith, I want to say as always, I really appreciate your continuing commitment to put all the work that you put in to come on the podcast and keep us updated on these rulemakings. I’ll let the listeners know that Keith always sends me a really nice set of notes, almost a legal brief, if you will, about what’s in the rule and so forth.

We always look to share that with the listeners. It’s always linked up and made available on the website, and we’ll do that again. If you want to read through the details and gather up all the specific citations to paragraphs and sections in the rule, then just go to the website, look for this episode, and look for the content available to download.

Again, Keith, thank you so much. I always learn a ton. I always enjoy talking to you. If, in fact, we actually have a GPAC meeting in November, I hope to see you in DC.

Keith: Yeah, I will definitely be there. Hopefully, we can do some podcasts on the sideline. Maybe hit up a happy hour that the firm is going to have at a location yet to be disclosed, but that’ll be an interesting meeting…

Russel: I might have to do some podcasting at the Bapst Alan happy hour. That might be really intriguing.

Keith: Yeah, we’ll try to do that early in the happy hour. I don’t want anybody to…You know.

Russel: Come on, Keith, come on.

Keith: As long as I can review and veto all kinds of…Now, later in the happy hour, you might have a far more interesting podcast than at the start of it, but I’ll leave that to your judgment.

Russel:  Thanks again, man.

Keith: Thanks, Russel. Talk to you soon.

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/Win and enter yourself in the drawing.

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Transcription by CastingWords