This week’s Pipeliners Podcast episode features Keith Coyle of Babst Calland discussing the newly reformed valve installation and rupture detection rule from PHMSA going into effect this October. 

In this episode, you will learn about rupture mitigation valves, how the new PHMSA rules are going to affect preexisting pipelines, repairing versus replacing pipes, and potential rupture notifications having a 30-minute shut-off time frame.

PHMSA Pipeline Rupture Detection Rule: 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.
    • Access the referenced advisory notice published by Babst Calland – “PHMSA Publishes Final Rule With New Valve Installation And Rupture Detection Requirements For Gas, Hazardous Liquid, And Carbon Dioxide Pipelines.”
• 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.
  • 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. 
  • 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.
• 49 CFR 192 is minimum safety requirements for pipeline facilities and the transportation of natural gas by PHMSA-regulated pipeline.
  • 192.610 contains the new requirements for valve spacing for gas transmission pipelines.
• 49 CFR 195 is minimum safety requirements for pipeline facilities and the transportation of hazardous liquids by PHMSA-regulated pipeline.
  • 195.260 and 195.418 contain the new valve spacing requirements for hazardous liquid pipelines.
• NTSB (National Transportation Safety Board) is an independent Federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation – railroad, highway, marine and pipeline.
• Rupture mitigation valves are remote controlled or automatic shut-off valves placed throughout a pipeline used to close off the pipe in case of a rupture.
• HCA (High Consequence Area) locations are segments of a pipeline system that pose the greatest risk to human life, property, and the environment.
• Highly volatile liquids are hazardous liquids which will form a vapor cloud when released to the atmosphere and which has a vapor pressure exceeding 276 kPa (40 psia) at 37.8 °C (100 °F).
• CFR (Code of Federal Regulations) is the annually updated codification of the general and permanent rules published in the Federal Register by the departments and agencies of the Federal Government.
• Episodes mentioned by Keith Coyle throughout the show: Episode 15 – Coyle’s first appearance on the podcast, Episode 223 with Skip Elliott, and Episode 228 with Bill Caram.

PHMSA Pipeline Rupture Detection Rule: Full Episode Transcript

Russel Treat:  Welcome to the Pipeliners Podcast, episode 231, sponsored by the American Petroleum Institute, driving safety, environmental protection, and sustainability across the natural gas and oil industry through world class standards and safety programs. Since its formation as a standard setting organization in 1919, API has developed more than 700 standards to enhance industry operations worldwide. Find out more about API at api.org.

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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 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.

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This week, Keith Coyle returns, and we’re going to be talking about the recently finalized and published PHMSA valve and rupture rule. Keith, welcome back to the Pipeliners Podcast. It hadn’t been such a long pause since the last time we got together and recorded.

Keith Coyle:  It has not been a fortnight, Russel. It has been much shorter than that. I always have fun talking to you, and I’m always game for it. Thanks for having me back on.

Russel:  We did an episode 151 – this has been probably almost two years ago now – about the valve and rupture rule. Now, the valve and rupture rule has been made final. Before we dive into this too deep, why don’t you tell us just a little bit about what’s the history behind this rule? What led to it? Then, we’ll talk about what’s in it, and what are people saying?

Keith:  There were two incidents involving pipelines back in 2010. One was a hazardous liquid pipeline in Marshall, Michigan, and another one was a natural gas pipeline out in San Bruno, California.

Those two incidents prompted investigations by the National Transportation Safety Board. That’s an independent agency in DC that investigates significant transportation related events.

The findings and recommendations from those two NTSB recommendations included findings related to the use of rupture mitigation valves and improving the ability of pipeline operators to respond to events that involve ruptures.

As a followup to those NTSB recommendations, Congress included some provisions in the 2011 Pipeline Safety Act that directed the Pipeline and Hazardous Materials Safety Administration to initiate some rulemakings to change their regulations to address the findings that NTSB made as a result of those investigations. There were also some provisions to go out and conduct some studies related to the use of rupture mitigation valves and related technologies.

PHMSA hired Oak Ridge National Laboratories to go out and do a technical study on the use of rupture mitigation valves. I think the GAO (General Accounting Office) did a separate study on responding to natural gas and hazardous liquid pipeline releases.

After all that data and information came back in early 2020, PHMSA proposed a rule that would address the congressional mandate, the NTSB findings, and the results of these studies, by changing their regulations relating to rupture mitigation valves and requirements related to that.

That’s where things stood the last time we talked. I think it was in the summer of 2020. A lot’s happened in the world since then, but I’m happy to be back on to talk about it.

Russel:  Yeah, absolutely. I’m looking at the show notes on the website from the last time we talked, and it brings to mind, we did an episode last time right after the GPAC and the LPAC met and talked about the rule. One of the very interesting dynamics there is that they had the GPAC meeting the first day, the gas meeting, and the liquid meeting the second day.

There was a lot of, I don’t know how to say this, but it was like there was an operating assumption that we’ll just do the same thing with the liquid valves that we do with the gas valves in terms of the way we write this rule.

It became very obvious very quickly that that’s not going to work at all, just because of the very different nature of hydraulics and how those things work.

Keith:  No, I agree with that. There were definitely operational, technical considerations that were unique to each of those two parts of the industry. PHMSA was trying to move a rulemaking in parallel to address a statutory mandate and some other things that they thought could be applied to both sides of the sector. That created some challenges when addressing the proposed rule.

That was actually one of the advisory committee meetings that I found, to the extent you can find those things, exciting.

There was a lot of interesting discussion and conversation that happened during that meeting. There were some pretty serious recommendations that the advisory committees made that PHMSA sought to address at least some of those in this rule. In terms of feedback and input on the proposed rule, I thought the advisory committee was very active and engaged during that process.

Russel:  Exactly. Now that the rule’s been published and you’re starting to look at it and talk to operators about how it’s going to get implemented, what are you finding? What are the operators saying about trying to implement the rule?

Keith:  One of the most challenging things about this rule is it’s touching a lot of different regulations, changing provisions that are located throughout the rules. There are some different compliance deadlines that apply for purposes of certain provisions. There are other exceptions and limitations that are applied in some of the rules, like a six-inch diameter cutoff.

There’s also a new definition of what an entire replacement is for purposes of certain rules where you need to have at least two miles of pipe within a continuous five-mile pipeline replaced within the previous 24 months.

A lot of that stuff has proved challenging for me as a lawyer, somebody who does this all day every day for a pretty long time here. It’s been difficult for me to unwrap some of that stuff, and we’re hearing some of the same from the clients, that this is a difficult rule to sort out.

Some of the sorting will be done as you start to apply rules to specific projects like valve spacing, rupture mitigation valve installation. Some of those things get flushed out when you’re dealing with a specific project in terms of which criteria will this new pipeline trigger or this replacement project trigger. That’s the feedback we’ve generally been getting.

Russel:  It’s interesting. How many different sections of the rule are being impacted by this? Do you know?

Keith:  I don’t know that I counted all of them. There are some changes in the valve spacing requirements in 192 and 195. There are some changes relating to class location requirements just for gas pipelines. Those are in 192.610 I believe.

There’s some changes to the operation and maintenance requirements both for 192 and 195, changes to some of the procedures that you need to have, provisions related to rupture mitigation valves, operation capability, those sort of things. There are changes to the integrity management requirements or at least clarifications to the requirements.

Russel:  It’s really scattered throughout the code.

Keith:  Yes. The applicability of some of those rule changes will depend. Some of the requirements will apply to existing pipelines. Some of the requirements will apply to new pipelines that meet certain diameter thresholds and to replacements that meet the threshold.

This is one of the challenges that we run into when we’re dealing with changes to rules. There are certain regulations in 192 and 195 that can’t be applied retroactively to existing pipelines, stuff like design, construction, initial testing, initial inspection.

When you get into the later portions of the code, things like operation, maintenance, and integrity management, those can be applied retroactively to both existing pipelines and to new pipelines.

You need to sort that out in your mind when you’re going through these changes and figure out what are the ones that go into effect right away on the effective day of the rule versus what are the ones that maybe I don’t need to comply with until a later time.

Russel:  I could see where the operators would have a big challenge with this. What I’ve always found in the work that we do is the program changes that are within a single department or discipline are one level of complexity.

When you start dealing with a program that has changes across more than one department, it’s like the complexity increases exponentially with the number of departments that are impacted.

Keith:  Some of these requirements are, for instance, for liquid pipelines, PHMSA’s adding some new spacing requirements for the installation of valves.

There’s a 20-mile limit for non-HCA locations (non-high consequence area locations). There’s a 15-mile limit for high consequence areas or pipelines that could affect high consequence areas.

There’s a 7.5- mile spacing requirement for certain pipelines that transport highly volatile liquids, but that can be increased a little bit if you file a notification.

These are the things that operators are going to have to look at when they’re building new pipelines, which is a little bit easier to absorb a rule change when you’re dealing with a brand new pipeline. After a rule’s in effect, you can plan a little bit better. One of the more challenging things about this rule is applicability to replacement projects.

Russel:  That actually is one of the questions I wanted to ask you is what defines a replacement project in the context of the valve and rupture rule?

Keith:  Some of the requirements that we just talked about are limited to what PHMSA is defining as entirely replaced. For purposes of this rule, PHMSA has defined “entirely replaced” as basically at least two miles within any continuous five-mile length of the pipeline over a 24-month period. That definition of entirely replaced is picked up in some of the provisions.

For instance, the rupture mitigation valve installation requirements, those are new. There’s also a diameter limit that’s associated with those rupture mitigation valve installation requirements, a six-inch diameter limitation.

You have to be really careful when you’re going through these rules. You have to check the scope and applicability sections for the rules. You have to look at the compliance dates that might be provided in the rules. Some of these rules have a compliance date of April 2023. Other rules will go into effect on the effective date of the rule, which is in October of this year.

It will matter, too, if you’re dealing with gas pipelines versus hazardous liquid pipelines. One of the things I mentioned earlier was some changes to the valve spacing requirements for class location driven pipeline replacements. That’s a regulation that’s unique to the gas pipeline side because we don’t use the class location concept for hazardous liquid pipelines.

Russel:  My take on this rule is unlike some other things, the implementation in gas and the implementation in liquids is completely different.

Keith:  In some respects, there are definitely parallels. There’s a lot of concepts that are paralleled. There are differences between the two sides of the rule in terms of changes or provisions that are unique on one side of the house and not on the other. There are no highly volatile liquid pipelines covered under 192. You have that under 195.

One of the things that’s more challenging about this rule is the new pipeline versus replacement or repair pipeline scenarios and when you need to do certain things as you’re rolling out new projects.

Is this an entirely new pipeline? If it is, when’s it being built? OK. What size is it? What location is it in? OK. I need to go look. Do I need to install a rupture mitigation valve? What’s the spacing requirements for those rupture mitigation valves?

I need to go look at the operation and maintenance requirements and see if those procedures are updated to accommodate the changes that the rule requires in terms of how I’m supposed to be responding to potential ruptures and things like that.

I see one of the more challenging things for me is how the rule deals with “replacement scenarios versus new pipeline.”

Russel:  I know, Keith, that in the GPAC, in the LPAC conversations there was a lot of conversation about definition of a rupture and defining the time to respond. They were nailing down some standards around all of that. Can you tell us where that landed in the final rule?

Keith:  Sure. There were a couple of different concepts that were at play during the advisory committee process.

It was this idea of what is the information that is sufficient to require an operator to identify a potential rupture. When should an operator know that a potential rupture has occurred? That’s concept one. Concept two is how fast does the operator need to respond to that potential event and what do they need to do.

One of the things that PHMSA had in the rulemaking proposal was there was a 10-minute limitation when you received certain information to make a judgment as to whether you had an actual rupture, and then there was a separate timeline on the back side of that that required you to basically respond to that rupture identification by closing your rupture mitigation valves or taking other actions.

What the advisory committee recommended to the agency was, “Hey, look, this is a little complicated here. There may be too many moving parts and too many timelines. Can we try to go with one uniform timeline?” Which they did in the final rule. There’s this 30-minute response time generally speaking.

The other concepts that are important under this new rule is PHMSA has defined what notification of a potential rupture means, and it defines that basically by using a time-based and volumetric threshold. It’s a pressure change of 10 percent or more over a 15-minute interval unless an operator defines it otherwise based on factors and criteria specified in the rule.

Then once you get that potential notification of a rupture, the operator in their procedures has to define OK, I’ve identified a rupture based on that potential notification, and then I’ve got 30 minutes to do my response, to close my rupture mitigation valves, things like that.

Russel:  I recall in the GPAC and LPAC that that conversation in particular was very materially different on the gas side versus the liquid side. The 30 minutes was agreeable on both sides, but the mechanism for identifying a rupture was different.

Keith:  I think that’s right.

Russel:  On the liquid side, it was more about a flow difference, and on the gas side, it was more about a pressure difference.

Keith:  I recall you bringing that up when we had this chat a couple years ago that your understanding was that just given operational characteristics on the gas side, maybe a pressure and time threshold was easier to handle on the gas side than it might be on a liquid side where you might have greater deviations in flow on a system.

One of the things that came up in the advisory committee process was one of the members saying, “Look, this definition, if I were to apply it to a new pipeline system, I might have hundreds of notifications of potential ruptures.”

And PHMSA tries to accommodate that flexibility by allowing operators to document in their procedures, “If the 10 percent, 15-minute doesn’t work for you, document a different threshold, a different set of criteria to use based on the circumstances of your system.”

Russel:  Doing a evaluation on pressure change in liquid systems is not very helpful. Very helpful on the gas side. Volume is more helpful on the liquid side.

Keith:  One of the other things that the rule accommodated was this idea of you have a notification of a potential rupture, and then you need to define when you identify an actual rupture event based on that indication or notification of a potential rupture.

One of the concerns that came out on the proposed rule was, “Hey, look, we don’t want to start the doomsday clock every time we have a potential indication of a rupture. Like if you force us to close valves and do other things every time we have a potential indication of a rupture, that’s going to cause severe operational disruptions within the system.”

So I think in the final rule, PHMSA tried to accommodate that with an understanding that notification of potential rupture is one thing, and then the operator needs to have a process in place for making an identification of the rupture, an actual rupture, which will then trigger the 30-minute time frame.

Russel:  I think actually that as this rule starts to get rolled out and people begin to understand it, it’s actually going to be good for the industry because there’s not a lot of consistency at present around how that’s done.

It’s all very operator specific, and this is going to drive some consistency, and ultimately that’ll be a good thing. It’ll be a painful transition, no doubt, but ultimately it’ll be a good thing.

Keith:  The 30-minute time frame, my understanding from the folks that use the technology, if you have an automatic shutoff valve or remotely controlled valve, you can close that well in advance of the 30-minute time frame.

There are provisions in this rule that allow manual valves to be used in certain circumstances, and those are the ones where it might be a little bit harder to get out there and close the manual valve within the 30-minute time frame, depending on where the valve is located, and where your personnel are located.

Is it an urban area? Am I dealing with traffic? Is it a very rural area? Do I have personnel on site? Some of those challenges will also be worked out as part of this implementation process.

Russel:  No doubt. What’s your advice to operators now that this rule has been published? Actually, before I ask this question, what’s the key timelines for implementation?

Keith:  The effective date of the final rule is October of this year. What’s an effective date? An effective date is when the Code of Federal Regulations will actually change to reflect the text of the rule that was published earlier this month. If you went on the Code of Federal Regulations today and you pull down 49 CFR and open 192, 195, you wouldn’t see any changes to the rule text.

On the online version, you would see a link to the final rule that had been published, but you wouldn’t see any actual changes in the text. In October of this year, the rule text will change, and you’ll see that.

Some of the compliance requirements are triggered to a deadline in April 2023. That’s particularly for the rupture mitigation valve installation requirements.

For new or “entirely replaced pipelines” that meet certain criteria on or after April 2023, that’s when those requirements will start to kick in. I would just caution folks to be careful, because there are definitely requirements in this rule that are going to go into effect in October, and there are things that will need to be done in October. I would focus in particular there on some of the updates to the operation and maintenance regulations and just be ready to accommodate those.

There may be some provisions within there where if they’re tied to these rupture mitigation valve installation requirements that don’t kick in for a few more months, maybe those you don’t need to do, but there are definitely provisions in there that you need to be aware of.

Russel:  Interesting. That’s not a very long timeline.

Keith:  No. Look, one of the things the advisory committees on some of these provisions, they were more accommodating in terms of the time frame. For some of the rule changes, they were suggesting a 24-month compliance deadline.

PHMSA shortened those deadlines in this rule. They provided an explanation for that in the final rule, but these things are going to happen a little bit quicker than I think the people involved in the advisory committee anticipated. That’s going to be another challenge for operators in terms of things are moving a little bit faster than everybody thought.

Russel:  That doesn’t really surprise me.

Keith:  We’ve seen that with some other recent final rules that came out on the new rule for gas gathering lines. There was a shorter compliance deadline than what the advisory committees had recommended on that one too. We’ve seen this on the last two rules. PHMSA provided a rationale for why they went with a shorter deadline in both of those rules.

There are some mechanisms built into this rule. I mentioned this pretty quickly, but for some of these requirements, you can use this 90-day, no-objection process that PHMSA has stood up in the last few years where you provide a notice to the agency with certain information, and the agency has essentially 90 days to object to your request for relief, whether it’s an alternative compliance deadline or use of alternative technology.

They’ve used that as a mechanism in some of these more recent rulemakings as a way to allow operators who have a particular compliance challenge on deadline to get an extension or some kind of relief.

Russel:  Note to operators, if you’re not already figuring out how to implement the requirements of this rule, you’re behind.

Keith:  I know it’s fresh off the presses, and it’s only been up there for about two weeks. I’m still sorting it in my mind. Every once in a while, I’ll have some cold sweats where I’m trying to figure out what a rupture mitigation valve is. That’s just sound advice across the board.

Take a look at this rule now. Even though you have a couple of months until the effective date and a few more months after that for some of these compliance dates, you need to be ahead of the game, sort it in your mind, get ready as a company because, again, you need to be planning, particularly as you have new projects unfold, whether it’s new build pipelines or replacements.

Just make sure, “Hey, look, that project that I got going on, part of it’s going to be done before some of these compliance deadlines or the effective date, but part of it isn’t. How does that affect this pipeline system,” or “I’m thinking about doing a replacement project a couple of months down the road, am I going to need to accommodate new valve spacing requirements or install rupture mitigation valves as part of that project?” Think ahead.

Russel:  That’s right. Certainly you’re going to have to look at your forward-looking construction plans and take this stuff into account. Of course, I would assume that most people doing that have already got an eye towards it.

Keith:  They do, but we’ve got questions from clients who have been in the planning stage for projects, and then this rule comes out, and they’re going to start a project in the next few months or even in the next 18 months because that’s the kind of lead times you need for some of this stuff.

They’re like, “All right, how does this impact the project that I had planned? Do I need to have more valves? Do I need to space them at different intervals? Do I need to have automated remote control valves?” Some of these decisions have, they’ve been in the oven for quite a while now. You need to take a look at this rule and figure it out.

From a company perspective, it’s like even if some of these compliance deadlines don’t run until the future, does it make sense for me as a company to just go ahead and do some things that aren’t strictly required under the rule, but I want to do it just to get ahead of my compliance obligations.

Russel:  It’s always true, too, that even if you’re tracking very closely one of these rules as they’re working through, you don’t know exactly what they say until they come out.

Keith:  A great example of that is this rule changes regulatory text in another rule that was published a few months ago, and neither of those changes are in the CFR yet. It’s crazy.

This rule amended a regulation that hasn’t yet been made effective in the CFR, stuff for gathering. We have changes to the gathering regs that aren’t in effect until next month, but this rule changes those regulations that aren’t yet effective.

There’s a lot going on in the regulatory space right now. Companies can be forgiven if they’re not keeping track of everything and understanding all of it.

Russel:  Yeah. Of course. This is always a challenge. This is always a challenge. There’s so dadgum many moving parts. It’s always a challenge.

Keith:  For a lot of years, we were just waiting for rules to come. There was a lot of activity in the 2011 reauthorization of the Pipeline Safety Act and then a little bit more in 2016. For a while, there were some really big rulemakings that had been spun up, and we were just waiting for the final rules.

Now, we’re the drinking from the fire hose end of this where we’ve got a lot of final rules coming out. It’s become challenging to digest all of it.

Russel:  No doubt. What additional advice would you give to operators about this?

Keith:  Just a couple of more procedural things to think about. There is an opportunity to file a petition for reconsideration of the final rule. There’s a 30-day deadline for that, 30 days from the publication date of April 8. There’s a possibility also for seeking judicial review of the rule. That deadline runs 89 days from the publication date.

Other things to keep your eyes on are PHMSA guidance. I assume that the agency will be publishing guidance related to the implementation of this rule. The guidance form they’ve chosen in recent years is frequently asked questions. I would be on the lookout for those to get a sense of how the agency anticipates operators to be implementing these rules.

There’s a lot of new regulatory text, so the FAQs are going to be important at least for operators that want to understand PHMSA’s expectations on the rule. I would be on the lookout for those FAQs and additional guidance, which hopefully comes pretty quickly.

The rule was just published, and we got a few months until October before it goes into effect. Hopefully, PHMSA’s using that window there to get some more guidance out to the community to help people understand what they need to be doing.

Russel:  One of the things I just want to mention is we’re going to link up into the show notes some advisory notices that Keith’s firm, Babst Calland, has put out that provides some additional written material.

If you’re interested in learning more about the details of what’s in the rule, go to the Pipeline Podcast Network website, look up this episode, and you’ll be able to find that on the show notes. Hopefully, that’ll be useful to operators.

Keith:  I know some of the pipeline trade organizations are very active in reviewing this rule, and they’re getting out information to their membership on at least what they understand the rule to be and what members might want to be thinking about in terms of compliance.

I would also recommend engaging your trade organization, pipeline trade organization, in terms of providing feedback, asking questions. Those trade organizations are extremely valuable. They allow operators to have discussion amongst other operators or with the experts at the trade organization.

It’s good to get outside of just your own company to get a sense of what other people in the industry are thinking about the rule and the approaches that they’re taking for compliance.

Russel:  Absolutely. Absolutely. Listen, Keith, as always, it’s a pleasure, and thanks for coming on and giving us a heads-up about the valve and rupture rule.

Keith:  I’m always more than happy to come on and chat with you. I love this platform. You’re doing great work. I was telling Russel, before the show started, that I’ve been listening to some older episodes.

I really enjoyed the episode that you have with Skip Elliott, the former PHMSA administrator. I found it really enlightening, just the way that you have this very informal but informative conversation with somebody who did big things while they were at PHMSA.

I also had a chance to listen to your episode with Bill Caram from the Pipeline Safety Trust, who’s somebody I haven’t had the chance to work with yet. Those two episodes were really interesting and fun, and I’m glad you put those out.

Russel:  Thanks. Thanks for that, Keith. Some of these guys like that, it’s hard to get those things scheduled, but boy, you certainly capture some gold and pearls, and just valuable ideas and concepts and experience.

Keith:  It’s a lot more easy to digest than rupture mitigation valves.

Russel:  [laughs]

Keith:  Not that I don’t love a good rupture mitigation valve, which I do, but I bet your listeners probably learn a whole lot more from those kinds of enlightening conversations than from listening to some lawyer go on and on.

Russel:  I don’t know about that. I think that the listeners like the more technical, and one of the things that people like is we cover these topics from a wide variety of perspectives. There’s the deep-in-the-weeds technical what is an ASV and how it works all the way to why they are writing the rule the way they are.

Keith:  It says a lot that you can have folks from the Pipeline Safety Trust, from API, from within the agency. You have all these different voices on the show, and they’re all very comfortable talking to you because they see the value in the platform, and they understand that they’re going to be treated fairly, and everybody has an opportunity to say what they need to say. I appreciate that as well.

Russel:  Cool. Thanks, Keith, until we meet again. Talk to you next time.

Keith:  Yes, sir. Thanks, Russel.

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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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 reach out to me on LinkedIn. Thanks for listening. I’ll talk to you next week.

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Transcription by CastingWords