How will PHMSA handle casing assessments made before the guidance material was made public (when operators used ECDA but may not have followed the guidelines entirely)?
PHMSA cannot make a blanket statement regarding how it views ECDA integrity assessments made prior to the publication of the casing guidance. It can affirm that if the guidance was adhered to, then the assessment is considered acceptable. Where there are differences, a situation by situation analysis will need to be performed and technical justifications for variances to the guidance provided. • FAQ-272. How would one handle a cased segment that has the attributes of Item 1 and Item 4 (from Exhibit B)? For example, a casing that has an attribute of Item 1, no attributes of Items 2-6, and perhaps some attributes from Items 7-17, could be placed in, say, Region A. Another casing that has an attribute of Item 4, no attributes of Items 2-6, and perhaps some attributes from Items 7-17, would be required per the guidance to be placed into a different region, say, Region B. How then would one regionalize a cased segment that has the attributes of Items 1 and 4, no attributes of Items 2, 3, 5,
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