PHMSA Gas Integrity Management
Time: 11/08/2008 04:43 PM

Protocol Item D.04

D.04 ECDA Direct Examination

Verify that the ECDA Direct Examination process complies with ASME B31.8S-2004, Section 6.4 and NACE RP0502-2002, Section 5 to collect data to assess corrosion activity and remediate defects discovered. [NACE RP0502-2002, Section 5.1.1 and §192.925(b)(3)]

  1. Verify that the operator performs excavations and data collection in accordance with NACE RP0502-2002, Section 5.3, NACE RP0502-2002, Section 5.4, NACE RP0502-2002, Section 5.10 and NACE RP0502-2002, Section 6.4.2.
    1. Verify that the operator makes excavations based on priority categories described in NACE RP0502-2002, Section 5.2. [NACE RP0502-2002, Section 5.3.1]
    2. Verify that the operator identifies and implements minimum requirements for data collection, measurements, and recordkeeping, to evaluate coating condition and significant corrosion defects at each excavation location. [NACE RP0502-2002, Section 5.3, NACE RP0502-2002, Section 5.4, NACE RP0502-2002, Appendix A, NACE RP0502-2002, Appendix B, and NACE RP0502-2002, Appendix C]
    3. Verify that the number and location of direct examinations complies with NACE RP0502-2002, Section 5.10 and NACE RP0502-2002, Section 6.4.2
  1. Verify that the operator determines the remaining strength at locations where corrosion defects are found. Any corrosion defects discovered during direct examinations must be remediated in accordance with �192.933. [�192.925(b)(3)(ii), �192.933, and NACE RP0502-2002, Section 5.5]

  1. Verify that the operator identifies the root cause of all significant corrosion activity, [NACE RP0502-2002, Section 5.6] and identifies and reevaluates all other indications that occur in the pipeline segment where similar root-cause conditions exist. [NACE RP0502-2002, Section 5.9.3]
    1. Verify that the operator considers alternative methods of assessing the integrity of the pipeline segment if the operator's root cause analysis uncovers problems for which ECDA is not well suited. [NACE RP0502-2002, Section 5.6.2 and �192.925(b)(3)(ii)(b)]
  1. Verify that the operator mitigates or precludes future external corrosion resulting from significant root causes. [NACE RP0502-2002, Section 5.7]

  1. Verify that the operator performs an evaluation of the indirect inspection data, the results from the remaining strength evaluation and root cause analysis to evaluate the criteria and assumptions used to: [NACE RP0502-2002, Section 5.7, NACE RP0502-2002, Section 5.8 and �192.933]
    1. Categorize the need for repairs
    2. Classify the severity of individual indications
  1. As appropriate, verify the basis upon which the operator may reclassify and reprioritize indications in accordance with any of the provisions that are specified in NACE RP0502-2002, Section 5.9. [�192.925(b)(3)(iv)]

  1. Verify the operator establishes and implements criteria and internal notification procedures for any changes in the ECDA Plan, including changes that affect the severity classification, the priority of direct examination, and the time frame for direct examination of indications. [�192.925(b)(3)(iii), �192.909, and �192.911(k)]

  1. Verify that the operator has a process to consider the use of assessment methods other than ECDA (i.e., ILI or Subpart J pressure test) to assess the impact of defects other than external corrosion (e.g., mechanical damage and stress corrosion cracking) discovered during direct examination. [NACE RP0502-2002, Section 5.1.5 and �192.933]

  1. Verify that the operator applies more restrictive criteria when conducting ECDA for the first time on a covered segment. [�192.925(b)(3)(i)]

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