Frequently-Asked Question FAQ #217

FAQ-217: Justifying assessment methods prior to use

Question: In Section 192.919(b), the rule states there must be an explanation of why assessment methods are chosen to assess the integrity of the line pipe. Does this mean the methods must be chosen and explained for all segments before the assessment begins, possibly by using some sort of decision tree, or does this mean that assessment methods can be explained after the assessment is complete? For example, an operator may plan on using an ILI tool for a segment but due to last minute budget restrictions must now hydrotest the segment. Will this last minute change cause a negative effect in an OPS audit even though the operator explains the reasons for the change and the reasons for the assessment method after the assessment is complete?

Answer: Assessment methods must be identified, and demonstrated to be capable of addressing applicable threats, before an assessment is conducted. At the same time, OPS recognizes that last-minute problems arise and that plans must often change as a result. It is acceptable for operators to change their assessment plans due to unexpected situations, but the reasons for the change and the acceptability of a changed assessment method should be documented when the change is made, prior to implementing the assessment.