PHMSA Gas Integrity Management Protocol Results Form

Protocol: A B C D E F G H I J K L M N O P

Explanation of Protocol Format

Each protocol element will have top-tier protocols that address the high level requirements. The regulatory requirement upon which the protocol is based is contained in brackets; e.g., [§192.905(a)]

Each top-tier protocol will have detailed "sub-tier" protocols which collectively lead the inspector to draw overall conclusions about compliance with the top-tier protocol. The regulatory requirement, upon which each sub-tier protocol is based, is also contained in brackets.

Notes on protocols:

The typical sentence structure used in the protocols follows the form of "Verify that [describe the requirement]." The use and meaning of the term "verify" is expanded upon below.
PHMSA will "verify" an operator’s compliance status with respect to each requirement. In order to perform this verification, PHMSA will inspect the operator’s documented processes and procedures in order to determine if a program has been established that complies with rule requirements. In addition, PHMSA will inspect an operator’s implementation records to determine if the operator is effectively implementing its programs and processes. The purpose of the PHMSA verification/inspection is not to perform a quality check of every integrity related activity. The PHMSA inspection is conducted in the form of an audit. As a result, the PHMSA inspection will typically perform an inspection of selected operator records sufficient in breadth and depth to give the inspection team adequate understanding regarding the degree of an operator's commitment to compliance with applicable requirements and/or the degree to which the operator's program has been effective with respect to achieving compliance. PHMSA may use any number of inspection or audit techniques to identify potential compliance issues. Program documents may be inspected to determine if adequate processes have been developed and documented to the degree necessary for competent professionals to understand and effectively implement the process with results that are consistent and repeatable. For example, one technique that might be used by the inspection team is a "vertical slice" in which a specific covered segment or pipeline system is selected to perform a detailed inspection of every aspect of integrity management, thus following a specific example through the entire process of integrity management. Based on those reviews, OPS will identify potential non-compliances with rule requirements. PHMSA can not and will not certify nor conclude that an operator is in full compliance with rule requirements, even if the inspection does not identify any areas of non-compliance. Operators are wholly responsible for compliance with regulations.
References to regulatory requirements may include references to specific rule sections/paragraphs and/or to industry standards that are invoked in the rule. As specified in §192.7, any requirement invoked by reference is a requirement of the rule as though it were set out in full in the regulation.
Protocols are subject to change without notice.
Protocols are an initial guide for use by OPS inspectors during Integrity Management inspections. Inspectors will develop additional questioning during the course of the inspection to investigate the specifics of an operator's program. Protocols are not to be construed as an exhaustive list of questions that may be presented to operators during an inspection.
Protocols are made publicly available as a courtesy to operators as they develop their Integrity Management program, as well as other stakeholders.

Protocol Area D. DA Plan

D.01 ECDA Programmatic Requirements
D.02 ECDA Pre-Assessment
D.03 ECDA Indirect Examination
D.04 ECDA Direct Examination
D.05 ECDA Post-Assessment
D.06 Dry Gas ICDA Programmatic Requirements
D.07 Dry Gas ICDA Pre-Assessment, Region Identification and Use of Model
D.08 Dry Gas ICDA Direct Examination
D.09 Dry Gas ICDA Post-Assessment
D.10 Wet Gas ICDA Programmatic Requirements
D.11 SCCDA Data Gathering and Evaluation
D.12 SCCDA Assessment, Examination and Threat Remediation

D.01 ECDA Programmatic Requirements

If the operator elects to use ECDA, verify that the operator develops and implements an ECDA plan in accordance with §192.925.

D.01.a. Verify that the operator developed a documented ECDA plan, and developed procedures to implement the plan. [§192.925(b)]

D.01.a. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.01.a. Inspection Issues Summary Leave blank if no issue was identified.

D.01 Documents Reviewed (Tab from bottom-right cell to add additional rows.)
Document Number	Rev	Date	Document Title

D.01 Inspection Notes

D.02 ECDA Pre-Assessment

Verify that the ECDA Pre-assessment process complies with ASME B31.8S-2004, Section 6.4 and NACE RP0502-2002 to (1) determine if ECDA is feasible for the pipeline to be evaluated, (2) identify ECDA regions and (3) select Indirect Inspection Tools. [§192.925(b)(1)]

D.02.a. Verify that the operator identifies and collects adequate data to support ECDA pre-assessment. [NACE RP0502-2002, Section 3.2]

D.02.a. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.02.a. Inspection Issues Summary Leave blank if no issue was identified.

D.02.b. Verify that the operator conducts an ECDA feasibility assessment by integrating and analyzing the data collected. [NACE RP0502-2002, Section 3.3]

D.02.b. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.02.b. Inspection Issues Summary Leave blank if no issue was identified.

D.02.c. Verify that the operator complies with all requirements for appropriate indirect inspection tools selection: [NACE RP0502-2002, Section 3.4, NACE RP0502-2002, Table 2, and 192.925(b)(1)(ii)]

A minimum of 2 complementary tools must be selected such that the strengths of one tool compensate for the limitations of the other tool. (Note: The operator must consider whether more than two indirect inspection tools are needed to reliably detect corrosion activity.)
Tools are able to assess and reliably detect corrosion activity and/or coating holidays.
Verify that the operator documents the basis for its tool selection.
If the operator utilizes an indirect inspection method not listed in NACE RP0502-2002, Appendix A, verify that the operator justifies and documents the method's applicability, validation basis, equipment used, application procedure, and utilization of data. [§192.925(b)(1)(ii)]

D.02.c. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.02.c. Inspection Issues Summary Leave blank if no issue was identified.

D.02.d. Verify that the operator identifies ECDA Regions based on the use of data integration results applied to specified criteria. [NACE RP0502-2002, Section 3.5]

D.02.d. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.02.d. Inspection Issues Summary Leave blank if no issue was identified.

D.02.e. Verify that the operator applies more restrictive criteria when conducting ECDA for the first time on a covered segment. [§192.925(b)(1)(i)]

D.02.e. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.02.e. Inspection Issues Summary Leave blank if no issue was identified.

D.02 Documents Reviewed (Tab from bottom-right cell to add additional rows.)
Document Number	Rev	Date	Document Title

D.02 Inspection Notes

D.03 ECDA Indirect Examination

Verify that the ECDA Indirect Examination process complies with ASME B31.8S-2004, Section 6.4 and NACE RP0502-2002, Section 4 to identify and characterize the severity of coating fault indications, other anomalies, and areas at which corrosion activity may have occurred or may be occurring, and establish priorities for excavation. [ï¿½192.925(b)(2)]

D.03.a. Verify that the operator conducts indirect examination measurements in accordance with NACE RP0502-2002, Section 4.2.

Verify that the operator identifies and clearly marks the boundaries of each ECDA region. [NACE RP0502-2002, Section 4.2.1]
Verify that the operator performs indirect inspections over the entire lengths of each ECDA region and that the inspections conform to generally accepted industry practices. [NACE RP0502-2002, Section 4.2.2]
Verify that the operator specifies and follows generally accepted industry practices for conducting ECDA indirect inspections and analyzing results. [NACE RP0502-2002, Section 4.2.2]
Verify that the operator specifies the physical spacing of readings (and the practices for changing the spacing as needed) such that suspected corrosion activity on the segment can be detected and located. [NACE RP0502-2002, Section 4.2.3]

D.03.a. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.03.a. Inspection Issues Summary Leave blank if no issue was identified.

D.03.b. Verify that the operator properly aligns indications and compares the data from each indirect examination to characterize both the severity of indications and urgency for direct examination in accordance with NACE RP0502-2002, Section 4.3 and NACE RP0502-2002, Section 5.2.

Verify the operator specifies criteria for identifying and documenting those indications that must be considered for excavation and direct examination. Minimum criteria include

Known sensitivities of assessment tools
The procedures for using each tool
The approach to be used for decreasing the physical spacing of indirect assessment tool readings when the presence of a defect is suspected. [ï¿½192.925(b)(2)(ii) and NACE RP0502-2002, Section 4.3.1.1]

Verify that the operator specifies and applies criteria for classification of the severity of each indication. [NACE RP0502-2002, Section 4.3.2],

Verify that the operator considers the impact of spatial errors when aligning indirect examination results. [NACE RP0502-2002, Section 4.3.1.2]
Verify that the operator compares the results from the indirect inspections and determines the consistency of indirect inspections results to resolve conflicting or differing indications by the primary and secondary tools. [NACE RP0502-2002, Section 4.3.3]
Verify that the operator compares indirect inspection results with pre-assessment results to confirm or reassess ECDA feasibility and ECDA Region definitions. [NACE RP0502-2002, Section 4.3.4]

Verify that the operator specified and applies criteria for defining the urgency level (i.e., immediate, scheduled, or monitored) with which excavation and direct examination of indications will be conducted based on the likelihood of current corrosion activity plus the extent and severity of prior corrosion. [ï¿½192.925(b)(2)(iii) and (iv) and NACE RP0502-2002, Section 5.2]
Verify that the operatorï¿½s ECDA procedures have a process to address pipeline coating indications. The procedures must provide for integrating ECDA data with encroachment and foreign line crossing data to evaluate the covered segment for the threat of third party damage, and to address this threat as required by ï¿½192.917(e)(1) (See Protocol C.02 and Protocol C.03). [ï¿½192.917(b), ï¿½192.917(e) and ï¿½192.925(b)]

D.03.b. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.03.b. Inspection Issues Summary Leave blank if no issue was identified.

D.03.c. Verify that the operator applies more restrictive criteria when conducting ECDA for the first time on a covered segment. [ï¿½192.925(b)(2)(i)]

D.03.c. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.03.c. Inspection Issues Summary Leave blank if no issue was identified.

D.03 Documents Reviewed (Tab from bottom-right cell to add additional rows.)
Document Number	Rev	Date	Document Title

D.03 Inspection Notes

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 Â§192.925(b)(3)]

D.04.a. 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.

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]
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]
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

D.04.a. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.04.a. Inspection Issues Summary Leave blank if no issue was identified.

D.04.b. 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 ï¿½192.933. [ï¿½192.925(b)(3)(ii), ï¿½192.933, and NACE RP0502-2002, Section 5.5]

D.04.b. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.04.b. Inspection Issues Summary Leave blank if no issue was identified.

D.04.c. 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]

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 ï¿½192.925(b)(3)(ii)(b)]

D.04.c. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.04.c. Inspection Issues Summary Leave blank if no issue was identified.

D.04.d. Verify that the operator mitigates or precludes future external corrosion resulting from significant root causes. [NACE RP0502-2002, Section 5.7]

D.04.d. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.04.d. Inspection Issues Summary Leave blank if no issue was identified.

D.04.e. 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 ï¿½192.933]

Categorize the need for repairs
Classify the severity of individual indications

D.04.e. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.04.e. Inspection Issues Summary Leave blank if no issue was identified.

D.04.f. 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. [ï¿½192.925(b)(3)(iv)]

D.04.f. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.04.f. Inspection Issues Summary Leave blank if no issue was identified.

D.04.g. 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. [ï¿½192.925(b)(3)(iii), ï¿½192.909, and ï¿½192.911(k)]

D.04.g. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.04.g. Inspection Issues Summary Leave blank if no issue was identified.

D.04.h. 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 ï¿½192.933]

D.04.h. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.04.h. Inspection Issues Summary Leave blank if no issue was identified.

D.04.i. Verify that the operator applies more restrictive criteria when conducting ECDA for the first time on a covered segment. [ï¿½192.925(b)(3)(i)]

D.04.i. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.04.i. Inspection Issues Summary Leave blank if no issue was identified.

D.04 Documents Reviewed (Tab from bottom-right cell to add additional rows.)
Document Number	Rev	Date	Document Title

D.04 Inspection Notes

D.05 ECDA Post-Assessment

Verify that the ECDA Post assessment process complies with ASME B31.8S-2004, Section 6.4 and NACE RP0502-2002, Section 6, to (1) define reassessment intervals and (2) assess the overall effectiveness of the ECDA process. [§192.925(b)(4) and §192.939]

D.05.a. Verify that the operator determined reassessment intervals in accordance with NACE RP0502-2002, Section 6.

Verify the adequacy of the operators remaining life calculations. [NACE RP0502-2002, Section 6.2]
Verify that the maximum re-assessment intervals for each region are one half the calculated remaining life. [NACE RP0502-2002, Section 6.1.3 and NACE RP0502-2002, Section 6.3]

D.05.a. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.05.a. Inspection Issues Summary Leave blank if no issue was identified.

D.05.b. Verify that the reassessment intervals are adjusted if required in accordance with special provisions in Subpart O, as follows:

Verify that reassessment intervals do not exceed the maximum intervals (refer to Protocol F) established in §192.939, as follows:

10 years for pipeline segments operating at SMYS levels greater than 50%
15 years for those segments operating between 30 and 50% SMYS
20 years for those segments operating below 30% SMYS

Verify that the operator specifies and applies criteria for evaluating whether conditions discovered by direct examination of indications in each ECDA region indicate a need for reassessment of the covered segment at an interval less than that specified in §192.939. [§192.925(b)(4)(ii)]

D.05.b. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.05.b. Inspection Issues Summary Leave blank if no issue was identified.

D.05.c. Verify that performance measures for ECDA effectiveness have been defined and are monitored. [§192.925, §192.945(b) and NACE RP0502-2002, Section 6]

Verify that at least one additional, randomly selected anomaly location has been excavated for process validation. [NACE RP0502-2002, Section 6.4.2]
Verify that additional criteria have been established and monitored to evaluate long-term program effectiveness such as those identified in NACE RP0502-2002, Section 6.4.3. [§192.945(b) and NACE RP0502-2002, Section 6.4.3]

D.05.c. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.05.c. Inspection Issues Summary Leave blank if no issue was identified.

D.05.d. Verify the operator's process has incorporated feedback at all appropriate opportunities throughout the ECDA process to demonstrate feedback and continuous improvement. [§192.907(a) and NACE RP0502-2002, Section 6.5]

D.05.d. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.05.d. Inspection Issues Summary Leave blank if no issue was identified.

D.05 Documents Reviewed (Tab from bottom-right cell to add additional rows.)
Document Number	Rev	Date	Document Title

D.05 Inspection Notes

D.06 Dry Gas ICDA Programmatic Requirements

If the operator elects to use ICDA, verify that the operator develops and implements an ICDA plan in accordance with §192.927.

D.06.a. Verify that the operator developed a documented ICDA plan [§192.927(c)]

D.06.a. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.06.a. Inspection Issues Summary Leave blank if no issue was identified.

D.06.b. Verify that the operator's plan contains provisions for carrying out ICDA on the entire pipeline in which covered segments are present, except that application of the remediation criteria of §192.933 may be limited to covered segments. [§192.927(c)(5)(iii)]

D.06.b. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.06.b. Inspection Issues Summary Leave blank if no issue was identified.

D.06.c. Verify that the operator implements the ICDA plan. [§192.927(c)]

D.06.c. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.06.c. Inspection Issues Summary Leave blank if no issue was identified.

D.06 Documents Reviewed (Tab from bottom-right cell to add additional rows.)
Document Number	Rev	Date	Document Title

D.06 Inspection Notes

D.07 Dry Gas ICDA Pre-Assessment, Region Identification and Use of Model

For dry gas systems, verify that the operator gathers, integrates and analyzes data and information to accomplish pre-assessment objectives and identify ICDA Regions. [§192.927(c)(1), §192.927(c)(2), ASME B31.8S-2004, Section 6.4.2, ASME B31.8S-2004, Appendix A2 and ASME B31.8S-2004, Appendix B2]

D.07.a. Verify that the operator's plan defines criteria to be applied in making key decisions (e.g., region identification, feasibility determinations) in implementing the pre-assessment stage of the ICDA process. [§192.927(c)(5)(i)]

D.07.a. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.07.a. Inspection Issues Summary Leave blank if no issue was identified.

D.07.b. Verify that the operator collects, as a minimum, the following data and information:

All data elements listed in ASME B31.8S-2004, Appendix A2 [§192.927(c)(1)(i)]
Information needed to support use of a model to identify areas where internal corrosion is most likely, including locations of all 1) gas input and withdrawal points, 2) low points such as sags, drips, inclines, valves, manifolds, dead-legs, and traps, 3) elevation profile in sufficient detail for angles of inclination to be calculated, and 4) the range of expected gas velocities within the pipeline; [§192.927(c)(1)(ii)]
Operating experience data that would indicate historic upsets in gas conditions, locations where these upsets have occurred, and potential damage resulting from these upset conditions [§192.927(c)(1)(iii)]
Information where cleaning pigs may not have been used or where cleaning pigs may deposit electrolytes. [§192.927(c)(1)(iv)]

D.07.b. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.07.b. Inspection Issues Summary Leave blank if no issue was identified.

D.07.c. Verify that the operator integrates the data collected and uses the integrated data analysis to evaluate and document the following:

Feasibility of performing ICDA on its pipe segments [§192.927(c)(1)]
Identification of all ICDA Regions and the location of each region. [§192.927(c)(1) & (2)]
Support use of a model to identify the locations along the pipe segment where electrolyte may accumulate [§192.927(c)(1)]
Identify areas within the covered segment where liquids may be potentially entrained. [§192.927(c)(1)]

D.07.c. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.07.c. Inspection Issues Summary Leave blank if no issue was identified.

D.07.d. Verify the operator's plan uses the model in GRI 02-0057 ICDA of Gas Transmission Pipelines- Methodology (or equivalent acceptable model) to define critical pipe angle of inclination above which water film cannot be transported by the gas, and that the model considers, as a minimum: [§192.927(c)(2)]

Changes in pipe diameter, [§192.927(c)(2)]
Locations where gas enters a line, [§192.927(c)(2)]
Locations down stream of gas draw-offs. [§192.927(c)(2)]
Other conditions that may result in changes in gas velocity. [§192.927(c)(2) and GRI 02-0057]

D.07.d. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.07.d. Inspection Issues Summary Leave blank if no issue was identified.

D.07.e. Verify that the operator's plan contains provisions for applying more restrictive criteria for pre-assessment and region identification when conducting ICDA for the first time on a covered segment. [§192.927(c)(5)(ii)]

D.07.e. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.07.e. Inspection Issues Summary Leave blank if no issue was identified.

D.07 Documents Reviewed (Tab from bottom-right cell to add additional rows.)
Document Number	Rev	Date	Document Title

D.07 Inspection Notes

D.08 Dry Gas ICDA Direct Examination

For dry gas systems, verify that the operator (1) identifies locations where internal corrosion is most likely in each ICDA region and (2) performs direct examinations of those locations. [§192.927(b), 192.927(c)(3), ASME B31.8S-2004, Section 6.4 and ASME B31.8S-2004, Appendix B2]

D.08.a. Verify that the operator's plan defines criteria to be applied in making key decisions (e.g., identifying locations most likely to have internal corrosion, selection of examination tools) in implementing the direct examination stage of the ICDA process. [§192.927(c)(5)(i)]

D.08.a. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.08.a. Inspection Issues Summary Leave blank if no issue was identified.

D.08.b. Verify the operator has identified locations where internal corrosion is most likely to exist in each ICDA region and where electrolyte accumulation is predicted. [§192.927(c)(3), ASME B31.8S-2004, Section 6.4.2 and ASME B31.8S-2004, Appendix B2.3]

D.08.b. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.08.b. Inspection Issues Summary Leave blank if no issue was identified.

D.08.c. Verify the operator requires a direct examination for internal corrosion using ultrasonic thickness measurements, radiography, or other generally accepted measurement technique of those covered segment locations where internal corrosion is most likely to exist, and includes as a minimum, the following: [§192.927(c)(3), ASME B31.8S-2004, Section 6.4.2, ASME B31.8S-2004, Appendix B2.3 and ASME B31.8S-2004, Appendix B2.4]

A minimum of two (2) locations within each ICDA region within a covered segment,
At least one location must be the low point (e.g., sags, drips, valves, manifolds, deadlegs, traps) nearest the beginning of the ICDA region and
The second location must be further downstream within a covered segment near the end of the ICDA Region (The end of the ICDA region is the farthest downstream location where the ICDA model predicts electrolytes could accumulate based on the critical angle of inclination above which water film cannot be transported by the gas). [§192.927(c)(2) and ASME B31.8S-2004, Appendix B2.3]

D.08.c. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.08.c. Inspection Issues Summary Leave blank if no issue was identified.

D.08.d. If internal corrosion exists at any location directly examined, verify that the operator: [192.927(c)(3)]

Evaluates the severity of the defect and remediates the defect per §192.933 (see Protocol E) [§192.927(c)(3)(i)], and
Either performs additional excavations or performs additional assessment using an allowed alternative assessment method [§192.927(c)(3)(ii)], and
Evaluates the potential for internal corrosion in all pipeline segments (both covered and non-covered) in the operator's pipeline system with similar characteristics to the ICDA region containing the covered segment in which the corrosion was found and remediates the conditions per §192.933. [§192.927(c)(3)(iii)]

D.08.d. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.08.d. Inspection Issues Summary Leave blank if no issue was identified.

D.08.e. Verify that the operator's plan contains provisions for applying more restrictive criteria for the direct examination when conducting ICDA for the first time on a covered segment [§192.927(c)(5)(ii)]

D.08.e. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.08.e. Inspection Issues Summary Leave blank if no issue was identified.

D.08 Documents Reviewed (Tab from bottom-right cell to add additional rows.)
Document Number	Rev	Date	Document Title

D.08 Inspection Notes

D.09 Dry Gas ICDA Post-Assessment

For dry gas systems, verify that the operator performs post-assessment evaluation of ICDA effectiveness and continued monitoring of covered segments where internal corrosion has been identified. [§192.927(c)(4)]

D.09.a. Verify that the operator's plan defines criteria to be applied in making key decisions (e.g., reassessment interval determination, techniques for monitoring internal corrosion) in implementing the post-assessment evaluation stage of the ICDA process. [§192.927(c)(5)(i)]

D.09.a. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.09.a. Inspection Issues Summary Leave blank if no issue was identified.

D.09.b. Verify the operator has a process for evaluating the effectiveness of ICDA as an assessment method and determining reassessment intervals. [§192.927(c)(4)(i) and ASME B31.8S-2004, Appendix B2.4]

Verify that if corrosion is found in areas where the pipeline inclination is greater than the estimated critical inclination, that the operator re-evaluates the critical inclination angle and additional new areas are selected for direct examination. [ASME B31.8S-2004, Appendix B2.4]
Verify the operator's process determines whether a segment must be reassessed at intervals more frequently than those specified in §192.939 using the largest defect most likely to remain in the covered segment as the largest defect discovered in the ICDA segment and estimating the reassessment interval as half the time required for the largest defect to grow to critical size. Verify that this evaluation is to be carried out within one year of completion of the assessment. [§192.927(c)(4)(i) and §192.939(a)(3)]
Verify the operator's reassessment intervals comply with the following maximum allowed intervals in accordance with 192.939 (see Protocol F). [§192.939(b)]

10 years for segments operating at SMYS levels greater than 50%
15 years for segments operating between 30 and 50% SMYS
20 years for segments operating below 30% SMYS

D.09.b. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.09.b. Inspection Issues Summary Leave blank if no issue was identified.

D.09.c. Verify the operator continually monitors each covered segment where internal corrosion has been identified using techniques such as coupons, UT sensors or electronic probes, periodically drawing off liquids at low points and chemically analyzing them for corrosion products. [§192.927(c)(4)(ii)]

Verify the operator has a process to determine the frequency for monitoring and liquid analysis based on all integrity assessments results conducted in accordance with 192 Subpart O and risk factors specific to the covered segment. [§192.927(c)(4)(ii) and ASME B31.8S-2004, Appendix A2.2]
Verify the operator's process requires that if any evidence of corrosion products is found in the covered segment, prompt action must be taken including, as a minimum: [§192.927(c)(4)(ii)]

Remediate the conditions the operator finds in accordance with §192.933, and
Implement one of the two following required actions: (1) Conduct excavations of covered segments at locations downstream from where the electrolyte might have entered the pipe, or (2) assess the covered segment using another integrity assessment method allowed by Subpart O.

D.09.c. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.09.c. Inspection Issues Summary Leave blank if no issue was identified.

D.09.d. Verify that the operator's plan contains provisions for applying more restrictive criteria for the post-assessment when conducting ICDA for the first time on a covered segment [§192.927(c)(5)(ii)]

D.09.d. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.09.d. Inspection Issues Summary Leave blank if no issue was identified.

D.09 Documents Reviewed (Tab from bottom-right cell to add additional rows.)
Document Number	Rev	Date	Document Title

D.09 Inspection Notes

D.10 Wet Gas ICDA Programmatic Requirements

If the operator elects to use ICDA to assess a covered segment operating with electrolyte present in the gas stream (wet gas), verify that the operator develops and implements an ICDA plan in accordance with §192.927 which addresses the following. [§192.927(b)]

D.10.a. Verify that the operator developed a documented ICDA plan which demonstrates how the operator will conduct ICDA on the entire pipeline in which covered segments are present to effectively address internal corrosion. [§192.927(c)]

D.10.a. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.10.a. Inspection Issues Summary Leave blank if no issue was identified.

D.10.b. Verify the operator has provided notification to PHMSA, and applicable state or local safety authorities, of an ICDA wet gas "other technology" application in accordance with ï¿½192.921 (a) (4) or ï¿½192.937 (c) (4). [ï¿½192.927(b)]

D.10.b. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.10.b. Inspection Issues Summary Leave blank if no issue was identified.

D.10 Documents Reviewed (Tab from bottom-right cell to add additional rows.)
Document Number	Rev	Date	Document Title

D.10 Inspection Notes

D.11 SCCDA Data Gathering and Evaluation

If the operator elects to use SCCDA, verify that the operator's SCCDA evaluation process complies with ASME B31.8S-2004, Appendix A3 in order to identify whether conditions for SCC of gas line pipe are present and to prioritize the covered segments for assessment. [§192.929(b)(1)]

D.11.a. Verify that the operator has a process to gather, integrate, and evaluate data for all covered segments to identify whether the conditions for SCC are present and to prioritize the covered segments for assessment. [§192.929(b)(1)]

Verify that the operator's process gathers and evaluates data related to SCC at all sites it excavates during the conduct of its pipeline operations (not just covered segments) where the criteria indicate the potential for SCC. [§192.929(b)(1) and ASME B31.8S-2004, Appendix A3.3]
Verify that the data includes, as a minimum, the data specified in ASME B31.8S-2004, Appendix A3.
Verify that the operator addresses missing data by either using conservative assumptions or assigning a higher priority to the segments affected by the missing data, as required by ASME B31.8S-2004, Appendix A3.2.

D.11.a. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.11.a. Inspection Issues Summary Leave blank if no issue was identified.

D.11 Documents Reviewed (Tab from bottom-right cell to add additional rows.)
Document Number	Rev	Date	Document Title

D.11 Inspection Notes

D.12 SCCDA Assessment, Examination and Threat Remediation

Verify that covered segments (for which conditions for SCC are identified) are assessed, examined, and the threat remediated. [§192.929(b)(2)]

D.12.a. Verify that, if conditions for SCC are present, that the operator conducts an assessment using one of the methods specified in ASME B31.8S-2004, Appendix A3.

D.12.a. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.12.a. Inspection Issues Summary Leave blank if no issue was identified.

D.12.b. Verify that the operator's plan specifies an acceptable inspection, examination, and evaluation plan using either the Bell Hole Examination and Evaluation Method (that complies with all requirements of ASME B31.8S-2004, Appendix A3.4 (a)) or Hydrostatic Testing (that complies with all requirements of ASME B31.8S-2004, Appendix A3.4 (b)).

Verify, that the operator's plan requires that for pipelines which have experienced an in-service leak or rupture attributable to SCC, that the particular segment(s) be subjected to a hydrostatic pressure test (that complies with ASME B31.8S-2004, Appendix A3.4 (b)) within 12 months of the failure, using a documented hydrostatic retest program developed specifically for the affected segment(s), as required by ASME B31.8S-2004, Appendix A3.4.

D.12.b. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.12.b. Inspection Issues Summary Leave blank if no issue was identified.

D.12.c. Verify that assessment results are used to determine reassessment intervals in accordance with §192.939(a)(3); (see Protocol F). [§192.939(a)(3)]

D.12.c. Inspection Results Type an "X" in the applicable box below. Select only one.
	No Issues Identified
	Potential Issues Identified (explain in summary)
	Not Applicable (explain in summary)

D.12.c. Inspection Issues Summary Leave blank if no issue was identified.

D.12 Documents Reviewed (Tab from bottom-right cell to add additional rows.)
Document Number	Rev	Date	Document Title

D.12 Inspection Notes

Protocol: A B C D E F G H I J K L M N O P

Protocol Areas

Protocol D
as Offline Form

Protocol D
as Offline Document

Protocol D Outline

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