Question: Currently, no standard exists for ICDA. How can we include ICDA in our plan when there is no accepted standard?
Answer: NACE is developing a standard for internal corrosion direct assessment (ICDA). OPS will consider incorporating that standard into the rule once it is approved. In the meantime, the rule, itself, includes requirements for ICDA that are consistent with drafts of the standard under development. Operators must follow the requirements in the rule and in ASME/ANSI B31.8S, Section 6.4 and Appendix B2 (referenced in the rule). Operators also must use the model in GRI 02-0057, "Internal Corrosion Direct Assessment of Gas Transmission Pipelines – Methodology" to identify ICDA regions (see 192.927(c)(2)). Operators must develop their own procedures based on the requirements in the rule and the referenced standard, and can also use the draft NACE standard as guidance.