PHMSA Gas Integrity Management
Time: 11/23/2009 09:46 PM

Frequently-Asked Question FAQ #196

FAQ-196: Time limit from indirect to direct - ECDA

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Question: Is there any time limit between step 2 and step 3 in the ECDA process (indirect exam and direct exam)?

Answer: The provisions of NACE RP0502-2002, which is incorporated into the rule by reference, govern the use of ECDA. The recommended practice does not specify any time limit between step 2, Indirect Inspection, and step 3, Direct Examination. OPS expects that operators would perform direct examinations shortly after completing the indirect inspection step, particularly if any severe indications are identified. Operators must be prepared to justify that any delay between these two steps does not affect the continued validity of the indirect inspection results or represent an imminent threat to pipeline integrity. Also, refer to FAQ-232.

These Frequently Asked Questions (FAQs) are intended to clarify, explain, and promote better understanding of the pipeline integrity management rules. These FAQs are not substantive rules and do not create rights, assign duties, or impose new obligations not outlined in the existing integrity management regulations and standards. Requests for informal interpretations regarding the applicability of one or more of the pipeline integrity management rules to a specific situation may be submitted to PHMSA in accordance with 49 C.F.R. § 190.11.
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