Question: Must an operator always perform a 100% direct examination inspection of the carrier pipe within the casing under Step 3, Direct Examination, when doing an ECDA assessment?
Answer: Yes. In the ECDA assessment process in Step 3, Direct Examination, in accordance with NACE RP0502-2002, Section 5, and 49 CFR Section 192.925, pipeline operators must do a full, 100% direct examination of the carrier pipe within the casing to ensure that no indications have been missed by any of the indirect inspection tools. Many of these indirect inspection tools cannot see' inside the casings but do infer by their readings that an indication may be located somewhere inside the casing. Because many of the indirect inspection tools can not accurately locate nor categorize the specific indication, a 100% direct examination of the carrier pipe is necessary.