Frequently-Asked Question FAQ #56

FAQ-56: Anomaly Repairs Requirements for Previous Inspection Results

Question: Do the anomaly repair schedule requirements in 192.933(d) apply to all previous internal inspection runs performed by the operator, or just the integrity assessments required by Subpart O (i.e., the baseline assessment and subsequent integrity assessments)?

Answer: The anomaly repair schedule requirements in 192.933(d) apply to baseline assessments and subsequent re-assessments required by the new integrity management rule. Prior internal inspection tool runs do not need to comply with the 192.933(d) criteria unless the pipeline segment inspection is declared to be a baseline assessment as described in 192.921(e). (All defects identified in the most recent prior assessment relied upon as a basis for a performance-based program under 192.913 must be repaired per 192.933).

In addition, operators are expected to review the results of their prior integrity assessments to prioritize pipeline segments for the Baseline Assessment Plan and to perform the information and risk analysis required in 192.917. In performing these reviews, operators should confirm that anomalies or defects identified in these earlier runs that might compromise integrity have been mitigated. (All defects in the most recent prior assessment relied upon as the basis for a performance-based approach under 192.913 must be repaired per 192.933).

Any assessments conducted after February 14, 2004 (the effective date of the rule), are considered assessments covered by Subpart O, and the schedule criteria of 192.933(d) apply.