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.[See Details...]
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)][See Details...]
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)][See Details...]
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)][See Details...]
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][See Details...]
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.[See Details...]
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][See Details...]
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][See Details...]
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)][See Details...]
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)][See Details...]
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)][See Details...]
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)][See Details...]
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.