What Are the Requirements for Using External Corrosion Direct Assessment (ECDA)? [49 CFR 192.925]

Current as of source date Government source

Louisiana Office of ConservationOfficial agency material

(A)A. Definition. ECDA is a four-step process that combines preassessment, indirect inspection, direct examination, and post assessment to evaluate the threat of external corrosion to the integrity of a pipeline. [49 CFR 192.925(a)]#

(B)B. General Requirements. An operator that uses direct assessment to assess the threat of external corrosion must follow the requirements in this Section, in ASME B31.8S (incorporated by reference, see §507), section 6.4, and in NACE SP0502 (incorporated by reference, see §507). An operator must develop and implement a direct assessment plan that has procedures addressing pre-assessment, indirect examination, direct examination, and post-assessment. If the ECDA detects pipeline coating damage, the operator must also integrate the data from the ECDA with other information from the data integration (§3317.B) to evaluate the covered segment for the threat of third party damage, and to address the threat as required by §3317.E.1 [49 CFR 192.925(b)] .#

(1)1. Pre-assessment. In addition to the requirements in ASME B31.8S section 6.4 and NACE SP0502, section 3, the plan's procedures for pre-assessment must include: [49 CFR 192.925(b)(1)]#

(a)a. provisions for applying more restrictive criteria when conducting ECDA for the first time on a covered segment; and [49 CFR 192.925(b)(1)(i)]#

(b)b. the basis on which an operator selects at least two different, but complementary indirect assessment tools to assess each ECDA Region. If an operator utilizes an indirect inspection method that is not discussed in appendix A of NACE SP0502, the operator must demonstrate the applicability, validation basis, equipment used, application procedure, and utilization of data for the inspection method. [49 CFR 192.925(b)(1)(ii)]#

(2)2. Indirect Inspection. In addition to the requirements in ASME B31.8S section 6.4 and NACE SP0502, section 4, the plan's procedures for indirect inspection of the ECDA regions must include: [49 CFR 192.925(b)(2)]#

(a)a. provisions for applying more restrictive criteria when conducting ECDA for the first time on a covered segment; [49 CFR 192.925(b)(2)(i)]#

(b)b. criteria for identifying and documenting those indications that must be considered for excavation and direct examination. Minimum identification criteria include the known sensitivities of assessment tools, the procedures for using each tool, and the approach to be used for decreasing the physical spacing of indirect assessment tool readings when the presence of a defect is suspected; [49 CFR 192.925(b)(2)(ii)]#

(c)c. criteria for defining the urgency of excavation and direct examination of each indication identified during the indirect examination. These criteria must specify how an operator will define the urgency of excavating the indication as immediate, scheduled or monitored; and [49 CFR 192.925(b)(2)(iii)]#

(d)d. criteria for scheduling excavation of indications for each urgency level. [49 CFR 192.925(b)(2)(iv)]#

(3)3. Direct Examination. In addition to the requirements in ASME B31.8S section 6.4 and NACE SP0502, section 5, the plan's procedures for direct examination of indications from the indirect examination must include: [49 CFR 192.925(b)(3)]#

(a)a. provisions for applying more restrictive criteria when conducting ECDA for the first time on a covered segment; [49 CFR 192.925(b)(3)(i)]#

(b)b. criteria for deciding what action should be taken if either: [49 CFR 192.925(b)(3)(ii)]#

(i)i. corrosion defects are discovered that exceed allowable limits (section 5.5.2.2 of NACE SP0502; or [49 CFR 192.925(b)(3)(ii)(A)]#

(ii)ii. root cause analysis reveals conditions for which ECDA is not suitable (section 5.6.2 of NACE SP0502; [49 CFR 192.925(b)(3)(ii)(B)]#

(c)c. criteria and notification procedures for any changes in the ECDA plan, including changes that affect the severity classification, the priority of direct examination, and the time frame for direct examination of indications; and [49 CFR 192.925(b)(3)(iii)]#

(d)d. criteria that describe how and on what basis an operator will reclassify and reprioritize any of the provisions that are specified in section 5.9 of NACE SP0502. [49 CFR 192.925(b)(3)(iv)]#

(4)4. Post Assessment and Continuing Evaluation. In addition to the requirements in ASME/ANSI B31.8S section 6.4 and NACE SP0502, section 6, the plan's procedures for post assessment of the effectiveness of the ECDA process must include: [49 CFR 192.925(b)(4)]#

(a)a. measures for evaluating the long-term effectiveness of ECDA in addressing external corrosion in covered segments; and [49 CFR 192.925(b)(4)(i)]#

(b)b. criteria for evaluating whether conditions discovered by direct examination of indications in each ECDA region indicate a need for reassessment of the covered segment at an interval less than that specified in §3339 (see appendix D of NACE SP0502. [49 CFR 192.925(b)(4)(ii)]#

AUTHORITY NOTE: Promulgated in accordance with R.S. 30:501 et seq.#

HISTORICAL NOTE: Promulgated by the Department of Natural Resources, Office of Conservation, Pipeline Division, LR 30:1278 (June 2004), amended LR 31:687 (March 2005), LR 33:484 (March 2007), amended by the Department of Natural Resources, Office of Conservation, LR 38:121 (January 2012), LR 44:1043 (June 2018), amended by the Department of Conservation and Energy, Office of Enforcement, LR 51:1837 (November 2025).#