{"operation":"document","citation":"PHMSA GT.2023.01","title":"2023 Gas Transmission IA Question Set","source_type":"inspection","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2022-12-28","effective_on":"2022-12-28","summary":"PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 Assessment and Repair - Repair Criteria (O&M) 1. Repair Criteria in Non-Covered Segments Does the integrity assessment and maintenance processes include","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-2023-gas-transmission-ia-question-set.json","markdown":"https://regulus.evalyn.ai/document/phmsa-2023-gas-transmission-ia-question-set.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-2023-gas-transmission-ia-question-set","source_url":"https://primis.phmsa.dot.gov/IA-Releases/ia-release-notes/notes/iac-fed.2023.01","body":"<<<PAGE 1>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\nAssessment and Repair - Repair Criteria (O&M)\n1. Repair Criteria in Non-Covered Segments Does the integrity assessment and maintenance processes include\nadequate criteria for determining the need for, and timeliness of, pipeline defect repairs in non-covered segments?\n(AR.RCOM.NONCOVERED.P) 192.485(a) (192.485(b);192.485(c);192.703(b);192.710;192.711;192.713)\n2. Repair Criteria in Non-Covered Segments From the review of the results of integrity assessments, did the\noperator repair conditions that posed a threat to pipeline integrity on Non-Covered segments? (AR.RCOM.NONCOVERED.R)\n192.485(a) (192.485(b);192.485(c);191.23(a)(1);192.703(b);192.710;192.711;192.713)\n3. Field Inspection - Remedial Actions (OM) Is anomaly remediation and documentation of remediation adequate\nfor all segments? (AR.RCOM.REMEDIATIONOM.O) 192.485(a) (192.485(b);192.485(c);192.710;192.711;192.713)\n4. Alternative Maximum Allowable Operating Pressure per 192.620 (80% SMYS Rule)? If the\npipeline operates using an alternative maximum allowable operating pressure per 192.620 (80% SMYS Rule), do the processes\nmeet the requirements of the permit or 192.620? (AR.RCOM.RCAMAOP.P) 192.620(d)\n5. Alternative Maximum Allowable Operating Pressure per 192.620 (80% SMYS Rule)? If the\npipeline operates using an alternative maximum allowable operating pressure per 192.620 (80% SMYS Rule), from a review of\nselected records, were required repairs performed? (AR.RCOM.RCAMAOP.R) 192.620(d)\nAssessment and Repair - Confirmatory Direct Assessment\n1. Qualification of Operator/Vendor Personnel Who Evaluate CDA Results Does the process require\nthat operator/vendor personnel (including supervisors) who review and evaluate CDA assessment results meet appropriate\ntraining, experience, and qualification criteria? (AR.CDA.CDAREVQUAL.P) 192.915(a) (192.915(b))\n2. Qualification of Operator/Vendor Personnel Who Evaluate CDA Results Do records demonstrate\nthat operator/vendor personnel, including supervisors, who conduct assessments or review assessment results, are qualified for\nthe tasks they perform? (AR.CDA.CDAREVQUAL.R) 192.947(h) (192.915(a);192.915(b))\nGT.2023.01 Page 1 of 246\n\n<<<PAGE 2>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\n3. Qualification of Operator/Vendor Personnel Who Evaluate CDA Results From the observation of\nselected integrity assessments, are operator and vendor personnel, including supervisors, who conduct assessments or review\nassessment results, qualified for the tasks they perform? (AR.CDA.CDAREVQUAL.O) 192.915(a) (192.915(b))\n4. CDA Plan Is an adequate Confirmatory Direct Assessment Plan in place? (AR.CDA.CDAPLAN.P) 192.931(a)\n(192.931(b);192.931(c);192.931(d))\n5. External Corrosion Plan Do records indicate that the external corrosion plan was properly implemented?\n(AR.CDA.CDAEXTCORR.R) 192.947(h) (192.931(b))\n6. Internal Corrosion Plan Do records demonstrate that the internal corrosion plan was properly implemented?\n(AR.CDA.CDAINTCORR.R) 192.947(h) (192.931(c))\n7. Remediation of Indications Do records demonstrate that the next assessment should have been accelerated?\n(AR.CDA.CDAINDICATION.R) 192.947(h) (192.931(d))\n8. CDA Does the process adequately account for taking required actions to address significant corrosion threats identified using\nconfirmatory direct assessment? (AR.CDA.CDACORR.P) 192.933 (192.917(e)(5))\n9. CDA Do records demonstrate that required actions are being taken to address significant corrosion threats identified by CDA\nas required? (AR.CDA.CDACORR.R) 192.933 (192.917(e)(5))\nAssessment and Repair - External Corrosion Direct Assessment\n(ECDA)\n1. Qualification of Operator/Vendor Personnel Who Evaluate ECDA Results Does the process require\nthat operator/vendor personnel (including supervisors) who review and evaluate ECDA assessment results meet appropriate\ntraining, experience, and qualification criteria? (AR.EC.ECDAREVQUAL.P) 192.915(a) (192.915(b))\nGT.2023.01 Page 2 of 246\n\n<<<PAGE 3>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\n2. ECDA Pre-Assessment Do records demonstrate that the ECDA pre-assessment process complied with NACE SP0502-\n2010 Section 3 and 192.925(b)(1)? (AR.EC.ECDAPREASSESS.R) 192.947(g) (192.925(b)(1))\n3. Qualification of Operator/Vendor Personnel Who Evaluate ECDA Results Do records demonstrate\nthat operator/vendor personnel, including supervisors, who conduct ECDA assessments or review and analyze assessment results\nare qualified for the tasks they perform? (AR.EC.ECDAREVQUAL.R) 192.947(g) (192.915(a);192.915(b))\n4. Qualification of Operator/Vendor Personnel Who Evaluate ECDA Results From the observation of\nselected integrity assessments, are operator and vendor personnel, including supervisors, who conduct assessments or review\nassessment results, qualified for the tasks they perform? (AR.EC.ECDAREVQUAL.O) 192.915(a) (192.915(b))\n5. ECDA Plan Is an adequate ECDA plan and process in place for conducting ECDA? (AR.EC.ECDAPLAN.P) 192.925(a)\n(192.925(b))\n6. Integration of ECDA Results with other Information Is the process for integrating ECDA results with other\ninformation adequate? (AR.EC.ECDAINTEGRATION.P) 192.917(b) (ASME B31.8S-2004 Section 4.5)\n7. Integration of ECDA Results with other Information Do records demonstrate that the operator integrated\nother data/information when evaluating data/results? (AR.EC.ECDAINTEGRATION.R) 192.947(g) (192.917(b))\n8. ECDA Region Identification Do records demonstrate that the operator identified ECDA Regions?\n(AR.EC.ECDAREGION.R) 192.947(g) (192.925(b)(1))\n9. ECDA Indirect Examination Do records demonstrate that ECDA indirect inspection process complied with NACE SP\n0502-2010 Section 4 and ASME B31.8S-2004, Section 6.4? (AR.EC.ECDAINDIRECT.R) 192.947(g) (192.925(b)(2))\n10. ECDA Direct Examination Do records demonstrate that excavations, direct examinations, and data collection were\nperformed in accordance with NACE SP 0502-2010, Sections 5 and 6.4.2 and ASME B31.8S-2004, Section 6.4?\n(AR.EC.ECDADIRECT.R) 192.947(g) (192.925(b)(3))\nGT.2023.01 Page 3 of 246\n\n<<<PAGE 4>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\n11. ECDA Direct Examination Were ECDA direct examinations adequately conducted? (AR.EC.ECDADIRECT.O)\n192.925(b)(3)\n12. Quality of ECDA Data Analysis Do records demonstrate that an analysis of the ECDA data and other information\nwas adequate to identify areas where external corrosion activity is most likely? (AR.EC.ECDAANALYSIS.R) 192.947(g)\n(192.925(b)(4);192.933(b))\n13. ECDA Change Control Have criteria and internal notification processes been established and implemented for any\nchanges in the ECDA plan? (AR.EC.ECDAPLANMOC.P) 192.947(g) (192.925(b)(3)(iii);192.911(k))\n14. ECDA Change Control Do records demonstrate that changes in the ECDA plan have been implemented and\ndocumented? (AR.EC.ECDAPLANMOC.R) 192.947(g) (192.925(b)(3)(iii))\n15. ECDA Post-Assessment Do records demonstrate that the requirements for post-assessment were met?\n(AR.EC.ECDAPOSTASSESS.R) 192.947(g) (192.925(b)(4))\n16. AMAOP ECDA If ECDA was performed on segments (as allowed by §192.620(d)(9)(iii)), were all ECDA assessment\nrequirements completed? (AR.EC.ECDAMAOP.R) 192.947(g) (192.620(d)(9)(iii);192.620(d)(10)(i);192.620(d)(10)(iii);)\n17. AMAOP ECDA If ECDA was performed on segments (as allowed by §192.620(d)(9)(iii)), were all ECDA assessment\nrequirements completed? (AR.EC.ECDAMAOP.O) 192.620(d)(9)(iii) (192.620(d)(10)(i);192.620(d)(10)(iii))\n18. External Corrosion Does the process adequately account for taking required actions to address significant external\ncorrosion threats? (AR.EC.ECCORR.P) 192.933 (192.917(e)(5))\n19. External Corrosion Do records demonstrate that required actions are being taken to address significant external\ncorrosion threats as required? (AR.EC.ECCORR.R) 192.933 (192.917(e)(5))\nGT.2023.01 Page 4 of 246\n\n<<<PAGE 5>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\nAssessment and Repair - Internal Corrosion Direct Assessment\n(ICDA)\n1. Qualification of Operator/Vendor Personnel Who Evaluate ICDA Results Does the process require\nthat operator/vendor personnel (including supervisors) who review and evaluate ICDA assessment results meet appropriate\ntraining, experience, and qualification criteria? (AR.IC.ICDAREVQUAL.P) 192.915(a) (192.915(b))\n2. Qualification of Operator/Vendor Personnel Who Evaluate ICDA Results Do records demonstrate\nthat operator/vendor personnel, including supervisors, who conduct ICDA assessments or review and analyze assessment results,\nare qualified for the tasks they perform? (AR.IC.ICDAREVQUAL.R) 192.947(g) (192.915(a);192.915(b))\n3. Qualification of Operator/Vendor Personnel Who Evaluate ICDA Results From the observation of\nselected integrity assessments, are operator and vendor personnel, including supervisors, who conduct assessments or review\nassessment results, qualified for the tasks they perform? (AR.IC.ICDAREVQUAL.O) 192.915(a) (192.915(b))\n4. ICDA Plan Is an ICDA plan and process in place for conducting ICDA? (AR.IC.ICDAPLAN.P) 192.927(c)\n(192.927(a);192.927(b))\n5. Pre-Assessment Do records demonstrate that the requirements for an ICDA pre-assessment were met?\n(AR.IC.ICDAPREASSESS.R) 192.927(c)(1) (192.947(g))\n6. Integration of ICDA Results with other Information Is the process for integrating ICDA results with other\ninformation adequate? (AR.IC.ICDAINTEGRATION.P) 192.917(b)\n7. Integration of ICDA Results with Other Information Do records demonstrate that other data/information\nwas integrated when evaluating data/results? (AR.IC.ICDAINTEGRATION.R) 192.917(b) (192.947(g))\n8. ICDA Region Identification Do records demonstrate that ICDA Regions were adequately identified?\n(AR.IC.ICDAREGION.R) 192.947(g) (192.927(c)(2);192.927(c)(5))\n9. Identification of Locations for Excavation and Direct Examination Do records demonstrate that sites\nwere identified where internal corrosion may be present? (AR.IC.ICDADIRECT.R) 192.947(g) (192.927(c)(3);192.927(c)(5))\nGT.2023.01 Page 5 of 246\n\n<<<PAGE 6>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\n10. Post-Assessment Evaluation and Monitoring Do records demonstrate that the operator assessed the\neffectiveness of the ICDA process? (AR.IC.ICDAPOSTASSESS.R) 192.947(g) (192.927(c)(4)(i);192.927(c)(4)(ii);192.477)\n11. Quality of ICDA Data Analysis Do records demonstrate that sufficient data was used to complete the ICDA\nanalysis to identify the internal corrosion threats to the pipeline? (AR.IC.ICDAANALYSIS.R) 192.947(g) (192.927(c);192.933(b))\n12. AMAOP ICDA If the pipeline is operated using an alternative maximum allowable operating pressure per 192.620 (80%\nSMYS Rule) were required ICDA assessments performed? (AR.IC.ICDAMAOP.R) 192.947(g)\n(192.620(d)(9);192.620(d)(10);192.927)\n13. P&M Measures (Internal Corrosion) Does the process adequately account for taking required actions to address\nsignificant internal corrosion threats related to internal corrosion? (AR.IC.ICCORR.P) 192.933 (192.917(e)(5))\n14. P&M Measures (Internal Corrosion) Do records demonstrate that required actions are being taken to address\nsignificant internal corrosion threats as required? (AR.IC.ICCORR.R) 192.933 (192.917(e)(5))\nAssessment and Repair - Stress Corrosion Cracking Direct\nAssessment (SCCDA)\n1. Qualification of Operator Personnel Who Evaluate SCCDA Results Does the process require that\noperator/vendor personnel (including supervisors) who review and evaluate SCCDA assessment results meet appropriate training,\nexperience, and qualification criteria? (AR.SCC.SCCDAREVQUAL.P) 192.915(a) (192.915(b))\n2. Qualification of Operator Personnel Who Evaluate SCCDA Results Do records demonstrate that\noperator/vendor personnel, including supervisors, who conduct assessments or review assessment results, are qualified for the\ntasks they perform? (AR.SCC.SCCDAREVQUAL.R) 192.947(e) (192.915(a);192.915(b))\n3. Qualification of Operator Personnel Who Evaluate SCCDA Results From the observation of selected\nintegrity assessments, are operator and vendor personnel, including supervisors, who conduct assessments or review assessment\nresults, qualified for the tasks they perform? (AR.SCC.SCCDAREVQUAL.O) 192.915(a) (192.915(b))\nGT.2023.01 Page 6 of 246\n\n<<<PAGE 7>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\n4. SCCDA Plan Is an adequate plan developed for performing SCCDA, if the conditions for SCC were present?\n(AR.SCC.SCCDAPLAN.P) 192.929(b)\n5. Collect and Evaluate Data Do records demonstrate that data was collected and evaluated? (AR.SCC.SCCDADATA.R)\n192.947(g) (192.929(b)(1))\n6. Assessment Method (High pH SCC) Do records demonstrate that an assessment was performed using one of the\nmethods specified in ASME B31.8S-2004 Appendix A3? (AR.SCC.SCCDAMETHOD.R) 192.947(g) (192.929(b)(2))\n7. Assessment Method (High pH SCC) From field observations, was SCCDA performed in accordance with 192.929\nand the SCCDA plan? (AR.SCC.SCCDAMETHOD.O) 192.929\n8. Assessing for Near Neutral SCC From the review of the results of selected integrity assessments, was the pipeline\nevaluated for near neutral SCC? (AR.SCC.SCCDANEARNEUTRAL.R) 192.947(g) (192.929(b)(2))\n9. Reassessment Interval From the review of the results of selected integrity assessments, did the operator determine a\nreassessment interval based on SCCDA results? (AR.SCC.SCCDAREASSESSINTRVL.R) 192.947(d) (192.939(a)(3))\n10. Alternative Maximum Allowable Operating Pressure per 192.620 (80% SMYS Rule)? If the\npipeline operates using an alternative maximum allowable operating pressure per 192.620 (80% SMYS Rule), from a review of\nselected records, were required SCCDA assessments performed? (AR.SCC.SCCDAAMAOP.R) 192.620(d)\n(192.620(d)(9);192.620(d)(10))\n11. SCC Does the process adequately account for taking required actions to address significant corrosion threats found following\nSCCDA? (AR.SCC.SCCCORR.P) 192.933 (192.917(e)(5))\n12. SCC Do records demonstrate that required actions are being taken to address significant corrosion threats as required\nfollowing SCCDA? (AR.SCC.SCCCORR.R) 192.933 (192.917(e)(5))\nGT.2023.01 Page 7 of 246\n\n<<<PAGE 8>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\nAssessment and Repair - In-Line Inspection (Smart Pigs)\n1. Qualification of Operator/Vendor Personnel (including Supervisors) Who Evaluate ILI\nResults Does the process require that operator/vendor personnel (including supervisors) who review and evaluate ILI\nassessment results meet appropriate training, experience, and qualification criteria? (AR.IL.ILIREVIEWQUAL.P) 192.915(a)\n(192.915(b);192.493)\n2. Qualification of Operator/Vendor Personnel (including Supervisors) Who Evaluate ILI\nResults Do records demonstrate that personnel who conduct assessments or review assessment results are qualified per the\nprocess requirements? (AR.IL.ILIREVIEWQUAL.R) 192.947(g) (192.915(a);192.915(b);192.493)\n3. Qualification of Operator/Vendor Personnel (including Supervisors) Who Evaluate ILI\nResults From the observation of selected integrity assessments, are operator and vendor personnel, including supervisors, who\nconduct assessments or review assessment results, qualified for the tasks they perform? (AR.IL.ILIREVIEWQUAL.O) 192.915(a)\n(192.915(b);192.493)\n4. ILI Specifications Does the process assure complete and adequate vendor ILI specifications? (AR.IL.ILISPECS.P)\n192.921(a)(1) (192.933(b);192.493;192.18)\n5. ILI Specifications Do records demonstrate that the ILI specifications were complete and adequate? (AR.IL.ILISPECS.R)\n192.947(g) (192.933(b);192.493)\n6. IMP Assessment Methods Does the process specify the assessment methods that are appropriate for the pipeline\nspecific integrity threats? (AR.IL.ASSESSMETHOD.P) 192.919(b) (192.921(a);192.937(c);192.917;192.493;192.506)\n7. IMP Assessment Methods Do records demonstrate that the assessment methods shown in the baseline and/or\ncontinual assessment plan were appropriate for the pipeline specific integrity threats? (AR.IL.ASSESSMETHOD.R) 192.947\n(192.919(b);192.921(a);192.937(c))\n8. Validation of ILI Results Does the process for validating ILI results ensure that accurate integrity assessment results\nare obtained? (AR.IL.ILIVALIDATE.P) 192.921(a)(1) (192.937(c);192.493)\nGT.2023.01 Page 8 of 246\n\n<<<PAGE 9>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\n9. Validation of ILI Results Do records demonstrate that the operator has validated ILI assessment results per their\nprocess? (AR.IL.ILIVALIDATE.R) 192.947 (192.921(a)(1);192.493)\n10. Validation of ILI Results From observation of field activities, do the employees and vendors validate ILI assessment\nresults per their process? (AR.IL.ILIVALIDATE.O) 192.921(a)(1) (192.493)\n11. Integration of ILI Results with other Information Is the process for integrating ILI results with other\ninformation adequate? (AR.IL.ILIINTEGRATION.P) 192.917(b) (192.493)\n12. Integration of ILI Results with other Information Do records demonstrate that the operator integrated\nother data/information when evaluating tool data/results? (AR.IL.ILIINTEGRATION.R) 192.947 (192.917(b);192.493)\n13. ILI Acceptance Criteria Is the process for ILI survey acceptance criteria adequate to assure an effective\nassessment? (AR.IL.ILIACCEPCRITERIA.P) 192.921(a) (192.493)\n14. ILI Acceptance Criteria Do records indicate adequate implementation of the process for ILI survey acceptance?\n(AR.IL.ILIACCEPCRITERIA.R) 192.947 (192.921(a);192.493)\n15. Integrity Assessments that were Not Performed as Scheduled or Within Required\nTimeframes Do records indicate that the performance of integrity assessments has been delayed and integrity assessment\ndelays have been justified? (AR.IL.ILIDELAY.R) 192.947(d) (192.909(a);192.909(b);192.943(a);192.943(b);190.341;192.18)\n16. Alternative Maximum Allowable Operating Pressure per 192.620 (80% SMYS Rule)? For\npipelines operating under AMAOP, do processes implement the ILI requirements of 192.620(d)(9) and (10) for the entire\nsegment? (AR.IL.ILIAMAOP.P) 192.620(d) (192.493)\n17. Alternative Maximum Allowable Operating Pressure per 192.620 (80% SMYS Rule)? For\npipelines operating under AMAOP, do records indicate the ILI requirements of 192.620(d)(9) and (10) have been implemented for\nthe entire segment? (AR.IL.ILIAMAOP.R) 192.620(d) (192.493)\nGT.2023.01 Page 9 of 246\n\n<<<PAGE 10>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\n18. Compliance with ILI Procedures Are O&M and IMP procedural requirements for the performance of ILI\nassessments followed? (AR.IL.ILIIMPLEMENT.O) 192.921(a)(1) (192.620(d);192.605(b);192.493)\n19. In-Line Inspection Does the process adequately account for taking required actions to address significant corrosion\nthreats identified during in-line inspections? (AR.IL.ILCORR.P) 192.933 (192.917(e)(5))\n20. In-Line Inspection Do records demonstrate that required actions are being taken to address significant corrosion\nthreats identified during in-line inspections? (AR.IL.ILCORR.R) 192.933 (192.917(e)(5))\nAssessment and Repair - Low Stress Reassessment\n1. Low Stress Reassessment Plan Is the process for performing low stress reassessment adequate?\n(AR.LSR.LSRPLAN.P) 192.941(a) (192.941(b);192.941(c))\n2. Baseline Assessment Do records demonstrate that a baseline assessment meeting the requirements of 192.919 and\n192.921 was performed prior to performing a low stress reassessment? (AR.LSR.LSRBA.R) 192.947(d)\n(192.919(c);192.921(d);192.941(a);192.506)\n3. External Corrosion Do records demonstrate that the requirements of §192.941(b) were implemented when performing\nlow stress reassessment for external corrosion? (AR.LSR.LSREXTCORR.R) 192.947(d) (192.941(b))\n4. Internal Corrosion Do records demonstrate that the requirements of §192.941(c) were implemented when performing\nlow stress reassessment for internal corrosion? (AR.LSR.LSRINTCORR.R) 192.947(d) (192.941(c))\n5. LSR - Corrosion Does the process adequately account for taking required actions to address significant corrosion threats\nfollowing a LSR? (AR.LSR.LSRCORR.P) 192.933 (192.917(e)(5))\n6. LSR - Corrosion Do records demonstrate that required actions are being taken to address significant corrosion threats as\nrequired following a LSR? (AR.LSR.LSRCORR.R) 192.933 (192.917(e)(5))\nGT.2023.01 Page 10 of 246\n\n<<<PAGE 11>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\nAssessment and Repair - Integrity Assessment Via Pressure Test\n1. Qualification of Operator/Vendor Personnel Who Evaluate Pressure Test Results Does the\nprocess require that operator/vendor personnel (including supervisors) who review and evaluate pressure test assessment results\nmeet appropriate training, experience, and qualification criteria? (AR.PTI.PRESSTESTREVQUAL.P) 192.915(a)\n(192.915(b);192.921(a)(4))\n2. Qualification of Operator/Vendor Personnel Who Evaluate Pressure Test Results Do records\ndemonstrate that operator/vendor personnel, including supervisors, who conduct or review pressure test assessment results are\nqualified for the tasks they perform? (AR.PTI.PRESSTESTREVQUAL.R) 192.947(g) (192.915(a);192.915(b))\n3. Test Acceptance Criteria and Procedures Were test acceptance criteria and processes sufficient to assure the basis for an\n(AR.PTI.PRESSTESTACCEP.P) 192.503(a)\n(192.503(b);192.503(c);192.503(d);192.505(a);192.505(b);192.505(c);192.505(d);192.507(a);192.507(b);192.507(c);192.513(a);192.51\n4. Pressure Test Results Do the test records validate the pressure test? (AR.PTI.PRESSTESTRESULT.R) 192.517(a)\n(192.505(a);192.505(b);192.505(c);192.505(d);192.507(a);192.507(b);192.507(c);192.513(a);192.513(b);192.513(c);192.513(d);192.51\n5. Alternative Maximum Allowable Operating Pressure per 192.620 (80% SMYS Rule)? If the\npipeline operates using an alternative maximum allowable operating pressure per 192.620 (80% SMYS Rule), from a review of\nselected records, were required pressure test assessments performed? (AR.PTI.PRESSTESTAMAOP.R) 192.517(a)\n(192.505(a);192.517(b);192.620(c)(4);192.620(d)(9);192.620(d)(10))\n6. Pressure Test Completion From field operations was the pressure test performed in accordance with Subpart J requirements and\n(AR.PTI.PRESSTESTCOMPLETE.O) 192.503(a)\n(192.503(b);192.503(c);192.503(d);192.505(a);192.505(b);192.505(c);192.505(d);192.507(a);192.507(b);192.507(c);192.513(a);192.51\n7. PTI Does the process adequately account for taking required actions to address significant corrosion threats?\n(AR.PTI.PTICORR.P) 192.933 (192.917(e)(5))\n8. PTI Do records demonstrate that required actions are being taken to address significant corrosion threats as required?\n(AR.PTI.PTICORR.R) 192.933 (192.917(e)(5))\nGT.2023.01 Page 11 of 246\n\n<<<PAGE 12>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\n9. Assessments - Spike Hydrotests Do the procedures for selecting pipeline assessment methods specifically include\nspike hydrotests as the assessment method for detecting time-dependent threats? (AR.PTI.SPIKEHYDRO.P) 192.506(a)\n(192.505;192.710(c)(3);192.921(a)(3))\n10. Assessments - Spike Hydrotests Where time-dependent threats were an identified risk, do the records indicate\nthat a spike hydrotest was performed to “clear” any cracks that might otherwise grow during pressure reductions after the\nhydrostatic test? (AR.PTI.SPIKEHYDRO.R) 192.506(a) (192.505;192.710(c)(3);192.921(a)(3))\nAssessment and Repair - Other Technology\n1. Other Technology Has a process been developed for \"other technologies\" that provide an equivalent understanding of\nthe condition of the pipe? (AR.OT.OTPLAN.P) 192.921(a)(4) (192.18)\n2. Other Technology Do records demonstrate that the assessments were performed in accordance with the process and\nvendor recommendations and that defects were identified and categorized within 180 days, if applicable? (AR.OT.OTPLAN.R)\n192.947(d) (192.921(a)(4);192.933(b))\n3. Qualification of Operator/Vendor Personnel Who Evaluate Other Technology Results Does the\nprocess require that operator/vendor personnel (including supervisors) who review and evaluate assessment results meet\nacceptable qualification standards? (AR.OT.OTREVQUAL.P) 192.915(a) (192.915(b);192.921(a)(7);192.493)\n4. Qualification of Operator Personnel Who Evaluate Other Technology Results Do records\ndemonstrate that operator/vendor personnel, including supervisors, who conduct assessments or review assessment results are\nqualified for the tasks they perform? (AR.OT.OTREVQUAL.R) 192.947(d) (192.915(a);192.915(b))\n5. Qualification of Operator Personnel Who Evaluate Other Technology Results From the\nobservation of selected integrity assessments, are operator and vendor personnel, including supervisors, who conduct\nassessments or review assessment results, qualified for the tasks they perform? (AR.OT.OTREVQUAL.O) 192.915(a) (192.915(b))\n6. Other Technology Were assessments conducted using \"other technology\" adequately performed in accordance with the\nOT process? (AR.OT.OTPLAN.O) 192.921(a)(4)\nGT.2023.01 Page 12 of 246\n\n<<<PAGE 13>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\n7. Other Technology - Corrosion Does the process adequately account for taking required actions to address\nsignificant corrosion threats identified using Other Technology? (AR.OT.OTCORR.P) 192.933 (192.917(e)(5))\n8. Other Technology - Corrosion Do records demonstrate that required actions are being taken to address significant\ncorrosion threats as required following the use of Other Technology? (AR.OT.OTCORR.R) 192.933 (192.917(e)(5))\nAssessment and Repair - Predicted Failure Pressure\n1. Anomaly Analysis - Corrosion Metal Loss Do the procedures for evaluating corrosion metal loss anomalies or\ndefects, ensure that a determination of the predicted failure pressure and the remaining life of the pipeline segment is established\nat the location of each anomaly or defect, in accordance with §192.712? (AR.PFP.ANOMALYMETALLOSS.P) 192.712(b)\n(192.607;192.712(a);192.917(b);192.933(d);192.485;)\n2. Anomaly Analysis - Crack Models Do the procedures for evaluating cracks and crack like defects ensure that a\ndetermination of the predicted failure pressure and the remaining life of the pipeline segment is established at the location of each\nanomaly or defect, in accordance with §192.712(d)(1)? (AR.PFP.ANOMALYCRACKMODEL.P) 192.712(d)(1) (192.607;192.712(a);)\n3. Anomaly Analysis - Crack Growth Do the procedures detail the performance of fatigue analysis and remaining life\ncalculations for pipeline segments susceptible to cyclic fatigue or other loading conditions that could lead to fatigue crack growth?\n(AR.PFP.ANOMALYCRACKGROWTH.P) 192.712(d)(2) (192.607;)\n4. Anomaly Analysis - Crack Survives Press Test Do procedures call for the calculation of the largest potential\ncrack defect sizes when analyzing potential cracks that could have survived a pressure test, specifically in the absence of any in-\nline inspection data in accordance with §192.712(d)(3)? (AR.PFP.ANOMALYCRACKSURVIVEPT.P) 192.712(d)(3)\n(192.607;192.712(a);192.712(d)(1))\n5. Anomaly Analysis - Required Data Use Do the procedures detail the use of data when performing analyses of\npredicted or assumed anomalies or defects, in accordance with §192.712(e)? (AR.PFP.ANOMALYDATAUSE.P) 192.712(e) (192.607)\n6. Anomaly Analysis - Records Process Do procedures detail the collection, creation and retention of records\nincluding all investigations, analyses, and other actions taken in performing analyses of predicted or assumed anomalies or\ndefects, in accordance with §192.712(g)? (AR.PFP.ANOMALYRECORDS.P) 192.712(g) (192.607)\nGT.2023.01 Page 13 of 246\n\n<<<PAGE 14>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\n7. Anomaly Analysis - Records Do the records capture all investigations, analyses and other actions taken to support\nthe analysis of predicted failure pressure in accordance with §192.712(g)? (AR.PFP.ANOMALYRECORDS.R) 192.712(g)\n(192.712(e))\nAssessment and Repair - Repair Criteria (HCA)\n1. Categorization of Defects Do records demonstrate that all defects were properly categorized? (AR.RC.DEFECTCAT.R)\n192.947(f) (192.933(b);192.933(d))\n2. Definition of Discovery Does the integrity assessment process properly define discovery and the required time frame?\n(AR.RC.DISCOVERY.P) 192.933(b)\n3. Definition of Discovery Do records demonstrate that discovery was declared in the required time frame or justification\nwas documented? (AR.RC.DISCOVERY.R) 192.947(f) (192.933(b))\n4. Inclusion of All IM Repair Criteria Does the Integrity Management Plan and/or maintenance processes include all\nof the actions that must be taken to address integrity issues in accordance with 192.933? (AR.RC.IMPRC.P) 192.933(a)\n(192.933(c);192.933(d);192.18)\n5. Pressure Reductions Taken in Response to Remediation of Conditions Do records demonstrate that\nan acceptable pressure reduction was promptly taken for each immediate repair condition or when a repair schedule could not be\nmet? (AR.RC.PRESSREDUCE.R) 192.947(f) (192.933(a)(1);192.18)\n6. Prioritized Schedule Do records demonstrate that a prioritized schedule was developed? (AR.RC.SCHEDULE.R)\n192.947(f) (192.933(c))\n7. Adequacy of Remediation Do records demonstrate that the remediation specified in the prioritized schedule was\nadequate to ensure the integrity of the pipeline until the next scheduled reassessment? (AR.RC.METHOD.R) 192.947(f)\n(192.933(a))\nGT.2023.01 Page 14 of 246\n\n<<<PAGE 15>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\n8. Repair Criteria in Covered Segments Does the repair process cover all of the elements for making repairs in\ncovered segments? (AR.RC.CRITERIA.P) 192.711(b) (192.703(a);192.703(b);192.703(c);192.713(a);192.713(b))\n9. Timely Remediation Do records demonstrate that defects in covered segments were remediated (i.e., repair, pressure\nreduction, or notification to PHMSA) within the applicable mandatory time limits of 192.933(d)? (AR.RC.SCHEDULEIMPL.R)\n192.947(f) (192.933(d))\n10. Field Inspection - Remedial Actions (IM) Is anomaly remediation adequate for the covered segments being\nobserved? (AR.RC.REMEDIATION.O) 192.933(c) (192.933(a);192.933(d))\n11. \"Look Beyond\" Evaluation of Significant Corrosion Does the process require an evaluation of all pipeline\nsegments with similar environmental and material coating conditions as segments where corrosion that could adversely affect the\nintegrity of the pipeline was found? (AR.RC.LOOKBEYOND.P) 192.917(e)(5)\n12. \"Look Beyond\" Evaluation of Significant Corrosion From the review of the results of integrity\nassessments, were all pipeline segments evaluated with similar environmental and material coating conditions as segments where\ncorrosion that could adversely affect the integrity of the pipeline was found? (AR.RC.LOOKBEYOND.R) 192.947(b)\n(192.917(e)(5);192.459)\nAssessment and Repair - Repair Methods and Practices\n1. Safety While Making Repairs Does the process ensure that repairs are made in a safe manner and are made so as\nto prevent damage to persons and property? (AR.RMP.SAFETY.P) 192.605(b)(9) (192.713(b))\n2. Safety While Making Repair Are repairs made in a safe manner and to prevent damage to persons and property?\n(AR.RMP.SAFETY.O) 192.605(b)(9) (192.713(b))\n3. Prevention of Accidental Ignition Is there a process for preventing accidental ignition where gas presents a\nhazard of fire or explosion? (AR.RMP.IGNITION.P) 192.605(b)(1) (192.751(a);192.751(b);192.751(c))\nGT.2023.01 Page 15 of 246\n\n<<<PAGE 16>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\n4. Prevention of Accidental Ignition Do records indicate adequate steps were taken by the operator to prevent\naccidental ignition prior to performing work? (AR.RMP.IGNITION.R) 192.751(a) (192.751(b);192.751(c))\n5. Prevention of Accidental Ignition Perform observations of selected locations to verify that adequate steps have\nbeen taken by the operator to minimize the potential for accidental ignition. (AR.RMP.IGNITION.O) 192.751(a)\n(192.751(b);192.751(c))\n6. Tapping Pipelines Under Pressure Is the process adequate for tapping pipelines under pressure?\n(AR.RMP.HOTTAP.P) 192.605(b)(1) (192.627)\n7. Tapping Pipelines Under Pressure From a review of selected records, were the personnel who performed pressure\ntaps on pipelines under pressure qualified? (AR.RMP.HOTTAP.R) 192.627 (192 Subpart N)\n8. Tapping Pipelines Under Pressure Were pressure taps on pipelines under pressure performed in accordance with\nprocesses by qualified personnel? (AR.RMP.HOTTAP.O) 192.627 (192 Subpart N)\n9. Transmission Lines General Requirements for Repair Procedures Does the repair process capture the\nrequirements of 192.711 for transmission lines? (AR.RMP.REPAIRREQT.P) 192.605(b)(1)\n(192.711(a);192.711(b);192.711(c);192.717(b)(3))\n10. Transmission Lines Permanent Field Repair of Defects Is the process adequate for the permanent field\nrepair of defects in transmission lines? (AR.RMP.FIELDREPAIRDEFECT.P) 192.605(b)(1) (192.713(a);192.713(b))\n11. Permissible Repair Methods From the review of records, were all repairs performed in accordance with processes,\napplicable sections of Part 192, the guidance of ASME B31.8S-2004, Section 7, and the Pipeline Repair Manual, Revision 5?\n(AR.RMP.METHOD.R) 192.709(a) (192.713(a);192.713(b);192.717(a);192.717(b);ASME B31.8S-2004 Section 7)\n12. Qualification of Personnel Performing Pipeline Repair From the review of selected records, were\npersonnel performing repairs, other than welding, and post repair tests qualified for the task they performed?\n(AR.RMP.REPAIRQUAL.R) 192.807(b) (192.805(h))\nGT.2023.01 Page 16 of 246\n\n<<<PAGE 17>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\n13. Transmission Lines Permanent Field Repair of Welds Is the process adequate for the permanent field\nrepair of welds? (AR.RMP.FIELDREPAIRWELDS.P) 192.605(b) (192.715(a);192.715(b);192.715(c))\n14. Welder Qualification From the review of selected records, were repairs requiring welding performed by qualified\nwelders using qualified welding processes? (AR.RMP.WELDERQUAL.R) 192.225(a)\n(192.225(b);192.227(a);192.227(b);192.229(a);192.229(b);192.229(c);192.229(d))\n15. Repair of Weld Defects From the review of records, were weld defects repaired in accordance with 192.245 and\n192.715? (AR.RMP.WELDQUAL.R) 192.245(a) (192.245(b);192.245(c);192.715(a);192.715(b);192.715(c))\n16. Inspection of Welds From the review of records, were welds inspected and examined in accordance with 192.241 and\n192.243? (AR.RMP.WELDINSPECT.R) 192.241(a)\n(192.241(b);192.241(c);192.243(a);192.243(b);192.243(c);192.243(d);192.243(e);192.243(f))\n17. Inspection of Welds Were welds inspected and examined in accordance with 192.241 and 192.243?\n(AR.RMP.WELDINSPECT.O) 192.241(a)\n(192.241(b);192.241(c);192.243(a);192.243(b);192.243(c);192.243(d);192.243(e);192.243(f))\n18. Repair Records Pipe Condition Do repair records document all information needed to understand the conditions of\nthe pipe and its environment and provide the information needed to support the Integrity Management Risk Model?\n(AR.RMP.PIPECONDITION.R) 192.709(a) (192.709(b))\n19. Replacement Components From the review of records, were any components that were replaced constructed to the\nsame or higher standards as the original component? (AR.RMP.REPLACESTD.R) 192.713(a) (Part 192 Subpart D)\n20. Transmission Lines Permanent Field Repair of Leaks Is there an adequate process for the permanent\nfield repair of leaks on transmission lines? (AR.RMP.FIELDREPAIRLEAK.P) 192.605(b) (192.717(a);192.717(b))\n21. Transmission Lines Permanent Field Repair of Leaks From the review of records, did the operator\nproperly repair leaks on transmission lines? (AR.RMP.FIELDREPAIRLEAK.R) 192.717(a) (192.717(b))\nGT.2023.01 Page 17 of 246\n\n<<<PAGE 18>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\n22. Transmission Lines Permanent Field Repair of Leaks Does the operator properly repair leaks on\ntransmission lines? (AR.RMP.FIELDREPAIRLEAK.O) 192.717(a) (192.717(b))\n23. Transmission Lines Testing of Repairs Is the process adequate for the testing of replacement pipe and repairs\nmade by welding on transmission lines? (AR.RMP.WELDTEST.P) 192.605(b) (192.719(a);192.719(b))\n24. Transmission Lines Testing of Repairs From the review of records, did the operator properly test replacement\npipe and repairs made by welding on transmission lines? (AR.RMP.WELDTEST.R) 192.719(a) (192.719(b))\n25. Transmission Lines Testing of Repairs Does the operator properly test replacement pipe and repairs made by\nwelding on transmission lines? (AR.RMP.WELDTEST.O) 192.719(a) (192.719(b))\n26. Non-Destructive Testing of Pipeline for Cracking and/or SCC When Exposed for Repair Does\nthe process require that when a pipeline segment that meets the conditions for cracking and/or possible SCC is exposed (i.e., the\ncoating is removed), an NDE method (e.g., MPI, UT) is employed to evaluate for cracking? (AR.RMP.CRACKNDT.P) 192.929(b)\n(ASME B31.8S-2004 Appendix A3.4)\n27. Non-Destructive Testing of Pipeline for Cracking and/or SCC When Exposed for Repair From\nthe review of records, when a pipeline segment that meets the conditions of possible cracking and/or SCC is exposed (i.e., the\ncoating is removed), was an NDE method (e.g., MPI, UT) employed to evaluate for cracking and/or SCC? (AR.RMP.CRACKNDT.R)\n192.947(g) (192.929(b))\nAssessment and Repair - Pipeline Assessments for Non-IM Onshore\nPipelines\n1. Initial Assessment Schedule (Outside of HCAs) What is the process/plan (including the selection criteria,\ntimeline, and use of prior assessments) for performing the initial assessments as required by §192.710(b)(1) and (b)(3)?\n(AR.PA.ASSESSSCHED.P) 192.710(b)(1) (192.710(b)(3))\n2. Initial Assessment Schedule (Outside of HCAs) Do records demonstrate pipeline segments were initially\nassessed (and when) per §192.710(b)(1)? (AR.PA.ASSESSSCHED.R) 192.710(b)(1) (192.710(b)(3))\nGT.2023.01 Page 18 of 246\n\n<<<PAGE 19>>>\n\nPHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023\n3. Assessment Methods (Outside of HCAs) Do the procedures include a methodology for conducting the initial\nassessment of pipeline segments outside of an HCA per §192.710(c)? (AR.PA.ASSESSMETHODS.P) 192.710(c)\n4. Assessment Methods (Outside of HCAs) Do the records confirm the methodology used for conducting the initial\nassessment of pipeline segments outside of an HCA per §192.710(c) was selected based on the results of a risk-based\nprioritization? (AR.PA.ASSESSMETHODS.R) 192.710(c)\n5. Periodic Re-Assessments Do the procedures require reassessments to be conducted at least once every 10 years, not\nto exceed 126 months, or a shorter interval based upon the nature and extent of anomalies discovered in the previous assessment\nas required by §192.710(b)(2)? (AR.PA.REASSESSMENTS.P) 192.710(b)(2) (192.710(b)(3);192.939(a))\n6. Periodic Re-Assessments Do the records indicate adequate documentation of and rationale for the reassessment\nintervals? (AR.PA.REASSESSMENTS.R) 192.710(b)(2) (192.710(b)(3);192.939(a))\n7. Assessments - Other Technology Where the operator has elected to use “Other Technology” (or other technical\nevaluation process) for assessing pipeline segments, does the process demonstrate an equivalent understanding of the condition\nof the line pipe for each of the threats to which the pipeline is susceptible? (AR.PA.OTHERTECH.P) 192.710(c)(7)\n(192.18;192.506(b))\n8. Assessments - Other Technology Where the operator has elected to use “Other Technology” (or other technical\nevaluation process) for assessing pipeline segments, do the records demonstrate an equivalent understanding of the condition of\nthe line pipe for each of the threats to which the pipeline is susceptible? (AR.PA.OTHERTECH.R) 192.710(c)(7)\n(192.18;192.506(b))\n9. Assessments - Anomaly Remediation Criteria Did the operator’s procedures for anomaly investigation and\nremediation criteria","truncated":true,"body_characters":540991}