# 2023 Gas Transmission IA Question Set - **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:** <<>> 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 adequate criteria for determining the need for, and timeliness of, pipeline defect repairs in non-covered segments? (AR.RCOM.NONCOVERED.P) 192.485(a) (192.485(b);192.485(c);192.703(b);192.710;192.711;192.713) 2. Repair Criteria in Non-Covered Segments From the review of the results of integrity assessments, did the operator repair conditions that posed a threat to pipeline integrity on Non-Covered segments? (AR.RCOM.NONCOVERED.R) 192.485(a) (192.485(b);192.485(c);191.23(a)(1);192.703(b);192.710;192.711;192.713) 3. Field Inspection - Remedial Actions (OM) Is anomaly remediation and documentation of remediation adequate for all segments? (AR.RCOM.REMEDIATIONOM.O) 192.485(a) (192.485(b);192.485(c);192.710;192.711;192.713) 4. Alternative Maximum Allowable Operating Pressure per 192.620 (80% SMYS Rule)? If the pipeline operates using an alternative maximum allowable operating pressure per 192.620 (80% SMYS Rule), do the processes meet the requirements of the permit or 192.620? (AR.RCOM.RCAMAOP.P) 192.620(d) 5. Alternative Maximum Allowable Operating Pressure per 192.620 (80% SMYS Rule)? If the pipeline operates using an alternative maximum allowable operating pressure per 192.620 (80% SMYS Rule), from a review of selected records, were required repairs performed? (AR.RCOM.RCAMAOP.R) 192.620(d) Assessment and Repair - Confirmatory Direct Assessment 1. Qualification of Operator/Vendor Personnel Who Evaluate CDA Results Does the process require that operator/vendor personnel (including supervisors) who review and evaluate CDA assessment results meet appropriate training, experience, and qualification criteria? (AR.CDA.CDAREVQUAL.P) 192.915(a) (192.915(b)) 2. Qualification of Operator/Vendor Personnel Who Evaluate CDA Results Do records demonstrate that operator/vendor personnel, including supervisors, who conduct assessments or review assessment results, are qualified for the tasks they perform? (AR.CDA.CDAREVQUAL.R) 192.947(h) (192.915(a);192.915(b)) GT.2023.01 Page 1 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 3. Qualification of Operator/Vendor Personnel Who Evaluate CDA Results From the observation of selected integrity assessments, are operator and vendor personnel, including supervisors, who conduct assessments or review assessment results, qualified for the tasks they perform? (AR.CDA.CDAREVQUAL.O) 192.915(a) (192.915(b)) 4. CDA Plan Is an adequate Confirmatory Direct Assessment Plan in place? (AR.CDA.CDAPLAN.P) 192.931(a) (192.931(b);192.931(c);192.931(d)) 5. External Corrosion Plan Do records indicate that the external corrosion plan was properly implemented? (AR.CDA.CDAEXTCORR.R) 192.947(h) (192.931(b)) 6. Internal Corrosion Plan Do records demonstrate that the internal corrosion plan was properly implemented? (AR.CDA.CDAINTCORR.R) 192.947(h) (192.931(c)) 7. Remediation of Indications Do records demonstrate that the next assessment should have been accelerated? (AR.CDA.CDAINDICATION.R) 192.947(h) (192.931(d)) 8. CDA Does the process adequately account for taking required actions to address significant corrosion threats identified using confirmatory direct assessment? (AR.CDA.CDACORR.P) 192.933 (192.917(e)(5)) 9. CDA Do records demonstrate that required actions are being taken to address significant corrosion threats identified by CDA as required? (AR.CDA.CDACORR.R) 192.933 (192.917(e)(5)) Assessment and Repair - External Corrosion Direct Assessment (ECDA) 1. Qualification of Operator/Vendor Personnel Who Evaluate ECDA Results Does the process require that operator/vendor personnel (including supervisors) who review and evaluate ECDA assessment results meet appropriate training, experience, and qualification criteria? (AR.EC.ECDAREVQUAL.P) 192.915(a) (192.915(b)) GT.2023.01 Page 2 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 2. ECDA Pre-Assessment Do records demonstrate that the ECDA pre-assessment process complied with NACE SP0502- 2010 Section 3 and 192.925(b)(1)? (AR.EC.ECDAPREASSESS.R) 192.947(g) (192.925(b)(1)) 3. Qualification of Operator/Vendor Personnel Who Evaluate ECDA Results Do records demonstrate that operator/vendor personnel, including supervisors, who conduct ECDA assessments or review and analyze assessment results are qualified for the tasks they perform? (AR.EC.ECDAREVQUAL.R) 192.947(g) (192.915(a);192.915(b)) 4. Qualification of Operator/Vendor Personnel Who Evaluate ECDA Results From the observation of selected integrity assessments, are operator and vendor personnel, including supervisors, who conduct assessments or review assessment results, qualified for the tasks they perform? (AR.EC.ECDAREVQUAL.O) 192.915(a) (192.915(b)) 5. ECDA Plan Is an adequate ECDA plan and process in place for conducting ECDA? (AR.EC.ECDAPLAN.P) 192.925(a) (192.925(b)) 6. Integration of ECDA Results with other Information Is the process for integrating ECDA results with other information adequate? (AR.EC.ECDAINTEGRATION.P) 192.917(b) (ASME B31.8S-2004 Section 4.5) 7. Integration of ECDA Results with other Information Do records demonstrate that the operator integrated other data/information when evaluating data/results? (AR.EC.ECDAINTEGRATION.R) 192.947(g) (192.917(b)) 8. ECDA Region Identification Do records demonstrate that the operator identified ECDA Regions? (AR.EC.ECDAREGION.R) 192.947(g) (192.925(b)(1)) 9. ECDA Indirect Examination Do records demonstrate that ECDA indirect inspection process complied with NACE SP 0502-2010 Section 4 and ASME B31.8S-2004, Section 6.4? (AR.EC.ECDAINDIRECT.R) 192.947(g) (192.925(b)(2)) 10. ECDA Direct Examination Do records demonstrate that excavations, direct examinations, and data collection were performed in accordance with NACE SP 0502-2010, Sections 5 and 6.4.2 and ASME B31.8S-2004, Section 6.4? (AR.EC.ECDADIRECT.R) 192.947(g) (192.925(b)(3)) GT.2023.01 Page 3 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 11. ECDA Direct Examination Were ECDA direct examinations adequately conducted? (AR.EC.ECDADIRECT.O) 192.925(b)(3) 12. Quality of ECDA Data Analysis Do records demonstrate that an analysis of the ECDA data and other information was adequate to identify areas where external corrosion activity is most likely? (AR.EC.ECDAANALYSIS.R) 192.947(g) (192.925(b)(4);192.933(b)) 13. ECDA Change Control Have criteria and internal notification processes been established and implemented for any changes in the ECDA plan? (AR.EC.ECDAPLANMOC.P) 192.947(g) (192.925(b)(3)(iii);192.911(k)) 14. ECDA Change Control Do records demonstrate that changes in the ECDA plan have been implemented and documented? (AR.EC.ECDAPLANMOC.R) 192.947(g) (192.925(b)(3)(iii)) 15. ECDA Post-Assessment Do records demonstrate that the requirements for post-assessment were met? (AR.EC.ECDAPOSTASSESS.R) 192.947(g) (192.925(b)(4)) 16. AMAOP ECDA If ECDA was performed on segments (as allowed by §192.620(d)(9)(iii)), were all ECDA assessment requirements completed? (AR.EC.ECDAMAOP.R) 192.947(g) (192.620(d)(9)(iii);192.620(d)(10)(i);192.620(d)(10)(iii);) 17. AMAOP ECDA If ECDA was performed on segments (as allowed by §192.620(d)(9)(iii)), were all ECDA assessment requirements completed? (AR.EC.ECDAMAOP.O) 192.620(d)(9)(iii) (192.620(d)(10)(i);192.620(d)(10)(iii)) 18. External Corrosion Does the process adequately account for taking required actions to address significant external corrosion threats? (AR.EC.ECCORR.P) 192.933 (192.917(e)(5)) 19. External Corrosion Do records demonstrate that required actions are being taken to address significant external corrosion threats as required? (AR.EC.ECCORR.R) 192.933 (192.917(e)(5)) GT.2023.01 Page 4 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 Assessment and Repair - Internal Corrosion Direct Assessment (ICDA) 1. Qualification of Operator/Vendor Personnel Who Evaluate ICDA Results Does the process require that operator/vendor personnel (including supervisors) who review and evaluate ICDA assessment results meet appropriate training, experience, and qualification criteria? (AR.IC.ICDAREVQUAL.P) 192.915(a) (192.915(b)) 2. Qualification of Operator/Vendor Personnel Who Evaluate ICDA Results Do records demonstrate that operator/vendor personnel, including supervisors, who conduct ICDA assessments or review and analyze assessment results, are qualified for the tasks they perform? (AR.IC.ICDAREVQUAL.R) 192.947(g) (192.915(a);192.915(b)) 3. Qualification of Operator/Vendor Personnel Who Evaluate ICDA Results From the observation of selected integrity assessments, are operator and vendor personnel, including supervisors, who conduct assessments or review assessment results, qualified for the tasks they perform? (AR.IC.ICDAREVQUAL.O) 192.915(a) (192.915(b)) 4. ICDA Plan Is an ICDA plan and process in place for conducting ICDA? (AR.IC.ICDAPLAN.P) 192.927(c) (192.927(a);192.927(b)) 5. Pre-Assessment Do records demonstrate that the requirements for an ICDA pre-assessment were met? (AR.IC.ICDAPREASSESS.R) 192.927(c)(1) (192.947(g)) 6. Integration of ICDA Results with other Information Is the process for integrating ICDA results with other information adequate? (AR.IC.ICDAINTEGRATION.P) 192.917(b) 7. Integration of ICDA Results with Other Information Do records demonstrate that other data/information was integrated when evaluating data/results? (AR.IC.ICDAINTEGRATION.R) 192.917(b) (192.947(g)) 8. ICDA Region Identification Do records demonstrate that ICDA Regions were adequately identified? (AR.IC.ICDAREGION.R) 192.947(g) (192.927(c)(2);192.927(c)(5)) 9. Identification of Locations for Excavation and Direct Examination Do records demonstrate that sites were identified where internal corrosion may be present? (AR.IC.ICDADIRECT.R) 192.947(g) (192.927(c)(3);192.927(c)(5)) GT.2023.01 Page 5 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 10. Post-Assessment Evaluation and Monitoring Do records demonstrate that the operator assessed the effectiveness of the ICDA process? (AR.IC.ICDAPOSTASSESS.R) 192.947(g) (192.927(c)(4)(i);192.927(c)(4)(ii);192.477) 11. Quality of ICDA Data Analysis Do records demonstrate that sufficient data was used to complete the ICDA analysis to identify the internal corrosion threats to the pipeline? (AR.IC.ICDAANALYSIS.R) 192.947(g) (192.927(c);192.933(b)) 12. AMAOP ICDA If the pipeline is operated using an alternative maximum allowable operating pressure per 192.620 (80% SMYS Rule) were required ICDA assessments performed? (AR.IC.ICDAMAOP.R) 192.947(g) (192.620(d)(9);192.620(d)(10);192.927) 13. P&M Measures (Internal Corrosion) Does the process adequately account for taking required actions to address significant internal corrosion threats related to internal corrosion? (AR.IC.ICCORR.P) 192.933 (192.917(e)(5)) 14. P&M Measures (Internal Corrosion) Do records demonstrate that required actions are being taken to address significant internal corrosion threats as required? (AR.IC.ICCORR.R) 192.933 (192.917(e)(5)) Assessment and Repair - Stress Corrosion Cracking Direct Assessment (SCCDA) 1. Qualification of Operator Personnel Who Evaluate SCCDA Results Does the process require that operator/vendor personnel (including supervisors) who review and evaluate SCCDA assessment results meet appropriate training, experience, and qualification criteria? (AR.SCC.SCCDAREVQUAL.P) 192.915(a) (192.915(b)) 2. Qualification of Operator Personnel Who Evaluate SCCDA Results Do records demonstrate that operator/vendor personnel, including supervisors, who conduct assessments or review assessment results, are qualified for the tasks they perform? (AR.SCC.SCCDAREVQUAL.R) 192.947(e) (192.915(a);192.915(b)) 3. Qualification of Operator Personnel Who Evaluate SCCDA Results From the observation of selected integrity assessments, are operator and vendor personnel, including supervisors, who conduct assessments or review assessment results, qualified for the tasks they perform? (AR.SCC.SCCDAREVQUAL.O) 192.915(a) (192.915(b)) GT.2023.01 Page 6 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 4. SCCDA Plan Is an adequate plan developed for performing SCCDA, if the conditions for SCC were present? (AR.SCC.SCCDAPLAN.P) 192.929(b) 5. Collect and Evaluate Data Do records demonstrate that data was collected and evaluated? (AR.SCC.SCCDADATA.R) 192.947(g) (192.929(b)(1)) 6. Assessment Method (High pH SCC) Do records demonstrate that an assessment was performed using one of the methods specified in ASME B31.8S-2004 Appendix A3? (AR.SCC.SCCDAMETHOD.R) 192.947(g) (192.929(b)(2)) 7. Assessment Method (High pH SCC) From field observations, was SCCDA performed in accordance with 192.929 and the SCCDA plan? (AR.SCC.SCCDAMETHOD.O) 192.929 8. Assessing for Near Neutral SCC From the review of the results of selected integrity assessments, was the pipeline evaluated for near neutral SCC? (AR.SCC.SCCDANEARNEUTRAL.R) 192.947(g) (192.929(b)(2)) 9. Reassessment Interval From the review of the results of selected integrity assessments, did the operator determine a reassessment interval based on SCCDA results? (AR.SCC.SCCDAREASSESSINTRVL.R) 192.947(d) (192.939(a)(3)) 10. Alternative Maximum Allowable Operating Pressure per 192.620 (80% SMYS Rule)? If the pipeline operates using an alternative maximum allowable operating pressure per 192.620 (80% SMYS Rule), from a review of selected records, were required SCCDA assessments performed? (AR.SCC.SCCDAAMAOP.R) 192.620(d) (192.620(d)(9);192.620(d)(10)) 11. SCC Does the process adequately account for taking required actions to address significant corrosion threats found following SCCDA? (AR.SCC.SCCCORR.P) 192.933 (192.917(e)(5)) 12. SCC Do records demonstrate that required actions are being taken to address significant corrosion threats as required following SCCDA? (AR.SCC.SCCCORR.R) 192.933 (192.917(e)(5)) GT.2023.01 Page 7 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 Assessment and Repair - In-Line Inspection (Smart Pigs) 1. Qualification of Operator/Vendor Personnel (including Supervisors) Who Evaluate ILI Results Does the process require that operator/vendor personnel (including supervisors) who review and evaluate ILI assessment results meet appropriate training, experience, and qualification criteria? (AR.IL.ILIREVIEWQUAL.P) 192.915(a) (192.915(b);192.493) 2. Qualification of Operator/Vendor Personnel (including Supervisors) Who Evaluate ILI Results Do records demonstrate that personnel who conduct assessments or review assessment results are qualified per the process requirements? (AR.IL.ILIREVIEWQUAL.R) 192.947(g) (192.915(a);192.915(b);192.493) 3. Qualification of Operator/Vendor Personnel (including Supervisors) Who Evaluate ILI Results From the observation of selected integrity assessments, are operator and vendor personnel, including supervisors, who conduct assessments or review assessment results, qualified for the tasks they perform? (AR.IL.ILIREVIEWQUAL.O) 192.915(a) (192.915(b);192.493) 4. ILI Specifications Does the process assure complete and adequate vendor ILI specifications? (AR.IL.ILISPECS.P) 192.921(a)(1) (192.933(b);192.493;192.18) 5. ILI Specifications Do records demonstrate that the ILI specifications were complete and adequate? (AR.IL.ILISPECS.R) 192.947(g) (192.933(b);192.493) 6. IMP Assessment Methods Does the process specify the assessment methods that are appropriate for the pipeline specific integrity threats? (AR.IL.ASSESSMETHOD.P) 192.919(b) (192.921(a);192.937(c);192.917;192.493;192.506) 7. IMP Assessment Methods Do records demonstrate that the assessment methods shown in the baseline and/or continual assessment plan were appropriate for the pipeline specific integrity threats? (AR.IL.ASSESSMETHOD.R) 192.947 (192.919(b);192.921(a);192.937(c)) 8. Validation of ILI Results Does the process for validating ILI results ensure that accurate integrity assessment results are obtained? (AR.IL.ILIVALIDATE.P) 192.921(a)(1) (192.937(c);192.493) GT.2023.01 Page 8 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 9. Validation of ILI Results Do records demonstrate that the operator has validated ILI assessment results per their process? (AR.IL.ILIVALIDATE.R) 192.947 (192.921(a)(1);192.493) 10. Validation of ILI Results From observation of field activities, do the employees and vendors validate ILI assessment results per their process? (AR.IL.ILIVALIDATE.O) 192.921(a)(1) (192.493) 11. Integration of ILI Results with other Information Is the process for integrating ILI results with other information adequate? (AR.IL.ILIINTEGRATION.P) 192.917(b) (192.493) 12. Integration of ILI Results with other Information Do records demonstrate that the operator integrated other data/information when evaluating tool data/results? (AR.IL.ILIINTEGRATION.R) 192.947 (192.917(b);192.493) 13. ILI Acceptance Criteria Is the process for ILI survey acceptance criteria adequate to assure an effective assessment? (AR.IL.ILIACCEPCRITERIA.P) 192.921(a) (192.493) 14. ILI Acceptance Criteria Do records indicate adequate implementation of the process for ILI survey acceptance? (AR.IL.ILIACCEPCRITERIA.R) 192.947 (192.921(a);192.493) 15. Integrity Assessments that were Not Performed as Scheduled or Within Required Timeframes Do records indicate that the performance of integrity assessments has been delayed and integrity assessment delays 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) 16. Alternative Maximum Allowable Operating Pressure per 192.620 (80% SMYS Rule)? For pipelines operating under AMAOP, do processes implement the ILI requirements of 192.620(d)(9) and (10) for the entire segment? (AR.IL.ILIAMAOP.P) 192.620(d) (192.493) 17. Alternative Maximum Allowable Operating Pressure per 192.620 (80% SMYS Rule)? For pipelines operating under AMAOP, do records indicate the ILI requirements of 192.620(d)(9) and (10) have been implemented for the entire segment? (AR.IL.ILIAMAOP.R) 192.620(d) (192.493) GT.2023.01 Page 9 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 18. Compliance with ILI Procedures Are O&M and IMP procedural requirements for the performance of ILI assessments followed? (AR.IL.ILIIMPLEMENT.O) 192.921(a)(1) (192.620(d);192.605(b);192.493) 19. In-Line Inspection Does the process adequately account for taking required actions to address significant corrosion threats identified during in-line inspections? (AR.IL.ILCORR.P) 192.933 (192.917(e)(5)) 20. In-Line Inspection Do records demonstrate that required actions are being taken to address significant corrosion threats identified during in-line inspections? (AR.IL.ILCORR.R) 192.933 (192.917(e)(5)) Assessment and Repair - Low Stress Reassessment 1. Low Stress Reassessment Plan Is the process for performing low stress reassessment adequate? (AR.LSR.LSRPLAN.P) 192.941(a) (192.941(b);192.941(c)) 2. Baseline Assessment Do records demonstrate that a baseline assessment meeting the requirements of 192.919 and 192.921 was performed prior to performing a low stress reassessment? (AR.LSR.LSRBA.R) 192.947(d) (192.919(c);192.921(d);192.941(a);192.506) 3. External Corrosion Do records demonstrate that the requirements of §192.941(b) were implemented when performing low stress reassessment for external corrosion? (AR.LSR.LSREXTCORR.R) 192.947(d) (192.941(b)) 4. Internal Corrosion Do records demonstrate that the requirements of §192.941(c) were implemented when performing low stress reassessment for internal corrosion? (AR.LSR.LSRINTCORR.R) 192.947(d) (192.941(c)) 5. LSR - Corrosion Does the process adequately account for taking required actions to address significant corrosion threats following a LSR? (AR.LSR.LSRCORR.P) 192.933 (192.917(e)(5)) 6. LSR - Corrosion Do records demonstrate that required actions are being taken to address significant corrosion threats as required following a LSR? (AR.LSR.LSRCORR.R) 192.933 (192.917(e)(5)) GT.2023.01 Page 10 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 Assessment and Repair - Integrity Assessment Via Pressure Test 1. Qualification of Operator/Vendor Personnel Who Evaluate Pressure Test Results Does the process require that operator/vendor personnel (including supervisors) who review and evaluate pressure test assessment results meet appropriate training, experience, and qualification criteria? (AR.PTI.PRESSTESTREVQUAL.P) 192.915(a) (192.915(b);192.921(a)(4)) 2. Qualification of Operator/Vendor Personnel Who Evaluate Pressure Test Results Do records demonstrate that operator/vendor personnel, including supervisors, who conduct or review pressure test assessment results are qualified for the tasks they perform? (AR.PTI.PRESSTESTREVQUAL.R) 192.947(g) (192.915(a);192.915(b)) 3. Test Acceptance Criteria and Procedures Were test acceptance criteria and processes sufficient to assure the basis for an (AR.PTI.PRESSTESTACCEP.P) 192.503(a) (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 4. Pressure Test Results Do the test records validate the pressure test? (AR.PTI.PRESSTESTRESULT.R) 192.517(a) (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 5. Alternative Maximum Allowable Operating Pressure per 192.620 (80% SMYS Rule)? If the pipeline operates using an alternative maximum allowable operating pressure per 192.620 (80% SMYS Rule), from a review of selected records, were required pressure test assessments performed? (AR.PTI.PRESSTESTAMAOP.R) 192.517(a) (192.505(a);192.517(b);192.620(c)(4);192.620(d)(9);192.620(d)(10)) 6. Pressure Test Completion From field operations was the pressure test performed in accordance with Subpart J requirements and (AR.PTI.PRESSTESTCOMPLETE.O) 192.503(a) (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 7. PTI Does the process adequately account for taking required actions to address significant corrosion threats? (AR.PTI.PTICORR.P) 192.933 (192.917(e)(5)) 8. PTI Do records demonstrate that required actions are being taken to address significant corrosion threats as required? (AR.PTI.PTICORR.R) 192.933 (192.917(e)(5)) GT.2023.01 Page 11 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 9. Assessments - Spike Hydrotests Do the procedures for selecting pipeline assessment methods specifically include spike hydrotests as the assessment method for detecting time-dependent threats? (AR.PTI.SPIKEHYDRO.P) 192.506(a) (192.505;192.710(c)(3);192.921(a)(3)) 10. Assessments - Spike Hydrotests Where time-dependent threats were an identified risk, do the records indicate that a spike hydrotest was performed to “clear” any cracks that might otherwise grow during pressure reductions after the hydrostatic test? (AR.PTI.SPIKEHYDRO.R) 192.506(a) (192.505;192.710(c)(3);192.921(a)(3)) Assessment and Repair - Other Technology 1. Other Technology Has a process been developed for "other technologies" that provide an equivalent understanding of the condition of the pipe? (AR.OT.OTPLAN.P) 192.921(a)(4) (192.18) 2. Other Technology Do records demonstrate that the assessments were performed in accordance with the process and vendor recommendations and that defects were identified and categorized within 180 days, if applicable? (AR.OT.OTPLAN.R) 192.947(d) (192.921(a)(4);192.933(b)) 3. Qualification of Operator/Vendor Personnel Who Evaluate Other Technology Results Does the process require that operator/vendor personnel (including supervisors) who review and evaluate assessment results meet acceptable qualification standards? (AR.OT.OTREVQUAL.P) 192.915(a) (192.915(b);192.921(a)(7);192.493) 4. Qualification of Operator Personnel Who Evaluate Other Technology Results Do records demonstrate that operator/vendor personnel, including supervisors, who conduct assessments or review assessment results are qualified for the tasks they perform? (AR.OT.OTREVQUAL.R) 192.947(d) (192.915(a);192.915(b)) 5. Qualification of Operator Personnel Who Evaluate Other Technology Results From the observation of selected integrity assessments, are operator and vendor personnel, including supervisors, who conduct assessments or review assessment results, qualified for the tasks they perform? (AR.OT.OTREVQUAL.O) 192.915(a) (192.915(b)) 6. Other Technology Were assessments conducted using "other technology" adequately performed in accordance with the OT process? (AR.OT.OTPLAN.O) 192.921(a)(4) GT.2023.01 Page 12 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 7. Other Technology - Corrosion Does the process adequately account for taking required actions to address significant corrosion threats identified using Other Technology? (AR.OT.OTCORR.P) 192.933 (192.917(e)(5)) 8. Other Technology - Corrosion Do records demonstrate that required actions are being taken to address significant corrosion threats as required following the use of Other Technology? (AR.OT.OTCORR.R) 192.933 (192.917(e)(5)) Assessment and Repair - Predicted Failure Pressure 1. Anomaly Analysis - Corrosion Metal Loss Do the procedures for evaluating corrosion metal loss anomalies or defects, ensure that a determination of the predicted failure pressure and the remaining life of the pipeline segment is established at the location of each anomaly or defect, in accordance with §192.712? (AR.PFP.ANOMALYMETALLOSS.P) 192.712(b) (192.607;192.712(a);192.917(b);192.933(d);192.485;) 2. Anomaly Analysis - Crack Models Do the procedures for evaluating cracks and crack like defects ensure that a determination of the predicted failure pressure and the remaining life of the pipeline segment is established at the location of each anomaly or defect, in accordance with §192.712(d)(1)? (AR.PFP.ANOMALYCRACKMODEL.P) 192.712(d)(1) (192.607;192.712(a);) 3. Anomaly Analysis - Crack Growth Do the procedures detail the performance of fatigue analysis and remaining life calculations for pipeline segments susceptible to cyclic fatigue or other loading conditions that could lead to fatigue crack growth? (AR.PFP.ANOMALYCRACKGROWTH.P) 192.712(d)(2) (192.607;) 4. Anomaly Analysis - Crack Survives Press Test Do procedures call for the calculation of the largest potential crack defect sizes when analyzing potential cracks that could have survived a pressure test, specifically in the absence of any in- line inspection data in accordance with §192.712(d)(3)? (AR.PFP.ANOMALYCRACKSURVIVEPT.P) 192.712(d)(3) (192.607;192.712(a);192.712(d)(1)) 5. Anomaly Analysis - Required Data Use Do the procedures detail the use of data when performing analyses of predicted or assumed anomalies or defects, in accordance with §192.712(e)? (AR.PFP.ANOMALYDATAUSE.P) 192.712(e) (192.607) 6. Anomaly Analysis - Records Process Do procedures detail the collection, creation and retention of records including all investigations, analyses, and other actions taken in performing analyses of predicted or assumed anomalies or defects, in accordance with §192.712(g)? (AR.PFP.ANOMALYRECORDS.P) 192.712(g) (192.607) GT.2023.01 Page 13 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 7. Anomaly Analysis - Records Do the records capture all investigations, analyses and other actions taken to support the analysis of predicted failure pressure in accordance with §192.712(g)? (AR.PFP.ANOMALYRECORDS.R) 192.712(g) (192.712(e)) Assessment and Repair - Repair Criteria (HCA) 1. Categorization of Defects Do records demonstrate that all defects were properly categorized? (AR.RC.DEFECTCAT.R) 192.947(f) (192.933(b);192.933(d)) 2. Definition of Discovery Does the integrity assessment process properly define discovery and the required time frame? (AR.RC.DISCOVERY.P) 192.933(b) 3. Definition of Discovery Do records demonstrate that discovery was declared in the required time frame or justification was documented? (AR.RC.DISCOVERY.R) 192.947(f) (192.933(b)) 4. Inclusion of All IM Repair Criteria Does the Integrity Management Plan and/or maintenance processes include all of the actions that must be taken to address integrity issues in accordance with 192.933? (AR.RC.IMPRC.P) 192.933(a) (192.933(c);192.933(d);192.18) 5. Pressure Reductions Taken in Response to Remediation of Conditions Do records demonstrate that an acceptable pressure reduction was promptly taken for each immediate repair condition or when a repair schedule could not be met? (AR.RC.PRESSREDUCE.R) 192.947(f) (192.933(a)(1);192.18) 6. Prioritized Schedule Do records demonstrate that a prioritized schedule was developed? (AR.RC.SCHEDULE.R) 192.947(f) (192.933(c)) 7. Adequacy of Remediation Do records demonstrate that the remediation specified in the prioritized schedule was adequate to ensure the integrity of the pipeline until the next scheduled reassessment? (AR.RC.METHOD.R) 192.947(f) (192.933(a)) GT.2023.01 Page 14 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 8. Repair Criteria in Covered Segments Does the repair process cover all of the elements for making repairs in covered segments? (AR.RC.CRITERIA.P) 192.711(b) (192.703(a);192.703(b);192.703(c);192.713(a);192.713(b)) 9. Timely Remediation Do records demonstrate that defects in covered segments were remediated (i.e., repair, pressure reduction, or notification to PHMSA) within the applicable mandatory time limits of 192.933(d)? (AR.RC.SCHEDULEIMPL.R) 192.947(f) (192.933(d)) 10. Field Inspection - Remedial Actions (IM) Is anomaly remediation adequate for the covered segments being observed? (AR.RC.REMEDIATION.O) 192.933(c) (192.933(a);192.933(d)) 11. "Look Beyond" Evaluation of Significant Corrosion Does the process require an evaluation of all pipeline segments with similar environmental and material coating conditions as segments where corrosion that could adversely affect the integrity of the pipeline was found? (AR.RC.LOOKBEYOND.P) 192.917(e)(5) 12. "Look Beyond" Evaluation of Significant Corrosion From the review of the results of integrity assessments, were all pipeline segments evaluated with similar environmental and material coating conditions as segments where corrosion that could adversely affect the integrity of the pipeline was found? (AR.RC.LOOKBEYOND.R) 192.947(b) (192.917(e)(5);192.459) Assessment and Repair - Repair Methods and Practices 1. Safety While Making Repairs Does the process ensure that repairs are made in a safe manner and are made so as to prevent damage to persons and property? (AR.RMP.SAFETY.P) 192.605(b)(9) (192.713(b)) 2. Safety While Making Repair Are repairs made in a safe manner and to prevent damage to persons and property? (AR.RMP.SAFETY.O) 192.605(b)(9) (192.713(b)) 3. Prevention of Accidental Ignition Is there a process for preventing accidental ignition where gas presents a hazard of fire or explosion? (AR.RMP.IGNITION.P) 192.605(b)(1) (192.751(a);192.751(b);192.751(c)) GT.2023.01 Page 15 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 4. Prevention of Accidental Ignition Do records indicate adequate steps were taken by the operator to prevent accidental ignition prior to performing work? (AR.RMP.IGNITION.R) 192.751(a) (192.751(b);192.751(c)) 5. Prevention of Accidental Ignition Perform observations of selected locations to verify that adequate steps have been taken by the operator to minimize the potential for accidental ignition. (AR.RMP.IGNITION.O) 192.751(a) (192.751(b);192.751(c)) 6. Tapping Pipelines Under Pressure Is the process adequate for tapping pipelines under pressure? (AR.RMP.HOTTAP.P) 192.605(b)(1) (192.627) 7. Tapping Pipelines Under Pressure From a review of selected records, were the personnel who performed pressure taps on pipelines under pressure qualified? (AR.RMP.HOTTAP.R) 192.627 (192 Subpart N) 8. Tapping Pipelines Under Pressure Were pressure taps on pipelines under pressure performed in accordance with processes by qualified personnel? (AR.RMP.HOTTAP.O) 192.627 (192 Subpart N) 9. Transmission Lines General Requirements for Repair Procedures Does the repair process capture the requirements of 192.711 for transmission lines? (AR.RMP.REPAIRREQT.P) 192.605(b)(1) (192.711(a);192.711(b);192.711(c);192.717(b)(3)) 10. Transmission Lines Permanent Field Repair of Defects Is the process adequate for the permanent field repair of defects in transmission lines? (AR.RMP.FIELDREPAIRDEFECT.P) 192.605(b)(1) (192.713(a);192.713(b)) 11. Permissible Repair Methods From the review of records, were all repairs performed in accordance with processes, applicable sections of Part 192, the guidance of ASME B31.8S-2004, Section 7, and the Pipeline Repair Manual, Revision 5? (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) 12. Qualification of Personnel Performing Pipeline Repair From the review of selected records, were personnel performing repairs, other than welding, and post repair tests qualified for the task they performed? (AR.RMP.REPAIRQUAL.R) 192.807(b) (192.805(h)) GT.2023.01 Page 16 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 13. Transmission Lines Permanent Field Repair of Welds Is the process adequate for the permanent field repair of welds? (AR.RMP.FIELDREPAIRWELDS.P) 192.605(b) (192.715(a);192.715(b);192.715(c)) 14. Welder Qualification From the review of selected records, were repairs requiring welding performed by qualified welders using qualified welding processes? (AR.RMP.WELDERQUAL.R) 192.225(a) (192.225(b);192.227(a);192.227(b);192.229(a);192.229(b);192.229(c);192.229(d)) 15. Repair of Weld Defects From the review of records, were weld defects repaired in accordance with 192.245 and 192.715? (AR.RMP.WELDQUAL.R) 192.245(a) (192.245(b);192.245(c);192.715(a);192.715(b);192.715(c)) 16. Inspection of Welds From the review of records, were welds inspected and examined in accordance with 192.241 and 192.243? (AR.RMP.WELDINSPECT.R) 192.241(a) (192.241(b);192.241(c);192.243(a);192.243(b);192.243(c);192.243(d);192.243(e);192.243(f)) 17. Inspection of Welds Were welds inspected and examined in accordance with 192.241 and 192.243? (AR.RMP.WELDINSPECT.O) 192.241(a) (192.241(b);192.241(c);192.243(a);192.243(b);192.243(c);192.243(d);192.243(e);192.243(f)) 18. Repair Records Pipe Condition Do repair records document all information needed to understand the conditions of the pipe and its environment and provide the information needed to support the Integrity Management Risk Model? (AR.RMP.PIPECONDITION.R) 192.709(a) (192.709(b)) 19. Replacement Components From the review of records, were any components that were replaced constructed to the same or higher standards as the original component? (AR.RMP.REPLACESTD.R) 192.713(a) (Part 192 Subpart D) 20. Transmission Lines Permanent Field Repair of Leaks Is there an adequate process for the permanent field repair of leaks on transmission lines? (AR.RMP.FIELDREPAIRLEAK.P) 192.605(b) (192.717(a);192.717(b)) 21. Transmission Lines Permanent Field Repair of Leaks From the review of records, did the operator properly repair leaks on transmission lines? (AR.RMP.FIELDREPAIRLEAK.R) 192.717(a) (192.717(b)) GT.2023.01 Page 17 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 22. Transmission Lines Permanent Field Repair of Leaks Does the operator properly repair leaks on transmission lines? (AR.RMP.FIELDREPAIRLEAK.O) 192.717(a) (192.717(b)) 23. Transmission Lines Testing of Repairs Is the process adequate for the testing of replacement pipe and repairs made by welding on transmission lines? (AR.RMP.WELDTEST.P) 192.605(b) (192.719(a);192.719(b)) 24. Transmission Lines Testing of Repairs From the review of records, did the operator properly test replacement pipe and repairs made by welding on transmission lines? (AR.RMP.WELDTEST.R) 192.719(a) (192.719(b)) 25. Transmission Lines Testing of Repairs Does the operator properly test replacement pipe and repairs made by welding on transmission lines? (AR.RMP.WELDTEST.O) 192.719(a) (192.719(b)) 26. Non-Destructive Testing of Pipeline for Cracking and/or SCC When Exposed for Repair Does the process require that when a pipeline segment that meets the conditions for cracking and/or possible SCC is exposed (i.e., the coating is removed), an NDE method (e.g., MPI, UT) is employed to evaluate for cracking? (AR.RMP.CRACKNDT.P) 192.929(b) (ASME B31.8S-2004 Appendix A3.4) 27. Non-Destructive Testing of Pipeline for Cracking and/or SCC When Exposed for Repair From the review of records, when a pipeline segment that meets the conditions of possible cracking and/or SCC is exposed (i.e., the coating is removed), was an NDE method (e.g., MPI, UT) employed to evaluate for cracking and/or SCC? (AR.RMP.CRACKNDT.R) 192.947(g) (192.929(b)) Assessment and Repair - Pipeline Assessments for Non-IM Onshore Pipelines 1. Initial Assessment Schedule (Outside of HCAs) What is the process/plan (including the selection criteria, timeline, and use of prior assessments) for performing the initial assessments as required by §192.710(b)(1) and (b)(3)? (AR.PA.ASSESSSCHED.P) 192.710(b)(1) (192.710(b)(3)) 2. Initial Assessment Schedule (Outside of HCAs) Do records demonstrate pipeline segments were initially assessed (and when) per §192.710(b)(1)? (AR.PA.ASSESSSCHED.R) 192.710(b)(1) (192.710(b)(3)) GT.2023.01 Page 18 of 246 <<>> PHMSA - Gas Transmission - GT.2023.01 IA Question Set - January 2023 3. Assessment Methods (Outside of HCAs) Do the procedures include a methodology for conducting the initial assessment of pipeline segments outside of an HCA per §192.710(c)? (AR.PA.ASSESSMETHODS.P) 192.710(c) 4. Assessment Methods (Outside of HCAs) Do the records confirm the methodology used for conducting the initial assessment of pipeline segments outside of an HCA per §192.710(c) was selected based on the results of a risk-based prioritization? (AR.PA.ASSESSMETHODS.R) 192.710(c) 5. Periodic Re-Assessments Do the procedures require reassessments to be conducted at least once every 10 years, not to exceed 126 months, or a shorter interval based upon the nature and extent of anomalies discovered in the previous assessment as required by §192.710(b)(2)? (AR.PA.REASSESSMENTS.P) 192.710(b)(2) (192.710(b)(3);192.939(a)) 6. Periodic Re-Assessments Do the records indicate adequate documentation of and rationale for the reassessment intervals? (AR.PA.REASSESSMENTS.R) 192.710(b)(2) (192.710(b)(3);192.939(a)) 7. Assessments - Other Technology Where the operator has elected to use “Other Technology” (or other technical evaluation process) for assessing pipeline segments, does the process demonstrate an equivalent understanding of the condition of the line pipe for each of the threats to which the pipeline is susceptible? (AR.PA.OTHERTECH.P) 192.710(c)(7) (192.18;192.506(b)) 8. Assessments - Other Technology Where the operator has elected to use “Other Technology” (or other technical evaluation process) for assessing pipeline segments, do the records demonstrate an equivalent understanding of the condition of the line pipe for each of the threats to which the pipeline is susceptible? (AR.PA.OTHERTECH.R) 192.710(c)(7) (192.18;192.506(b)) 9. Assessments - Anomaly Remediation Criteria Did the operator’s procedures for anomaly investigation and remediation criteria - **truncated:** true - **body characters:** 540991