# 2024 Gas Transmission IA Question Set - **operation:** document - **citation:** PHMSA GT.2024.01 - **title:** 2024 Gas Transmission IA Question Set - **source type:** inspection - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** guidance - **official:** true - **published on:** 2023-12-26 - **effective on:** 2023-12-26 - **summary:** PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 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-2024-gas-transmission-ia-question-set.json - **markdown:** https://regulus.evalyn.ai/document/phmsa-2024-gas-transmission-ia-question-set.md - **app url:** https://regulus.evalyn.ai/document/phmsa-2024-gas-transmission-ia-question-set - **source url:** https://primis.phmsa.dot.gov/IA-Releases/ia-release-notes/notes/iac-fed.2024.01 **body:** <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 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;192.714) 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) 6. Repair Criteria in Type B and C Gas Gathering Pipelines Do maintenance procedures include adequate criteria for determining the need for, and timeliness of, pipeline repairs in gas gathering pipelines? (AR.RCOM.GGREMEDIATION.P) 192.485(a) (192.9(d)(2);192.9(e)(1)(ii);192.453;192.485(b)) 7. Repair Criteria in Type B and C Gas Gathering Pipelines From the review of records, did the operator repair or replace pipe to permanently restore the serviceability of the pipe? (AR.RCOM.GGREMEDIATION.R) 192.485(a) (191.23(a)(1);191.23(b)(1);192.9(d)(2);192.9(e)(1)(ii);192.453;192.485(b)) 8. Field Inspection - Gas Gathering Remedial Actions Is operator's remediation and documentation of remediation adequate? (AR.RCOM.GGREMEDIATION.O) 192.485(a) (192.453;192.459;192.485(b)) GT.2024.01 Page 1 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 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)) 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)) GT.2024.01 Page 2 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 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)) 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)) GT.2024.01 Page 3 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 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)) 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)) GT.2024.01 Page 4 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 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)) Assessment and Repair - Internal Corrosion Direct Assessment (ICDA) 1. ICDA Plan Pre-Assessment Is an ICDA plan and process in place prior to conducting the pre-assessment step of ICDA? (AR.IC.ICDAPLANPRE.P) 192.927(c) (192.927(a);192.927(b)) 2. ICDA Plan Indirect Inspection Is an ICDA plan and process in place prior to conducting the indirect inspection step in the ICDA process? (AR.IC.ICDAPLANINDIRECT.P) 192.927(c) (192.927(a);192.927(b)) 3. ICDA Plan Detailed Examination Is an ICDA plan and process in place prior to conducting the detailed examination step of the ICDA process? (AR.IC.ICDAPLANEXAM.P) 192.927(c) (192.927(a);192.927(b);192.485;192.712;192.714;192.933) 4. ICDA Plan Post Assessment Is an ICDA plan and process in place prior to conducting the post assessment monitoring? (AR.IC.ICDAPLANPOST.P) 192.927(c) (192.927(a);192.927(b);192.478;192.485;192.712;192.714;192.933) 5. Pre-Assessment Do records demonstrate that the requirements for an ICDA pre-assessment were met? (AR.IC.ICDAPREASSESS.R) 192.947(g) 6. 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)) GT.2024.01 Page 5 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 7. Identification of Locations for Indirect Inspection Do records demonstrate that sites where internal corrosion may be present were properly identified? (AR.IC.ICDAINDIRECT.R) 192.947(g) (192.927(c)(2);192.927(c)(5)) 8. Identification of Locations for Excavation and Direct Examination Do records demonstrate the operator performed detailed examinations of locations identified during the Indirect Inspection? (AR.IC.ICDADIRECT.R) 192.947(g) (192.927(c)(3);192.927(c)(5)) 9. 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);192.927(c)(4)(iii)(A);192.477) 10. 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)) 11. 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)) 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)) 15. 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)) GT.2024.01 Page 6 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 16. 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)) 17. 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)) Assessment and Repair - Stress Corrosion Cracking Direct Assessment (SCCDA) 1. SCCDA Preassessment Plan Does the SCCDA plan include requirements for preassessment? (AR.SCC.SCCDAPLANPRE.P) 192.929(b) (;;;;;;) 2. SCCDA Indirect Inspection Plan Is an adequate SCCDA plan developed prior to indirect inspections? (AR.SCC.SCCDAPLANINDIRECT.P) 192.929(b) (192.929(b)(2);;;;;;) 3. SCCDA Direct Examination Plan Is an adequate plan developed prior to performing SCCDA? (AR.SCC.SCCDAPLANDIRECT.P) 192.929(b) (192.929(b)(3);;;;;;) 4. SCCDA Post Assessment Plan Is an adequate SCCDA plan developed prior to post assessment requirements? (AR.SCC.SCCDAPLANPOST.P) 192.929(b) (192.929(b)(5)) 5. SCCDA Mitigate Is an adequate plan developed for remediating and mitigating SCC once discovered? (AR.SCC.SCCDAMITIG.P) 192.929(b)(4) (NACE SP0204, Section 5.5.1, 6.1.2 and 6.2.1;ASME B31.8S, Appendix A3 and A3.4) 6. Collect and Evaluate Data Do records demonstrate that data was collected and evaluated? (AR.SCC.SCCDADATA.R) 192.947(g) (192.929(b)(1)) GT.2024.01 Page 7 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 7. Indirect Inspection Do records demonstrate that at least two Indirect Inspections were conducted using complementary measurement tools appropriate for the pipeline segment? (AR.SCC.SCCDAINSPECTION.R) 192.947(g) (192.929(b)(2)) 8. Direct Examination Do records demonstrate that a minimum of three direct examinations for SCC were performed within the covered pipeline segment? (AR.SCC.SCCDAEXAM.R) 192.947(g) (192.929(b)(3)) 9. Assessment Method (Near Neutral and High pH SCC) Do records demonstrate that the operator mitigated the threat of SCC, if found? (AR.SCC.SCCDAMITIG.R) 192.947(g) (192.929(b)(4);NACE SP0204, Section 5.5.1, 6.1.2, and 6.2.1;ASME B31.8S, Appendix A3 and A3.4) 10. Assessment Method (Near Neutral and High pH SCC) From field observations, was SCCDA performed in accordance with 192.929 and the SCCDA plan? (AR.SCC.SCCDAMETHOD.O) 192.929 11. 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)) 12. 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)) 13. 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)) 14. 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)) 15. 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.2024.01 Page 8 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 16. 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)) 17. 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)) 18. 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)) 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) GT.2024.01 Page 9 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 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) 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) GT.2024.01 Page 10 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 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) 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 (192.919;192.921;192.941(b);192.941(c)) GT.2024.01 Page 11 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 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)) 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 GT.2024.01 Page 12 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 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)) 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)(7) (192.18) GT.2024.01 Page 13 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 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)(7);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)(7) 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? (AR.PFP.ANOMALYMETALLOSS.P) 192.605 (192.607;192.712(a);192.917(b);192.933(d);192.485;192.712(b)) GT.2024.01 Page 14 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 2. Anomaly Analysis - Dents Do the procedures for evaluating dents and other mechanical damage 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? (AR.PFP.ANOMALYDENTS.P) 192.605 (192.607;192.712(a);192.712(b);192.933(d);192.485;192.712(c);192.712(h)) 3. 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) 192.605 (192.607;192.712(a);192.712(d)(1)) 4. 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) 192.605 (192.607;192.712(d)(2)) 5. 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)) 6. 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) 192.605 (192.607;192.712(e)) 7. 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) 192.605 (192.607;192.712(g)) 8. Anomaly Analysis - Records Process Do procedures detail the reassessment of anomalies when an operator used an Engineering Critical Assessment method? (AR.PFP.ANOMALYREASSESS.P) 192.605 (192.712(h)) 9. 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)) GT.2024.01 Page 15 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 Assessment and Repair - Repair Criteria (HCA) 1. General Requirements Do the repair procedures detail what actions must be taken to address integrity issues? (AR.RC.GENERAL.P) 192.907(a) (192.933(a)) 2. General Requirements Do the repair records show what actions the operator took to address integrity issues? (AR.RC.GENERAL.R) 192.947(a) (192.933(a)) 3. Temporary Pressure Reduction Do the repair procedures require a temporary pressure reduction for making repairs in covered segments? (AR.RC.PRESSUREREDUC.P) 192.907(a) (192.933(a)(1);192.933(a)(2);192.933(d)(1)) 4. Temporary Pressure Reduction Do records demonstrate that a temporary pressure reduction was taken immediately or when a repair schedule could not be met? (AR.RC.PRESSUREREDUC.R) 192.947 (192.933(a)(1);192.933(a)(2);192.933(d)(1)) 5. Discovery of Condition Do the repair procedures require properly define discovery and the required time frame for response in covered segments? (AR.RC.DISCOVERY.P) 192.907 (192.933(b)) 6. Discovery of Condition Do the records show that discovery was declared in the required timeframe? (AR.RC.DISCOVERY.R) 192.947 (192.933(b)) 7. Prioritized Scheduling Do the repair procedures discuss remediating conditions according to a prioritization schedule in covered segments? (AR.RC.SCHEDULE.P) 192.907(a) (192.933(c)) 8. Prioritized Scheduling Do records demonstrate that defects in covered segments were remediated according to a prioritization schedule? (AR.RC.SCHEDULE.R) 192.947 (192.933(c)) 9. Immediate Repair Conditions Do the repair procedures cover all of the elements for making immediate repairs in covered segments? (AR.RC.IMMEDIATE.P) 192.907 (192.933(d)(1)) GT.2024.01 Page 16 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 10. Immediate Repair Conditions Do records demonstrate that all conditions requiring immediate repair were repaired immediately upon discovery? (AR.RC.IMMEDIATE.R) 192.947 (192.933(d)(1)) 11. One-Year Conditions Do the repair procedures cover all of the elements for making repairs in covered segments for One-year conditions? (AR.RC.ONEYEAR.P) 192.907 (192.933(d)(2)) 12. One-Year Conditions Do records demonstrate that all conditions meeting the one-year condition requirements were repaired within one year of discovery? (AR.RC.ONEYEAR.R) 192.947 (192.712;192.933(d)(2)) 13. Monitored Conditions Do the repair procedures require the operator to record and monitor conditions that meet monitoring criteria in covered segments? (AR.RC.MONITOR.P) 192.907 (192.933(d)(3)) 14. Monitored Conditions Do records demonstrate that all defects were properly categorized? (AR.RC.MONITOR.R) 192.947 (192.712;192.933(d)(3)) 15. Crack Defects Do the repair procedures require the operator to perform direct examinations of known locations of cracks or crack-like defects? (AR.RC.CRACK.P) 192.907 (192.933(e)) 16. Crack Defects Do the records show that the operator performed direct examinations of known locations of cracks or crack-like defects? (AR.RC.CRACK.R) 192.947 (192.933(e)) 17. Field Inspection - Remedial Actions Is anomaly remediation adequate for the covered segments being observed? (AR.RC.REMEDIATION.O) 192.933 18. Repair Procedures (Temporary) Do the repair procedures require the operator to take immediate temporary measures to protect the public? (AR.RC.CRITERIATEMP.P) 192.605(b)(1) (192.711(a)) GT.2024.01 Page 17 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 19. Repair Procedures (Temporary) Do the records show that the operator took immediate temporary measures to protect the public? (AR.RC.CRITERIATEMP.R) 192.709 (192.711(a)) 20. Repair Procedures (Permanent) Do the repair procedures require the operator to make permanent repairs? (AR.RC.CRITERIAPERM.P) 192.605(b)(1) (192.711(b)) 21. Repair Procedures (Permanent) Do the records show that the operator made permanent repairs on both non- integrity management and integrity management segments of the pipeline? (AR.RC.CRITERIAPERM.R) 192.709 (192.711(b)) 22. Repair Procedures (Weld Patch) Do the repair procedures prohibit the operator from using welded patches? (AR.RC.CRITERIAWELD.P) 192.605(b)(1) (192.711(c)) 23. Repair Procedures (Weld Patch) Do the records show that the operator made repairs using welded patches? (AR.RC.CRITERIAWELD.R) 192.709 (192.711(c)) 24. Repair Procedures (Observations) Is the anomaly remediation adequate for segment being observed? (AR.RC.CRITERIAOBSERVE.O) 192.711 Assessment and Repair - Repair Criteria (Non-HCA) 1. General Requirements Do the repair procedures detail making repairs in a safe manner in non-covered segments? (AR.RCNONHCA.GENERAL.P) 192.605(a) (192.714(a);192.714(b);192.714(h)) 2. General Requirements Do records demonstrate that repairs were made in a safe manner in non-covered segments? (AR.RCNONHCA.GENERAL.R) 192.714(b) (192.714(h)) GT.2024.01 Page 18 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 3. Prioritized Scheduling Do the repair procedures discuss remediating conditions according to a prioritization schedule in non-covered segments? (AR.RCNONHCA.SCHEDULE.P) 192.605 (192.714(c);192.714(h)) 4. Prioritized Scheduling Do records demonstrate that defects in non-covered segments were remediated according to a prioritization schedule? (AR.RCNONHCA.SCHEDULE.R) 192.714(c) (192.105;192.714(h)) 5. Immediate Repairs Do the repair procedures cover all of the elements for making immediate repairs in non-covered segments? (AR.RCNONHCA.IMMEDIATE.P) 192.605 (192.714(d)(1);192.714(h)) 6. Immediate Repairs Do records demonstrate that all conditions requiring immediate repair were repaired immediately upon discovery? (AR.RCNONHCA.IMMEDIATE.R) 192.714(d)(1) (192.712;192.714(h)) 7. Two-Year Conditions Do the repair procedures cover all of the elements for making repairs in non covered segments for Two-year conditions? (AR.RCNONHCA.TWOYEAR.P) 192.605 (192.714(d)(2);192.714(h)) 8. Two-Year Conditions Do records demonstrate that all conditions meeting the two-year condition requirements were repaired within two years of discovery? (AR.RCNONHCA.TWOYEAR.R) 192.714(d)(2) (192.712;192.714(h)) 9. Monitored Conditions Do the repair procedures require the operator to record and monitor conditions that meet monitoring criteria in non covered segments? (AR.RCNONHCA.MONITOR.P) 192.605 (192.714(d)(3);192.714(h)) 10. Monitored Conditions Do records demonstrate that all defects were properly categorized? (AR.RCNONHCA.MONITOR.R) 192.714(d)(3) (192.712;192.714(h)) 11. Temporary Pressure Reduction Do the repair procedures require a temporary pressure reduction for making repairs in non-covered segments? (AR.RCNONHCA.PRESSUREREDUC.P) 192.605 (192.714(e);192.714(h)) GT.2024.01 Page 19 of 269 <<>> PHMSA - Gas Transmission - GT.2024.01 IA Question Set - January 2024 12. Temporary Pressure Reduction Do records demonstrate that a temporary pressure reduction was taken immediately or when a repair schedule could not be met? (AR.RCNONHCA.PRESSUREREDUC.R) 192.714(e) (192.714(h)) 13. Other Conditions Do the repair procedures require the operator to take appropriate remedial action for other conditions that could affect safe operations in non-covered segments? (AR.RCNONHCA.OTHER.P) 192.605 (192.714(f);192.714(h)) 14. Other Conditions Do the records show that the operator took appropriate remedial action for other conditions that could affect safe operations in non-covered segments? (AR.RCNONHCA.OTHER.R) 192.714(f) (192.714(h)) 15. Crack Defects Do the repair procedures require the operator to perform direct examinations of known locations of cracks or crack-like defects? (AR.RCNONHCA.CRACK.P) 192.605 (192.714(g);192.714(h)) 16. Crack Defects Do the records show that the operator performed direct examinations of known locations of cracks or crack-like defects? (AR.RCNONHCA.CRACK.R) 192.714(g) (192.714(h)) 17. Field Inspection - Remedial Actions Is anomaly remediation adequate for the non-covered segments being observed? (AR.RCNONHCA.REMEDIATION.O) 192.714 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) 1 - **truncated:** true - **body characters:** 573560