Can the ECDA assessment option be applied to significant portions of above ground portions of pipelines that cannot be assessed with ILI tools or hydrostatic testing?
No. Per 195.588 (b) (1), the use of direct assessment on an onshore pipeline to evaluate the effects of external corrosion must follow the requirements of NACE Standard RP05022002. As stated in NACE RP0502-2002 Section 1.1.5 ECDA as described in this standard is specifically intended to address buried onshore pipelines constructed from ferrous materials. While the NACE standard (Section 3.4.1.3) does, in certain cases, allow for the substitution of 100% direct examination at bellhole locations in lieu of a minimum of two indirect examination tools, PHMSA does not apply this exception to significant lengths of above ground piping. Operators may be able to technically justify a direct approach for assessing above ground lines, but such approaches are considered to be other technology that require a Notification to PHMSA per 195.452 (c) (1) (i) (D) and 195.452 (j) (5) (iv).
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