What does PHMSA expect to see in a direct assessment feasibility study?
The specific considerations in determining the feasibility of ECDA, ICDA, and SCCDA will differ, since the methods themselves differ. In any case, PHMSA expects an operator’s IM plan to include a written process integrating the information available about the pipeline to demonstrate its conditions/characteristics are consistent with assumptions made in each of the DA methods. The plan is also expected to provide mechanisms to maintain the associated documentation to record the basis upon which the operator concluded that each selected DA method is feasible. For ECDA, this should include determining the practicality of using two complementary indirect examination tools, assembling information about the pipeline (including coating condition and cathodic protection experience) necessary to define Regions, and identifying areas where indirect tools may not provide accurate readings and determining how those areas will be handled. This also includes all documentation associated with verific
