The new regulations, Part 195 Section 195.452, require that special integrity assessments be made to address potential seam-defect problems in low-frequency-welded ERW (electric-resistance-welded) pipe materials where a failure of such materials could have an impact on a high-consequence area (HCA). The spirit of this requirement appears to require action if, and only if, significant seam-related deficiencies are in evidence or if they can be reasonably anticipated. This leaves open the option of categorizing these types of pipelines by performance such that potentially problematic pipeline segments can be subjected to special (i.e., seam-quality) inspections while those that show little or no propensity for such problems can be subjected to metal loss and deformation inspections only. This document is intended to establish a systematic procedure to permit an operator to characterize the relevant ERW pipe segments as to the likelihood of significant seam-related deficiencies. The author is particularly grateful to Rich Turley of Marathon Ashland Pipe Line LLC for helping to formulate the essential steps in deciding when an integrity assessment is needed. Rich made significant inputs to Figure 1 of this document.

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