The presentation will be based on a study that I commissioned and managed with Stress Engineering to help the industry deal with the PHMSA Mega Rule requirements. These requirements have implications on the operating pressures of gas pipelines across the country and require that the records be traceable, verifiable, and complete. If the records do not meet the TVC standards, then operators are required to use field methods to determine pipe properties such as grade. Prior to this study, all testing has been done by the equipment manufacturer's engineers (Massachusetts Material Testing MMT, Frontix, and Plastometrex PLX). None of these companies are service providers and therefore they also have a training component that is not included in their technology validation work. The study that we performed used average level II NDE technicians trained on the equipment to perform the testing with the manufacturers being held to a hands off support role to mimic what could be achieved over the phone. The presentation does not rank the technologies or companies, but does identify some gaps in training as well as "human factors" that affected the results.
Several factors are involved including:
Communication - NDE company communication with the client as well as communication with the technician. This let to non-mega rule compliant performance of the testing.
Training Gaps - There were technicians that were in-experienced and not trained to perform all of the tasks involved in the process which led to sampling not being taken in the right location for the seam.
Regulatory Gap - PHMSA does not approve technologies, they only "don't object" and this leaves the operator to perform their own due diligence on technologies, but also makes every operator do their own unless a JIP is involved.