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Regulation and Records

The documentation an operator should demand from any testing contractor

Specify the deliverable in the contract and you receive it. Leave it to custom and you receive whatever the contractor usually sends.

Why be specific

Test records must be retained for the life of the pipeline under 49 CFR 192.517 and 195.310. A record that is thin on the day is thin for thirty years.

The cost of specifying the deliverable is one clause. The cost of not specifying it is discovered by whoever inherits the file.

The list

  • Segment definition — identification, limits, pipe and fittings within it, with grades and wall thicknesses
  • The test plan as executed — the ladder, pressures, durations, sequence, including any spike
  • Continuous traces — pressure and temperature, at the recorded sample interval, in an open format
  • Instrument records — identification, resolution, calibration certificates with matching serial numbers
  • Fill and medium data — volume, source, treatment, temperatures
  • The analysis — predicted pressure-temperature response, the weighted temperature basis, the balance statement and the residual
  • Acceptance — the criteria applied, the argument, and who signed against what
  • Deviations — anything that departed from procedure, and how it was resolved
  • Photographs — test heads, instrument installations, gauge plates where relevant

The two that get left out

The analysis and the deviations. Both are the parts that would be most useful later, and both are the parts a contractor has least incentive to volunteer.

A test with no recorded deviations on a real jobsite is usually a test where deviations were not recorded.

Format and timing

Specify open formats and a delivery deadline tied to something meaningful — typically before final payment. Records requested six months later arrive incomplete, if at all.

Apply the stranger testCould a competent engineer who was not there, working for a company that did not own the asset, reconstruct what was done and why it was accepted? If not, the record is not finished.

Where this is taught

The record that survives is a full session on the executive briefing, because the people who can insist on it are usually the people buying the test, not the people running it.

Standing noteThis is educational reference material, not engineering advice. Regulations are revised continually; the editions in force at the time of a project govern, and every project requires its own qualified engineering analysis and the operator’s governing specifications.
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