Person Person Email Origin Category Section Page

First
Name

Michiel mbrongers@em Voter Negative Sections 5

Brongers c-sq.com and 7

Garry Garry.Matocha Voter Negative 1.12 4

Matocha @enbridge.com

Voter Appendix 22
A
Voter 3.5.1 13

Voter 3.5.3 13

Voter 3.5.4 13

Voter 4.4 15

Voter 4.5 15

Voter 5.3.2 17
Voter 5.5 18

Voter 7.4 20

Voter 7.5 20

Voter Appendix
B

Voter Appendix
D
John john.bringas@c Voter Negative 2.1 4
Bringas asti.ca

Carlos cpalacios59@g Voter Negative

Palacios mail.com
Antony antony.semerad Voter Negative
Semerad @bellaliant.net

Joe Davis jd1@xsmail.com Voter Negative 46

Rhett rdobriant@gmai Observer Substantive Multiple Multiple
O'Briant l.com

Substantive Section
1.1

Substantive Section
1.7
Substantive Section
1.7

Editorial Section
1.7

Editorial Section 2

Substantive Section 3

Substantive Section 3

Substantive Section
3.2.1
Substantive Section
3.2.2
Substantive Section
3.5

Substantive Section
5.3.2

Substantive Appendix
A, B & D

Substantive Appendix
A, 2.2
Substantive Appendix
A, 2.3

Substantive Appendix
A, 2.5.2
Substantive Appendix
A, Table
2.1

Substantive Appendix
A, Section
3

Substantive Appendix
A, Section
4

Substantive Appendix
A, Section
4

Substantive Appendix
A, Section
8
Substantive Appendix
A, Section
8.1
 Subject

See comments provided in attached form.

Lack of clarity on scope

Appendix A is not needed

Qualification and Ceritifications

Pending publications should not be referenced

Pending certification programs should not be referenced

Delete or identify threats

Use of the term "possibly" is not appropriate

Detection of Cracks is not a stated capability of most GWT

Table 3 labeling is incorrect

Direct Examination and Validation

All actions should be recorded

Delete Appendix B

Delete Appendix D
2.1 Definitions does not reference NACE/ASTM G193

Negative arguments are attached

VAWS Ballot vote for SC 15 AMPP SP0131-202x

Consistent naming/description
Method vs. Technique

Scope - Internally Coupled Tools

Guided Wave Transmission

Guided Wave Detection

GWT vs. Guided Wave

Figure 2 Graphic

Appendix A - Recommend Removal

90 Degree Bends - Table 2

Appendix A Reference

Appendix A Reference
GWT Qualification & Certification

Guided Wave & Crack Detection

Appendix A, B & D - Recommend Removal

Sound travel terminology

Guided Wave Excitation

Sensor Spacing Term

90 Degree Bends - Appendix A, Table 2.1

Appendix A, Section 3 Regulatory

Guided Wave Detection

Mechanical Damage & SCC

Correct DAC Setting

DAC Settings/Calibration
 Comment

I vote negative, because the SP should limit itself to detection and sizing
of features, and leave any interpretations to other standards. SP 0313
should not specify: (1) what assessment methods or criteria to use to
interpret results, (2) how to assess feature severity, (3) what responses
to take, (4) what standards to use or how to determine reassessment
intervals, (5) perform any calculations beyond sizing the features,
including making any estimates of corrosion growth rates, remaining life,
(6) what mitigation acitvities might be appropriate, or (7) any planning
for follow-up.  All of these are beyond the scope of the SP0313.

There needs to be an "introduction of some type in the General Section

to indicate that that there are several steps to the process.   1.  Pre-
Assessment  2, Conducting the Guided Wave Test   3. Post
Assessment

Appendix A is a reprint from a 2010 GTi doucment which was prepared

at the request of PHMSA.  A reprint of a 12 year old study in an AMPP
standard is not appropriate
Section 3.5.1 provides for based on internal resources and outside
entities such as universities for low attenuationa and high attenuation
piping.  There is no definiction of low or high attenuation piping. 
 Why is it necessary to have certification from internal resources and a
university. This is not relevant or practical

This section references a pending publication from 10 years ago.  This

should be deleted

Section 3.5.4, references an upcoming certification program from 10

years ago.   This is nor appropriate for a standard

The section section on wall thicknesses should either delete the

reference to detecting other threats or identify the threats
There is a statement that information should "possibly" be included in
the report.  Either it should or it should not.   

Delete the section on cracks.  It is not a stated capability of most GWT

equipment
The heading in the table indicates that the categories are based on
population density but the data provided is in % SMYS. As this is an
international document, the heading is not relevant for international use

There is a section on Direct Examination and validation but there is not

guidance in the standard regarding these items.  It only provides
information the records

There is a requirement to record "all actions".  This is a very open

ended requirement and leaves the companies open to liabilty

The reference to Appendix B is a footnote in the Definitions section.  As

this is a standard and not a state of the art report, this appendix provides
not value to the standard 

Delete Appendix D as the information references a report that is 12 years

old and out of date
The 2.1 Definitions section does not reference NACE/ASTM G193,
“Standard Terminology and Acronyms Relating to Corrosion† for
corrosion-related terms and definitions, included in the NACE
International Publications Style Manual as follows.

2.6 Corrosion-Related Terms

Corrosion-related terms must be used consistent with definitions
given in the latest revision of NACE/ASTM G193, “Standard
Terminology and Acronyms Relating to Corrosion† (Item no. 21137).
Special usage and uncommon terms not included in the glossary should
be defined in the text as appropriate. For abbreviations, symbols, and
acronyms associated with corrosion-related terms, see Appendix B.
Consequently, since the following SP0313-202x balloted terms and
definitions are identical as in NACE/ASTM G193, thereby redundant, they
can be deleted.

Corrosion: The deterioration of a material, usually a metal, that results

from a chemical or electrochemical reaction with its environment.
Crack: A partial split or break.
Cracking: Fracture of a material along a path that produces a linear
discontinuity (without complete separation).
Fatigue: The process of progressive localized permanent structural
change occurring in a material subjected to fluctuating stresses less than
the ultimate tensile strength of the material that may culminate in cracks
or complete fracture after a sufficient number of fluctuations.

See attached Ballot Form

Please see the attached document for my comments. Tony SEMERAD,

04-11-2022

The word coating is used over 2 dozen times, paint or painted occurs
two.  Harmonize the terms to coating
There are multiple locations in the document where GWT is referred to
as a technique (as well as many where it is referred to as a method). 

The paragraph references internally coupled tools.  The scope should

be limited to conventional, externally coupled screening systems. 

Text 'through the pipeline wall' is incorrect.

Second sentence - Changes in time of flight is not how GWT is used to

detect imperfections - this would only be the case for thinning and use of
a dispersive wave.

In the text 'The transducer transmits a controlled pulse GWT along the
pipe', GWT is incorrect here.

Figure 2 graphic needs to be clearer, more legible.  

Appendix A references a 12 year old report OTD-11/0001 and should be

removed.   

Bends-90s, number that can be tested 'two' is not correct.

Appendix A references a 12 year old report OTD-11/0001 and should be

removed.   
Appendix A references a 12 year old report OTD-11/0001 and should be
removed.   
This entire section needs to be updated and reorganized.  The CP 105
reference in first sentence of Paragraph 3.5.1 needs to be updated.
 The last sentence of paragraph 3.5.1 is vague and should be removed.
 The current Section 3.5.3 content should be removed as it references
OTD-11/0001. 

This section on cracking seems out of place in the contact of guided

wave.  Guided wave screening is not considered or marketed as a crack
detection method.  It is acknowledged, however, that cracks may be
found as part of the direct examination process (not a direct result of
guided wave screening)  

Appendix A, B and D contain many outdated references and add

unnecessary complexity to the standard.  The standard should be
reduced to the core content for better readability and continuity.

Text '...sound to travel longitudinally down the pipe in both directions'.

Text '...or laser techniques can be used'

Text '...sensors at a known spacing in the longitudinal  direction'.

Bends-90s, number that can be tested, 'two' is not correct.

If Appendix A remains in the document, the "accepted integrity

assessments in accordance with Part 192.." paragraphs need to be
updated to state that guided wave is now an approved assessment
method per 192.  This is true for any section referencing the PHMSA
"18-Point Checklist".

4th paragraph '...GWT can only detect relatively large reflectors , has
difficulty determining whether the anomaly is internal or external, and
has limited sizing ability.'  Guided wave can, in fact detect small
reflectors but this statement is relative.  The determination of internal
vs. external is not possible.  

Text: 'To date, neither 3rd party mechanical damage nor SCC has been
successfully detected by GWT (assuming the typical wall loss for these
types of features is under 5% cross-sectional area [CSA])'.  

It has been shown that guided wave based monitoring systems can
detect 1% cross-sectional area, but this is not in the context of screening
(recommended scope of this standard).

The importance of setting the DAC correctly should be emphasized.

In the text: 'The inspection system software can “fit† a line (DAC or
TCG) to the weld peaks'. The use of quotation marks around the word fit
is unclear. The Absolute Calibration method (on equipped systems) is the
most accurate method to automatically fit the DAC curves (as opposed to
manual manipulation). This method calculates the DAC levels using an
algorithm of signal reflections and their multiple reflections from
reflectors such as welds, within the normal test range. 
 Proposal Response

See comments provided in attached form. See responses on the attached

comment form.

GWT may be used as a stand-a-lone process to Agree: Added this suggested

identify area of internal and/or external metal language to the scope.
loss or as an assesment method using the
follownig processes

* Pre-Assessment

* Conducting guide wave testing

*  Post Assessment

Either include relevant sections from the GTI  Agree: Removed Appendix A
Report, but inclusion as a whole is not pertinent since it is out of date.
in a standard.  It may have been state of the art
12 years ago as it uses terms such as "to-date"
and "currenty" but does not include any changes
that have been made.  It provides guidance on
the use of GWT as an assessment method and
not as an inspection method.  This technical
guidance is out of date for a industry standard.
Delete the sentence that reads   "GWT
certification should be based on traiing and
testing from internal resources and outside
entities such as universities for both low
attenuation and high attenuation piping"
Delete this section as referencing a pending
publication from 10 years ago is not appropriate
for a standard.
This section should be deleted as referencing an
upcoming certification program in a standard is
not apprpriate
Eliminate the last sentence on identifying other
threats
The sentence is as follows:
"The requirements of the service provider or the
operator should be detailed in the contract and
possibly repeated in the report".     
Delete "and possibly repeated in the report"
Delete setion 5.3.2 as the use of GWT is to find
changes in volumetric metal loss.  See section
1.8.  Appendix A indicates that it was not
normally used ot detect SCC.  Thus the
inclination that it will find cracks is misleading.
Agree. Changed to "Method
training for GWT personnel shall
meet the minimum
requirements set forth in the
body of knowledge in ANSI/ASNT
CP 105 or ISO 25107 where
applicable. The employers
written practice should stipulate
the number of hours of training
and the required hands on
experience needed for each level
of GWT certification."
Agree. Deleted.
Agree. Changed the wording to
"Certification programs, such as
those developed by ASNT,8,9 or
another nationally recognized
certification program may be
considered."
Agree. Deleted last sentence.
Agree. Deleted.
Agree. Section is deleted.
Change the heading to indicate the factors are
relelated ot % SMYS rather than population
density
When operating at a certain %
SMYS, then the population
density would drive a
corresponding response plan. It
seems like the table is shown
correctly. Please clarify and/or
propose new wording.

There is guidance on the documents that need to
be provided for direct examination and
validation, but nothting in the remainder of the
document that addresses the data to be
collected.
This is just saying that whatever
direct examintion is conducted
should be recorded. No change
is needed.

Delete the reference to  Agree. Based on other

"All actions should be recorded".   comments, this section is
deleted completely.
 

Substitute

" That that should be recorded are as follow:"

Delete Appendix B as this is a standard and not a Agree. It doesn't add value.
state of the art report. Deleted.

Delete the Appendix as it is out of date and Agree. It doesn't add value.
provides no current value to the standard.  It is Deleted.
only referenced as an alternative to "pending
publication".
Add the following sentence to 2.1 Definitions and Everett B: This does need to be
delete the above 4 redunadant terms and added to the beginning of the
definitions. definitions section, this is my
mistake. I will add.
2.1 Definitions
For corrosion-related terms and definitions used
in this Standard Practice, reference NACE/ASTM
G193 “Standard Terminology and Acronyms
Relating to Corrosion” (Item no. 21137), with
the following additional terms and definitions.

See responses on the attached

comment form.
See responses on the attached
comment form.

Level 1 Agree. The entire appendix has

been deleted based on other
Road crossings that arepainted coated no comments. The revised
centering rings document is now consistent with
the use of the word "coating".
Level 2

Buried piping in
sand/earth with thin
fusion-bonded
epoxy (FBE) or liquid coatingsor paint
All instances of the word 'technique' related to Accept. Technique replaced
GWT should be replaced with 'method'. with method.

Remove everything after the first sentence. Left as-is. It is just saying that it
may be possible to adapt this to
internally coupled tools.

Statement should be replaced with 'along the Agree. Replaced as stated.

length of the pipe'.
Change second sentence to read:  "and Agree. Replaced as stated.
interpretation of reflected signals received can be
used to detect imperfections, features, and
defects in the short segments of the pipeline
system under inspection."

GWT should be replaced with 'guided wave'. Yes, that was corrected already.
 This appears to be corrected in the submitted
draft, but the comment is included to be sure.  

Update Figure 2 with improved graphic.   I agree but it is a picture that I

don't have access to edit. So not
changed at this time.

Delete last sentence of paragraph 3.1.1 and Agree. Deleted.

delete Appendix A and all associated references.
 

"Number That Can Be Tested" should say "One", Changed to One.

maximum.
Delete last sentence of paragraph 3.2.1 Agree. Deleted.

Delete paragraph 3.2.2. Agree. Deleted.

Suggested revision:   Agree. Rewritten as suggested.
3.5.1 - Method training for GWT personnel shall
meet the minimum requirements set forth in the
body of knowledge in ANSI/ASNT CP 105 or ISO
25107 where applicable. The employers written
practice should stipulate the number of hours of
training and the required hands on experience
needed for each level of GWT certification. 
3.5.2 - Third party Certifications schemes such as
ASNT ACCP Level II and Level III or PCN Level II
and Level III can be considered if and when those
programs are available.  
3.5.3 - Specific manufactures training in the
operations of the GWT equipment and the
software associated with the particular GWT
equipment should be required for all levels of
GWT Certification. 

Consider removing Sections 5.3.2 and 5.3.2.1.   Agree. Removed.

Remove Appendix A, B & D and all references Agree. Removed A, B, and D.

within the document.

Additional technical comments are provided for

Appendix A, should it be decided to retain the
content within the standard.  

Better to say ‘axially’ to avoid Removed Appendix A.

misinterpretation with longitudinal modes.
There is no laser-based commercial screening Removed Appendix A.
tool available.  Recommend removing 'laser'
from the text.  EMAT can be used to excite
guided waves.  May consider replacing 'laser'
with "EMAT".  

Better to say ‘sensors at a known spacing in Removed Appendix A.

the axial direction’ to avoid misinterpretation
with longitudinal modes.
"Number That Can Be Tested" should say "One", Removed Appendix A.
maximum.

Revise the 2nd, 3rd and 5th paragraphs to align Removed Appendix A.
with current 49 CFR Part 192.

Suggestion:  "By varying the amplitude, Removed Appendix A.

frequency, and direction of the signal travel and
the analytical resolution and differentiation of the
reflected signals, GWT can detect large and
relatively small reflectors, depending on testing
conditions.  It is not possible to determine
whether a reflector is internal or external." 

Suggestion:  "3rd party mechanical damage and Removed Appendix A.

SCC are not reliably detected by GWT screening
(assuming the typical wall loss for these types of
features is under 5% cross-sectional area [CSA]).
Both threats generally produce signals that are
below the detection level of the equipment, i.e.,
GWT screening should be used to detect external
and internal corrosion."

Provide further emphasis to the importance of Removed Appendix A.

DAC setting.

Suggestion:  "The DAC provides the ability to

determine the signal amplitude at a point away
from the transducer ring. This allows for
determining the relative amplitude of an echo,
expressed eg in CSA, at a given distance. If the
DAC curves are set too low, the size of possible
defects may be overestimated, and vice versa.
 Therefore it is vital that the DAC levels are set
correctly before interpreting the data as they
provide reference CSA levels to all other signals
for comparison.  Setting the DAC or TCG curves
correctly is a reference calibration process."

Reference eg: ISO 18211:2016.

Suggested addition of:  "If the equipment Removed Appendix A.
permits absolute calibration of amplitude, then it
be used. Otherwise calibration shall be carried
out using reflections from features of the pipe
which have known, predictable reflectivity."
Liaison suggestions