A Level III Named in Your Practice, Reachable During Turnaround

The Houston industrial base a Level III has to actually cover

The Houston Ship Channel and the Texas Gulf Coast around it form the largest concentration of refining and petrochemical capacity in North America. The refining base runs from ExxonMobil's Baytown complex through the Deer Park refinery, Chevron's Pasadena refinery, LyondellBasell's Houston refinery, Valero's Houston plant, and Marathon's Galveston Bay refinery at Texas City, with Phillips 66 Sweeny out at Old Ocean. Petrochemicals sit alongside them: Chevron Phillips at Cedar Bayou, LyondellBasell and Equistar at Channelview, INEOS at Chocolate Bayou, Celanese at Clear Lake, Covestro at Baytown, and the Dow, BASF and Olin complexes at Freeport.

That base is not one NDT problem, it is several. Refining brings sulfidation, naphthenic acid corrosion, wet H2S cracking and high-temperature hydrogen attack. Olefins and polymers bring different cracking mechanisms and a great deal of B31.3 piping. The NGL side at Mont Belvieu brings fractionation trains, brine systems and salt-dome storage. The terminal and tank farm belt at Galena Park, Seabrook, Bayport and Texas City brings API 653 work at scale, with floor scanning and shell course thickness surveys on a repeating out-of-service cycle.

Behind all of it sits a manufacturing and fabrication economy that most Level III scopes forget. Pressure vessel and skid shops across Channelview, La Porte and the west industrial belt work to Section VIII and Section IX. Oilfield and subsea equipment manufacturers in northwest Houston and out toward Katy and Rosenberg work to API 6A and 16A with forging and casting acceptance levels. The seamless pipe mill at Bay City sits inside the region's supply chain. A written practice built only for field refinery work will not carry a shop that examines forgings.

Who regulates what in Texas, and what nobody regulates

Texas has no state OSHA plan covering private-sector employers, so process safety management under 29 CFR 1910.119 is enforced federally, and refineries in the region have long experience of the national emphasis programme aimed at that sector. Air authorisations run through the Texas Commission on Environmental Quality, with Harris County Pollution Control Services active locally. Intrastate pipelines and oil and gas operations answer to the Railroad Commission of Texas; interstate lines answer to PHMSA under 49 CFR Parts 192 and 195. The US Chemical Safety Board has investigated enough incidents in this corridor that its reports are effectively part of the region's engineering memory.

The gap is the interesting part. The Texas Department of Licensing and Regulation administers the state boiler law under Health and Safety Code Chapter 755, which means boilers get a statutory inspection regime with a state-recognised inspector. Unfired pressure vessels do not. There is no Texas equivalent of a state pressure vessel inspection statute reaching into a refinery's vessel population, which is why in-service integrity here is driven by API 510, 570 and 653, by the mechanical integrity requirements of the process safety rule, and by owner specifications.

For an NDT programme that inversion matters enormously. In a jurisdiction with a state inspector, external authority arrives on a cycle and finds problems for you. In Texas, the only routine external scrutiny of your NDT is the client audit — and the client audits because his own mechanical integrity file depends on your certificates and your procedures. That is why the Level III function here is a commercial asset, not a compliance overhead.

Turnaround season is really a certification queue

Houston turnaround work concentrates in spring and autumn, and the technician pool is shared across contractors. When a large unit comes down, the crews staffing it come from everywhere, and every one of them arrives with a certificate issued under somebody else's written practice. Certification is employer-specific: a card from another contractor has no standing under your practice. So the receiving employer must credit documented training, experience and examination through a Level III review, or examine and certify from scratch.

That review is not a formality and it does not scale by goodwill. Twenty supplemental technicians across four methods is a real workload of records review, specific examinations against your procedures, and practical examinations with graded records. It lands in the two weeks before mobilisation, at exactly the moment everyone is busiest, and it is the single most common reason a contractor arrives on site with people who are not acceptable to the owner's QA representative.

The way to defuse it is to build the crediting process into the written practice in advance — what evidence is acceptable, who reviews it, what is examined regardless, and what the turnaround time is — and to keep a bank of controlled examination material ready rather than assembling it under pressure. A Level III of record who has done this in the Houston market knows the seasonal shape of it and staffs accordingly. One who does not will grade your examinations in November.

Tank farms, terminals and the API 653 workload

The storage and terminal belt around Houston is enormous: refinery tank farms, the merchant terminals along Galena Park and the Ship Channel, Bayport and Seabrook, and the Texas City complex, plus the salt-dome storage at Mont Belvieu. API 653 drives an out-of-service inspection cycle in which floor scanning by magnetic flux leakage is followed by ultrasonic verification of indications, shell course thickness surveys establish corrosion rates, and settlement and shell distortion surveys feed the evaluation.

The NDT technical authority questions here are specific. What is the MFL procedure qualified on — plate of the right thickness, with the right coating, with representative top-side and underside loss? What is the verification technique for an MFL indication, and what is the reporting threshold that decides whether a prover is used? How is the scanner's detection performance demonstrated, and by whom? These decisions are Level III decisions and they change the outcome of a tank inspection more than any instrument choice.

There is also a division of roles here that gets muddled constantly. The API 653 inspector authorises and signs the tank inspection and makes the fitness-for-service call. The NDT technician performs the scanning and thickness work under a written practice. The Level III approves the procedures both of them rely on, and reviews the data independently when it is contested. Atlantis supplies the third of those roles. It does not act as the inspector of record.

The shop side: fabrication, forgings and equipment manufacturing

Field refinery work dominates the conversation in Houston, but a large part of the region's NDT demand sits in shops. Pressure vessel and skid fabricators work to ASME Section VIII Division 1 with Section V examination and Section IX welding qualification. Structural fabricators work to AWS D1.1, where the ultrasonic acceptance regime is materially different from the ASME approach and where the crossover error — applying one code's acceptance criteria under the other's calibration — is a genuine recurring finding.

Oilfield and subsea equipment manufacturing brings a third regime again. API 6A and 16A products involve forgings and castings where the ultrasonic acceptance level, the scanning coverage of a forged body, and the demonstration on a representative block are the whole substance of the procedure. Where a shop also does aerospace-adjacent work, NAS 410 enters and with it a different personnel qualification regime, which the written practice has to accommodate explicitly rather than by implication.

A Level III scope built only around in-service refinery inspection will not serve those shops well, and a scope built only around shop work will be thin on damage mechanisms. This matters when choosing who to name in your practice: ask what the individual has actually approved procedures for, in which product forms, against which acceptance regimes — not simply which method certificates he holds.

What 'of record' obliges the Level III to do

Naming someone in your written practice creates specific, continuing obligations. He prepares and maintains the practice itself. He writes or approves the NDT procedures and their qualification records. He prepares, administers and grades the general, specific and practical examinations, and controls the examination material so it does not circulate. He recommends certification, and the employer certifies. He reviews technique changes against the referencing codes when the service or the code edition moves. And he represents you on technical questions when a client audits.

What he does not do is equally important and should be written down. He does not authorise or sign the in-service inspection — that is the API 510, 570 or 653 inspector's function. He does not audit your process safety management programme. He does not become your quality manager. Blurring those roles is convenient right up to the moment somebody asks who was accountable for a decision, at which point the ambiguity is expensive for everyone.

Founder Anoop Rayavarapu holds ASNT NDT Level III certification in multiple methods and is an API 653 Authorized Inspector, and Atlantis works out of Houston and Hyderabad. The scope of methods covered by any engagement is agreed in writing before anything is signed, because that scope is the boundary of the authority — and a practice that claims more coverage than its Level III can support is worse than a practice that claims less.

The questions to ask before you name anyone

Ask for the method certificates and match them line by line against the methods in your written practice. Ask what happens to any method that does not match. Ask for a response commitment in writing — hours, not intentions — and ask who signs if the named individual is unreachable during a turnaround. Ask whether he will attend a client audit in person, and whether that is inside the engagement or billed separately. Ask what examination material he controls and how it is protected from circulation.

Then ask the technical questions that reveal whether he has worked your service. For a refiner: which damage mechanisms his procedures were qualified against, and what he does about HTHA screening. For a terminal operator: what he requires of an MFL procedure and its verification technique. For a shop: which acceptance regimes he has approved procedures under, and how he handles the AWS-versus-ASME calibration crossover. The answers separate people who have run programmes from people who have signed documents.

Finally, ask about handover. Level III relationships end — retirement, relocation, a change of contractor. A practice should say what happens then, and a professional arrangement should include a documented handover pack: current procedures with qualification records, examination material inventory, personnel file status, and open issues. Programmes that fall apart usually fall apart at that transition, not during normal operation.

Scope, boundaries and how to start

Atlantis provides NDT technical authority: written practice development, procedure development and qualification, personnel certification within the practice, examination preparation and grading, audit representation on technical questions, and independent review of inspection data. Alongside that sit the software products — inspection reporting and the digital twin platform — which are separate offerings and are never a condition of the consulting work. Positioning is affordable, accessible and fully customisable; consultation or quote on request.

The boundaries are firm and worth restating. Atlantis is not a PSM auditor. Atlantis does not act as the API 510, 570 or 653 inspector of record. Atlantis does not run API individual inspector certification training. Those are distinct roles held by distinct parties, and a consultant who offers to be all of them at once is offering you a conflict rather than a service.

A sensible first engagement in the Houston market is a gap review timed against your next turnaround: the written practice against the contracts you have signed, the personnel files against the practice, and the procedures against the damage mechanisms your units actually have. That produces a short, ordered list of what must be fixed before mobilisation and what can wait. Write to info@atlantisndt.com with your method scope, your client specifications and your turnaround dates.

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