Naming a Level III of Record for a Permian Basin NDT Program
A Level III of record is the named technical authority in your written practice: he approves procedures, controls examinations, recommends certification and answers for the program when a client audits it. Atlantis provides that role for Odessa and Permian Basin operators and service companies, across the methods we hold certification in, with scheduled basin time and continuous remote authority.
Odessa is the working half of the Permian Basin. Midland holds the head offices; Ector County holds the machine shops, the pipe yards, the coating and fabrication plants, the compressor and pump packagers, the gas processing and gathering infrastructure spread across the basin, and the service bases of every major pressure pumping and wireline company. That mix produces an unusual NDT problem: enormous volumes of routine examination performed by a workforce that moves between employers several times in a cycle. Certification does not move with them. An ASNT Level II certificate issued by one Odessa contractor is void at the contractor across the road until that employer's own Level III qualifies and certifies the technician under its own written practice. Companies here discover this in the middle of a client audit, with fifteen active certificates that were never legitimately issued. A named Level III of record is what stops that from happening twice.
Source: Written against ASNT SNT-TC-1A and ANSI/ASNT CP-189, ASME Section V Article 1, the personnel provisions of API 510, 570 and 653, API RP 7G-2 and DS-1 for used drill stem inspection, Texas Administrative Code Title 25 Chapter 289 for radioactive material licensing and industrial radiography administered by Texas DSHS, Railroad Commission of Texas intrastate pipeline safety authority under 49 CFR 192 and 195, and Texas Health and Safety Code Chapter 755 for boilers administered by TDLR.
| Role | What it authorises | Qualified under | Who normally holds it |
|---|---|---|---|
| API 510, 570 or 653 inspector | Authorises and signs the in-service inspection of the vessel, piping circuit or tank | API individual certification against the relevant code's body of knowledge | Owner's inspector, or a contracted API inspector |
| NDT technician, Level I or II | Performs the examination and, at Level II, interprets and reports to an approved procedure | The employer's written practice, to SNT-TC-1A or CP-189 | Service company or owner employee |
| ASNT NDT Level III of record | Approves the written practice, the procedures and the examinations; recommends certification | ASNT NDT Level III certification in each method claimed | Staff or contracted Level III, named in the practice |
| Radiation safety officer | Radiation safety, surveys, dosimetry, storage and transport of sources | Conditions of the Texas DSHS radioactive material licence | The individual named on the licence |
| Drill stem inspection operator | Inspects used drill stem and classifies it to DS-1 or API RP 7G-2 categories | Employer written practice plus the inspection standard's own personnel requirements | Odessa or Midland inspection shop employee |
What "of record" means, and why the phrase matters
A Level III of record is not a consultant you call when something goes wrong. He is the person named inside your written practice as the continuing technical authority for the NDT program, and the practice states what he does: approve the practice and its revisions, approve every NDT procedure and its qualification record, control examination content or qualify whoever writes it, recommend certification, recertification and reinstatement, resolve interpretation disputes on technical grounds, and answer for the program when a client or a regulator audits it.
The distinction from ad hoc Level III support is the word continuing. A signature on a procedure two years ago tells an auditor nothing about who has authority today. What an audit tests is whether there is an identifiable person, currently certified in the method under discussion, whose approval stands behind the document in front of him — and whether that person can be produced.
In the Permian this matters more than it does in a settled refinery program, because Permian NDT programs are built and rebuilt constantly. Companies scale from twelve technicians to sixty inside eighteen months, add methods to win a contract, and drop them when the contract ends. Each of those moves needs a technical authority to sign it off, and each one leaves a documentary trail somebody will later read.
What Odessa actually is, industrially
The Midland–Odessa metroplex splits along a line most outsiders miss. Midland carries the corporate side of the Permian: operator head offices, land, finance, geoscience. Odessa and Ector County carry the physical side — machine shops, pipe and tubular yards, coating and threading plants, valve and wellhead repair shops, compressor and pump packaging, tank and separator fabrication, and the large service bases of the major pressure pumping, wireline, coiled tubing and directional companies. If steel is being cut, welded, threaded, coated, pressure tested or inspected in the Permian, a great deal of it happens inside Ector County.
Around that core sits the infrastructure the shops feed. Cryogenic gas processing plants are built densely across both the Midland and Delaware sub-basins. Crude gathering converges on hub complexes at Midland, Crane and Wink, and long-haul lines run from there to the Gulf Coast. In-basin frac sand mines operate in the dune district west and south of the city, in Winkler and Ward counties. Produced water gathering and disposal systems have grown into a pipeline network in their own right. Gas-fired generation and a very large wind and solar build-out sit on the ERCOT grid across West Texas. Heavier refining capacity sits east of the region rather than in the city itself, so the basin's process inspection load is weighted toward gas plants, compression, separation and storage rather than crude towers.
The NDT consequence is a specific mix: high-volume weld examination on spool fabrication and plant construction, API 653 tank populations spread across hundreds of small tank batteries and truck terminals rather than concentrated in one terminal, pressure vessel work on separators and treaters built in local shops, and a very large used drill stem inspection sector working to DS-1 and API RP 7G-2. That last one is nearly invisible outside the basin and it carries its own personnel requirements layered on top of the written practice — a point that catches Level IIIs who arrive from a refining background.
Certification does not travel — the basin's most expensive misunderstanding
An NDT certification is issued by an employer, under that employer's written practice, on the recommendation of that employer's Level III. It is not a licence and it is not a portable qualification. When the technician leaves, it lapses. When he arrives at the company across the road, he is uncertified there until that company examines and certifies him under its own practice.
In Odessa this collides with a labour market where technicians change employers two or three times in a cycle. What actually happens on the ground is that a hiring supervisor takes a photograph of the incoming technician's previous card, files it, and puts him on a job the same week. Six months later a client auditor pulls three certification files, finds no examination records for any of them, and asks the obvious question. The answer — that the technician was certified elsewhere — is not an answer.
A written practice can and should make this manageable. It can define what documented prior training and experience is creditable, what evidence it accepts, and what examinations must still be run before certification. Done properly, a competent transferring technician is legitimately certified within days rather than weeks, and the file survives an audit. Done by photograph, nothing survives. Structuring that transfer route is one of the first things we do when we take on the Level III of record role for a basin company.
Boom, bust, and the interrupted service clause nobody wrote
The Permian's cycle does something to NDT programs that steady-state industries never experience. A downturn removes a crew for eight or nine months; the recovery brings the same people back to the same employer. Their certifications were never revoked, but they have not performed the method in the interim, and the written practice is supposed to say what happens next.
Most Odessa practices we review either omit the interrupted service clause entirely or reproduce a sentence from a template without defining anything usable. A clause that works states the interruption period that triggers action, distinguishes an absence from the employer from an absence from the method, sets what is required on return — a practical re-examination, a full re-examination, or a documented period of supervised work — and names who decides. It also says what evidence goes in the file.
Without that clause a company has only two options after a layoff, and both are bad. Re-examine everyone from scratch, which is expensive and slows remobilisation at precisely the wrong moment; or reinstate everyone quietly, which is fast and indefensible. Writing the clause takes an afternoon. Living without it costs a company a full audit cycle.
Texas jurisdiction over the work your certificates support
Texas regulates the Permian through a set of agencies that do not overlap the way people expect. The Railroad Commission of Texas has jurisdiction over oil and gas production, gathering systems and intrastate pipeline safety, administering the federal pipeline safety rules on intrastate lines as PHMSA's agent. Interstate lines stay with PHMSA directly. TCEQ handles air and waste authorisations, which is what actually schedules a great deal of turnaround and repair work.
Radiography is the one that most often surprises incoming Level IIIs. Texas is an NRC Agreement State, so radioactive material licences are issued by the Texas Department of State Health Services and industrial radiography operates under state rules in Title 25 of the Texas Administrative Code, Chapter 289 — not under the NRC directly. That governs licensing, the radiation safety officer, radiographer and assistant requirements, surveys, storage and transport. A company that adds radiography to win a plant contract is entering a licensing regime, not just adding a method to its practice.
Pressure equipment runs the other way. Texas administers a boiler programme through the Department of Licensing and Regulation under Chapter 755 of the Health and Safety Code, but the state operates no jurisdictional inspection programme for unfired pressure vessels. For separators, treaters, filters and the rest of the equipment population an Odessa shop builds and an operator runs, there is no state inspector arriving to check the work. The owner's own API 510 programme, the procedures behind it, and the written practice certifying the technicians are the entire control. That is worth stating plainly to anyone who assumes somebody else is watching.
Method scope, and what radiography drags in
A Level III of record can only carry the methods he is certified in. This is not a formality — it is the point at which a written practice most often becomes indefensible. A service company running penetrant, magnetic particle, ultrasonics and radiography needs Level III authority in all four, and the practice must state each Level III's scope by method. Naming one person against methods he does not hold puts every certification issued under those methods in question.
Where a company's scope exceeds ours, we say so at the scoping call rather than at the audit. In practice that means naming our covered methods in the practice, and either bringing in a second named Level III for the remainder or helping the company qualify and name its own. A practice with two named Level IIIs and clean scope boundaries is entirely normal and far stronger than one name stretched across everything.
Radiography deserves separate attention because it pulls in a licensing regime, an RSO, radiographer qualification requirements and transport obligations that sit outside the written practice altogether. The Level III of record is responsible for radiographic technique, procedure adequacy, image quality requirements and personnel qualification in the method. He is not, by virtue of that role, the radiation safety officer. One person can hold both if properly qualified and named for each, but the roles must be separately documented, because they answer to different bodies for different failures.
What operators' contracts and client audits now ask for
Master service agreements issued by the larger Permian operators have tightened noticeably. The recurring clauses ask the contractor to name its NDT Level III, to make the written practice available on request, to demonstrate that procedures are approved and qualified, and to permit an audit of personnel certification records. Some now ask for the Level III's certification expiry date directly in the prequalification questionnaire.
The audits that follow are short and file-based, and they follow the same path every time: pull the written practice, note the revision, pull three certification files, trace each backwards to training, experience, examinations, examiner qualification and vision, and check the certifying signature against the practice and against that signatory's own certification status on the date signed. Any break in that chain is a finding. Two breaks usually means a corrective action plan with a deadline attached to a contract.
Being able to produce a named, current, contactable Level III who wrote the practice and approved the procedures changes the tone of that audit considerably. It is the difference between a contractor explaining its documents and a contractor's technical authority explaining them. We attend those audits for clients where the scope covers our methods, and we prepare for them by running the same trace ourselves first.
How the engagement runs for an Odessa company
It starts with an honest inventory: methods actually performed, levels needed, existing written practice and revision, existing procedures and their approval status, the certification files as they stand, the client and regulatory regimes in play, and whether radiography or drill stem inspection brings additional requirements. Nothing existing is discarded — certifications and records are mapped forward and repaired, because voiding a file to make paperwork tidy creates a worse problem than the one it solves.
From there the role becomes continuing rather than project-shaped. Procedure approvals and revisions as work changes. Examination control and grading, or qualification of your examiner. Certification and recertification recommendations on a schedule. Interrupted service decisions when the cycle turns. A documented annual review of the practice. Audit preparation and attendance where our scope covers the methods in question. Scheduled time in the basin for practical examinations and demonstrations, which cannot be done remotely, combined with continuous remote authority for everything that can.
The scope of our certification is stated in writing before anything is signed, and it is repeated inside the written practice so no auditor has to ask. Scoping conversation and consultation on request through info@atlantisndt.com.
Where this role stops
A Level III of record is technical authority over the NDT programme. He is not the API 510, 570 or 653 inspector of record. He does not authorise or sign the in-service inspection of a vessel, a piping circuit or a tank, and he does not set inspection intervals. Those are the API inspector's acts, performed under a different certification and a different body of knowledge, and conflating the two in a contract is a documentation failure that surfaces at the worst possible time.
He is also not a process safety management auditor. Where a Permian facility falls under 29 CFR 1910.119 — and many gas processing and NGL facilities do — the mechanical integrity element will reference NDT procedures and personnel qualification, and the Level III of record supplies and defends that piece. He does not conduct the compliance audit, certify the programme, or represent the operator on process safety questions beyond the NDT technical scope.
What sits inside the role is specific and worth being clear about: written practice authorship and approval, procedure development, qualification and approval, personnel certification within that practice, technical resolution of interpretation disputes, independent review of inspection data, and representation on technical questions when the programme is audited. That boundary is written into the engagement, because a Level III who accepts responsibility he cannot discharge is not an asset to anyone's programme.
What does a Level III of record actually approve?
The written practice itself and its revisions; each NDT procedure and its qualification record; examination content and the examiner's qualification, or the examinations directly; recommendations for certification, recertification and reinstatement; the technical resolution of interpretation disputes; and the program's answers during a client or regulatory audit. He does not sign the employer's certificates unless the practice names him as the certifying authority.
Does an NDT certification move with a technician between Odessa employers?
It does not. Certification belongs to the employer that issued it and lapses when the technician leaves. In a basin where crews change companies inside a single drilling cycle, this is the most expensive misunderstanding on site. The receiving employer may credit documented training and experience, but must examine and certify under its own written practice first. Fifteen invalid certificates surfacing mid-audit is a routine Permian event.
Which Texas agencies regulate the work an Odessa NDT program supports?
The Railroad Commission of Texas covers oil and gas production, gathering and intrastate pipeline safety, acting for PHMSA on intrastate lines. TCEQ handles air and waste permitting that drives turnaround scope. Texas Department of State Health Services licenses radioactive material, so industrial radiography runs under state rules, not the NRC directly. Texas regulates boilers through TDLR but operates no state unfired pressure vessel inspection program.
What happens to certification after a Permian layoff?
The written practice's interrupted service clause decides, and most Odessa practices do not have one worth reading. It must state the interruption length that triggers action, what is required on return — practical re-examination, full re-examination, or documented supervised work — and who decides. Without it, a company rehiring a crew after a nine-month downturn either re-examines everyone unnecessarily or reinstates people it cannot defend.
Can one Level III cover every method a Permian service company runs?
Only the methods he holds certification in. A company running PT, MT, UT and RT needs Level III coverage in all four, and the written practice must state the scope of each Level III by method. Naming a single Level III against methods he is not certified in is a finding that invalidates the certifications issued under it. Where our scope stops, we say so and help you cover the gap.
Is the Level III of record the same as the radiation safety officer?
No, and conflating them causes real trouble in Texas. The RSO is named on the radioactive material license issued by the state health department and answers for radiation safety, surveys, dosimetry and transport. The Level III of record answers for radiographic technique, procedure adequacy and radiographer qualification. One person may hold both roles only if that person is qualified and named for each.