Dr. Dave’s Take on Green Bananas and the Standards Process

Rhett Dotson So, one of my favorite quotes. I've been told that I use it several times a year is barring from the introduction to the landslide management standard written by Enga. Today, I no longer have to borrow from the original author of those words as he's a guest on the show and gives us exclusive used to the use of the word geezer. We are not changing the name of the series from the Sage series to the Geezer series, but today we do enjoy a great conversation with a well-known geezer in the industry covering all sorts of topics from ASMEB 318S to again, the challenges and standard development today Christopher De Leon The one-armed metallurgist. Rhett Dotson And yes, hear about one armed metallurgist. Today on pipeline things. Rhett Dotson Boom. Welcome to today's edition of Pipeline things. I am your host Rhett Dotson, my co-host, Christopher de Leon. It is a pleasure to be with you guys again as we continue our sage series. So really excited about today's guest because I feel like he almost needs no introduction to give the audience some clues. This particular gentleman, I mean, it's like his reputation precedes him, but I love to quote him. I've probably quoted his introduction to the landslide, the ENGA management of landslides, GOP probably ten times on this planet. Ten times on this podcast is probably something I feel like I have the need to do. Like once or twice a year. It's just so well-written. But really a great, great with jokes, lots of great humor. You know, Chris, before we were when we were doing a little research for the Sage series, and we reached out to him through getting candidates right, this one told us that he doesn't buy green bananas anymore. Christopher De Leon And it takes you little want to think about it. And if you if you are a little bit witty, you're like, oh I think I get it. Do you still buy green bananas that we're not talking about like Grinch Christmas? Where you do you like the Elf on the shelf? Where like you have one banana that the Grinch touched? Rhett Dotson I wonder does miss producer, does Trip S does she does she eat bananas? It's a question, alright she's a Banana fan. Okay, so but anyway, I. I tell you what, I'm going to read our guest is a is a coauthor on the book By God, if I were in charge. And I think what he wrote actually in his section really if I had if I thought about this before we did the Sage series, I probably would have used it as the introduction to the Sage series. It's really well-written. It summarizes, I think, what we're trying to capture. Christopher De Leon The importance of Sages Rhett Dotson Absolutely. And it says starting is speaking of grandchildren whether you are reading this early, mid or later in your life and career, you are probably working with people who are not too different in age from your grandparents, parents, children, or even grandchildren. Right. So, to our audience out there. Stop for a moment. Think about those people in your in your career, maybe even in your life that you're surrounded by that are same, same age as people, that you would consider mentors and or people you maybe get advice from you in your own family. And he says, what are you learning from them and what are they learning from you? And a little further down, he says, if you are younger, seek out the geezer down the hall. His words, not ours. He may not be as grumpy as he appears and may have some knowledge or experience that is useful to you if you are one of the geezers. Again, his words, not ours. Keep your door open, figuratively and literally. You are valuable not because you know things. You are valuable because you share that knowledge. Christopher De Leon If you share that knowledge, right? Rhett Dotson If you share that knowledge, that is such a great opening, such a great introduction to what we're trying to accomplish in this Sage series and why this particular individual we bring on. So, I think without further ado, we go ahead and bring him on. It's my pleasure to introduce the audience to Dave Johnson, better known as Dr. Dave, or more affectionately known as Dr. Dave. Christopher De Leon If you know, Dave Johnson, you know it's Dr. Dave. Rhett Dotson Indeed, you do. Welcome. And so, Dave, thanks for joining us today. Thank you. As he takes some time to get in his seat, I'll just say I've had the pleasure in crossing paths with Dr. Dave. Through many stages of my career, going back to when I was a consultant, as stress engineering and it's certainly my pleasure to have him on today. So, like I was saying welcome. Christopher De Leon Yeah, I've gone into his open door many a time when I had the opportunity to meet up Panhandle energy and learn a whole lot. So, geezers are funny and you can take a lot from them. Rhett Dotson And I think this particular geezer actually fairly cultured among other thing. So, we have a cultured geezer on the show, but that's not why we brought him ono today. We brought him on me. Please introduce yourself. Who are you? Why are you a sage in the industry? What brings you to us today? Dave Johnson Well, good morning. Thanks for having me. Yeah, I guess I'm considered a sage in the industry because I last a long time, and I know I really don't know how old you are, Rhett. I know about how old you are, and I know that you. You had not probably even been thought of when. When I started my career in this industry. I started a long time ago in with Northern Natural Gas in Omaha, Nebraska. In 1979. I was a refugee from the nuclear industry. It I joined northern shortly after the Three Mile Island nuclear incident, and it looked like the nuclear industry was not going to be very healthy and have a lot of career opportunities for a number of years. And I think that was probably accurate because I don't think any nuclear plants have been built since Three Mile Island. So. So I bailed out into natural gas at Northern in 79. Northern changed its name to inner north and inner north was one of the companies that that merged to form Enron. I think you probably all heard of Enron and Christopher De Leon Maybe not everybody has, right? Rhett Dotson Yeah. As I meet people now, they don't even realize Minute Maid Park was formerly Enron Field. There are a number of younger people. Christopher De Leon You might actually have some you might have some juice box, i.e. Enron field swag. I bet. Dave Johnson I have an Enron field cap. I have an Enron field opening day baseball. I have worn my Enron field cap to games at Mermaid Park. That is also which was kind of fun. It got, you know, some laughs and some kind of side eye looks. But that's okay. So went through the Enron, experience. And I don't regret going through that, but I certainly don't want to do it again. And then after Enron cratered and spun off the pipelines, we were acquired by Southern Union, which was the owner of Panhandle Energy. And then and then Panhandle was acquired by Energy Transfer. And, about the time we got, got deep. And several months into the COVID pandemic, it was time to retire. So, I pulled the plug and stayed home. Rhett Dotson Are you truly retired now? Dave Johnson I am retired. I've done a little bit of consulting, but not for a year and a half or so. So, we're just kicking back, doing some traveling, enjoying driving back and forth to see the grandkids do stuff and spend time with them. Rhett Dotson Well, congratulations. Well, we are happy to drag you back to offer your wisdom. Christopher De Leon But talk a little bit about yourself. So, for the audience, I mean, I think one of the things we like to do with our podcast is for people to get to know our guests, right? So, people feel like if you listen to us long enough, you know a little bit about Rhett and I and our families and what we like and don't like. Dr. Dave, what's your PhD in? tell us a little bit more about you because you were a nuclear then you went to pipelines. Like what was your focus? I'm, I'm a metallurgist and, and for, for, you know, any of you who are maybe still thinking about a specialty metallurgy is great. Yeah. Yeah, it it really is. If you actually want an answer to a question, you need to ask a one-armed metallurgist, because if you don't, he's going to say, well, on the one hand and on the other hand. Rhett Dotson And now the audience knows what I mean about Dr. Dave. Christopher De Leon Talk to your geezers. All right. They're good at telling stories and teach you something. Dave Johnson So, I my oldest grandson is a senior in high school this year. And it appears as though he is going to go to Texas A&M University and probably major in engineering, likely mechanical engineering. I have I have counseled him a little bit about metallurgy because you get all these engineering fields and they and they're all interesting and technical and useful. But you got the mechanicals and the electricals and the civils and nukes and all these folks. And they are all designing and building things and occasionally and, and inevitably some of the things that those guys and women design and build. Break occasionally but it's going to happen things break it's an imperfect world so when they break the metallurgist comes in to assist and do the materials part of the failure investigation. So, what the metallurgist gets to do is find fault and assign blame for it. It's a it's a great job. Christopher De Leon It's a great and it's rarely you. Dave Johnson So yeah, I, I got my Ph.D. in metallurgy at Purdue University who is currently occupying the number one spot in basketball. Which is as it should be. Rhett Dotson Until U oh H gets ahold of them. But that's another topic for another day. That's another topic for another day. Well thanks for sharing that. I do what. So, a lot of the sages that we've brought onto the show, obviously Rhett and I have some form of a relationship with them and, and I exactly said in the book is exactly what I remember. Right. So, I was a double e coming out of you of age and I got thrown into pipeline integrity and obviously we understand the threats and managing integrity program and I was very fortunate to have these sages right I had Doctor Dave, you there with us, I remember at the time. David McQuillan. Q On our corrosion side and Jerry Rau. So, I was very fortunate I'd come in and, and normally when you and I would interact is because we were trying to understand something that probably wasn't solved or, or lessons learned. So exactly what you said in the book is, it was what I remember talking to you and taking staple statements from you right? Things that I was able to latch on. The other thing that I remember is it's you're very active in the industry. You know, I remember you saying, hey, Christopher, you know, we're working on this initiative or this your project. I need you to do this for me right here. Hey, we're working at PRCI or we're working on this standard, so maybe you can walk us through a little bit of your history as it relates to your involvement, not just within a specific pipeline organization, but maybe some of the broader industry stuff. Dave Johnson Sure. I think it's important to be involved, to have to have the interactions to meet some of the people if for no other reason than when something comes up, crosses your desk or hits you in the face, out in the field and you haven't seen it before and there are some people that you can call and say, hey, have you ever seen one of these? Or what does this look like to you? So, yes, involvement and interactions are really important and they're probably three that I can think I'm going to leave something out probably. But with 40 but three it's three main areas that that people can be involved in to have these interactions. One is their industry trade associations. And those are organizations like, like ENGA and AGA and API. Yes. Yeah. And those, they get together and share information. Those organizations typically are also lobbying organizations, so they try to influence legislation and regulations, primarily at the Federal level. But, but some of the trade associations like the statements or regional ones, work with state agencies also. And some of them are more educational than lobbying, like SGA is more of an educational information exchange than say, Enga, which is lobbying a second group is the R&D arm of the industry is organizations like PRCI, GTI, Southwest Research. And there are others that that investigate phenomena and try to solve some of the that do the research to try to solve some of the industry's problems. And you meet a lot of really, really smart people in those organizations. And then the third one is the standards Development organizations. And API also does standards. But ASME, NFPA, the new AMP that right the standards and you like to have kind of a flow so if an issue is identified you want to do enough research on the issue that you have an adequate background knowledge. So, you know what a standard should say how, how to address the issue. And then you developed a standard. It goes through sometimes pretty lengthy development process to get it approved. And then you take that standard to the agencies or to the legislators and lobby to have that standard used as a basis for regulations or incorporated into the regulations. So that's kind of the idealistic way of how this this works. It doesn't always you know some sometime you see the regulation comes first and then you have to do the work to see is the regulation practical, is it achievable, can we do it? Does it make sense. Christopher De Leon I, I don't know how common this is. I mean Rhett and I are pretty involved in in the standards process. What are your thoughts on for some of our audience you know, do you need to be a sage or have ten plus years’ experience to contribute in any of these three groups that you talked about industry organizations, research organizations or standards committees? Dave Johnson You know, I think there are going to be people in those groups who have ten, 20, 30, 40 years of experience. But that's where you get experience and where you learn things. So, I think starting out, starting out as a young, relatively new engineer in the industry, it's a great experience to get involved in one or more of those kinds of organizations, too, to get to know people. You learn things and you'll go to meetings and come away. If you pay attention, you will come away with several things that you've jotted down that you did not know before. Rhett Dotson Yeah, I want to, I want to pare it off. Yeah, I'll put a brief plug for B 31 eight because I sit currently as the vice chair of O&M and B 31 eight. We interacted there in my early days on that. And you don't have to be an expert to sit on that committee. And we do have a significant need for more volunteers, particularly from the industry and I've been surprised at the number of things it's forced me to learn about. Right. So, what I mean is that often things come either inquiries into the 31 eight committee or recommendations for changes and the discussion can get quite hot. And usually, the hotter the discussion it means, the more than I need to learn. So, I've been forced to learn about things like why we do casings and vents a certain way, why they have to be metallic, the problems with nonmetallic casings. I've even learned other things about vowels and set points that I had no idea that as you get into a, you realize like, wow, it is a great way to meet people as well as to get information on topics that I otherwise would have very little interaction. Christopher De Leon You might have heard this for me a couple of times, and one of our former employers and we were building a pretty big team of integrity engineers. And at least my experience and my upbringing right was you have a team of complementary disciplines, right? And so, we had SMEs on our team when we were at Energy Transfer, Southern Union Panhandle, with people who focused on certain disciplines. And it allowed you to learn enough about your neighbors to be dangerous is kind of the way you thought about it, right? So, I was a little bit of a jack of all trades and my SME was in line inspection for ILI assessments. Right. And we were fortunate enough and I'm speaking to the audience now, we, I was pretty blessed to have the opportunity to participate in all three of those types of organizations that you mentioned. Right. So, participating in some of the, the consensus groups like API, getting to go to PRCI, getting to participate in in standards, but not that I was contributing to standards. But if not, I was asked to do tasks related to the standard. Like I remember running a project that you gave me, you were like, hey, we're looking at some of these mature properties and how it relates to the impact of hydrant testing. Can you go run this analysis for me? And so yeah, I had to run numbers, but the reason for the numbers really opened my mind up. I was like, well, this is great. I understand what we're trying to do. And I think it helps connect the dots. So, I would just encourage you guys, if you guys would talk, if you have a relationship with your mentor, with your supervisor, with the geezer down the hall or on a different floor, be courageous. Right. Raise your hand, ask questions, ask for an opportunity to get involved. And it doesn't have to initially mean that you can add value through your experience. But if not, you could be some of the working hands that help get tasks completed. And in that, I mean, it ends up becoming incredible, right? So just a little plug there and definitely agrees with you with your comment there. Rhett Dotson I think this is a good chance to ask, in all the time that you spent on standards and I know you were one of the people that had a lot of input into 31. You were around when PRCI was PRC, I assume? Dave Johnson Yes. Yes. Rhett Dotson And so, what do you think what are some learnings that you would share there in terms of how standard development has gone? We as an industry have approached maybe standards and regulations looking forward to the future like what are your thoughts on that? Dave Johnson The standards process, it generally tends to be a very deliberate process. The, the, the issues and you know from your time on B318 and I spent a lot of time on B 31 eight and B 318s the we used to joke about the, the glacial pace that that some of the items moved through. you know, here's, here's one from 2005 we're going to do this and word continues. So, it tends to be a very deliberate process and it is at times frustrating because people and companies and supervisors and managers, when they when they want something, they would prefer to have had it yesterday or on their desk when they came in this morning and not next week or next month or next year, we'll have that. So, there's always a push to get things done faster. But standards are one of the things that I think need to be done very, again, very deliberately. I keep using that word. Yeah, but with a lot of thought about where it's going and the potential for unintended consequences and action. Christopher De Leon I want to jump in there and maybe as an industry, us being more engaged sometimes I feel because there is a structure in the standards process, right? So, there are technical reports available where you can go in and see where industry has come together to research a topic and say, here are some of the findings we have. And then often you could see a technical report then evolves into an RP like a recommended practice, right? So, if we were to give you an example, there, API, RP 1183 is the recommended practice for dents, but then after the RP is vetted, then it can become a standard, right? So, you don't always have to jump to the standard, right? That there is a process in the standards making that allows for experience and maturity of what we're proposing. Right? And then it can become a standard like API standard 1163, which is how we qualify ILI systems. Rhett Dotson You know, it's interesting, I have to jump in because you mentioned 1183. I happen to settle 31 eight and 1183 and the way those two so one is a consensus standard. And the other behaves very differently. 1183 was developed opposite of glacial and opposite of deliberate, opposite of deliberate. And we are fully in the middle of seeing the challenges with that now. Right. And the number of consultants that have raised concerns about the methods, the structure, the use of 1183 totally different process, consensus voting, majority wins type thing, I think you need two thirds are sitting on a ASME B 31 eight. Speaking to Dave's point, it is often frustrating because you need unanimous consent to get things passed. And oftentimes I find myself arguing with one individual who will hold things up that I have to convince them of the technical merits or why that's the case. On the flip side, I will say. Dave Johnson I’m not on committee anymore. Rhett Dotson No, you're not. It's key. Don't tell. But it's key. But it's it is surprising. You know, you don't see that is that is a standard B 318 that has endured the test of time, if you will. And so, I really will. I find very, very close to my heart what Dave is speaking about sometimes that glacial pace, while frustrating, is so important. Christopher De Leon Yeah. And again, for you guys, the takeaway, right, is it's when you grab when you grab a document, it is important for you to appreciate how the document came about and what its intent is, right? So, if you see a technical report or you see an IPC paper or you see a report from PRCI or it's an RP, a recommended practice or standard right? Just have an appreciation for what document am I reading and then having appreciation for what is that possible path that it took to get that document published before you use it? Dave Johnson Well, you mentioned the dents standards and the dents, dents are very interesting that that whole subject and I think it leads us to thinking, okay, let's once we get a standard, let's make sure that we understand that we still may have some things to learn, that that may impact that standard or how we apply it. Dents for years and years and years, we in the industry said plain dents that that our relatively shallow and innocuous. Christopher De Leon Just recode them. Dave Johnson Yeah, just recode and go if the coding is damaged if the coding is not damaged, just leave it alone. Back fill it and go well then. Not to me. Christopher De Leon For the record Rhett is very uncomfortable right now. Rhett Dotson I’m thinking of the Centerville episode from The Failure files. Trying to keep a straight face. Dave Johnson Well, I'm sorry because we didn't talk about this going here, but. But I but I think it's an important illustration of we need to keep our eyes and our minds open to things. Maybe, you know, something happening that you think that that shouldn't have happened. That's not right. That's and but it but it is. And you may have to change your mind about things because what we found over the last several years is that in even in shallow, dents we can nucleate fatigue cracks and depending on the nature of the dent and how the stresses are applied, the fatigue cracks can be longitudinal or they can be transverse and they can occur in the bottom of the dent or up on the shoulder of the dent and what they look like when the metallurgist or just look at them, look at the surface Christopher De Leon One armed or two armed? Dave Johnson Two, always two. They look like little colonies of stress, corrosion cracks because you may get multiple cracks nucleated So my personal opinion is that that over the years over the decades there have probably been in pipelines where we have found some of these things a number of crack families that have been classified as stress corrosion cracks that were actually fatigue cracks. Rhett Dotson You know, I wonder at that point if it's because they went to the metallurgist and asked them, and he said, it depends. But in order to know that we're going to take a break and you have to come back to hear the answer to that question. We'll be right back. All right. Welcome back to Pipeline things with our esteemed guest, Dr. Dave. So, when we left you, we were in the middle of discussing Doctor Dave brought up some of the challenges that can happen when you rush a standard. And I immediately gravitated. Chris incidentally, brought up 1183, but I was very clearly able to relate, you know, 1183, verse 31 eight and the differences in the speed with which those were developed and that is something that is ongoing of the industry is working through. Christopher De Leon But maybe not the speed they were developed, maybe how changes managed, right. Maybe how 1183 was developed. But how b318 is potentially being changed. Rhett Dotson Let's just say the development processes as a whole. One is glacial, one moves rapid pace. One is majority consensus one there you have near uniform. Dave, you kind of had your own experiences nearly 24 years ago, I guess, in the development of 318S. And I'd like for you to share a little bit, maybe help our audience understand briefly the history of 318S and it was a similar, very quickly assembled document, was it not? Dave Johnson It 318s I think at certainly at the time I believe it was the fastest first publication of the standard that the ASME had done, at least in in the pipeline area. It was about a year. Rhett Dotson From start to finish, 318S. Dave Johnson Yes. Yes. And it was a very intense year. We had meetings with the regulators and with the advisory committees. The you know, at the time it was called TPSSC. I think it's the Transmission Advisory committee or a gas transmission advisory committee. There's gas and liquid committees. But we had meetings with them about every month, every month to six weeks for a period of about a year. And in those meetings, we would bring in our researchers and present the work, whatever the topic was, if the topic was dents or corrosion or stress, corrosion cracking or third-party damage or whatever, the subject was, we would bring in the people who had done the work on that subject for us for PRCI or at ENGA the foundation and research any of the research organizations. So, these are people like and I don't mean to leave anybody out, but it's people like Brian Leese, Battelle, John Keefner, Bill Bruce and Denby and the other folks there, maybe some Southwest research and others certainly. But people of that caliber were coming in to present what, you know, their work and their conclusions on uncertain areas. So, we were trying to set a background for the regulators so they would understand what we were writing in the standard. So, we wrote it then very quickly and we had different little task groups for different sections that that put it together and then then tried to edit it. So, it all fit the ASME templates and style guide and, and all that and looked like it was done by one author, not by a whole bunch. Rhett Dotson I want to ask you, it's 20 years later. Is it surprising how I almost want to say central that document has become I mean because there are tenets in there that are like Moses came down off of the mountain with them. Dave Johnson Yeah. Rhett Dotson Did you envision when you were writing it that it would be that I don't want to use the word lasting, but that had that kind of permanency. Dave Johnson We I think we thought that it would it would be a lasting document. I think we didn't anticipate it being a essentially so set in stone so early. You know it Moses didn't bring this down this this was not engraved in tablets of stone. It's a document that we did the best we could with what we had and the time that we had to do it. And again, we were under the industry was under a lot of pressure to develop this standard very quickly because the integrity regulations were upon us and the regulators wanted something. Christopher De Leon So, can we highlight that a little bit? Can you maybe elaborate on what that relationship looked like? What was the role that the standard B 318S had with the formulation of regulation? Dave Johnson The regulators FEMSA was under the gun to write integrity management regulations and we met with them in late 1999 and said okay, we'll we will help you with this and will develop a standard but that you need to go along with this and we'll keep you up to speed and we'll have meetings and exchange information and do all of that. So that's what we did and it was a relatively collaborative process between us and the regulators as we wrote the standard. But that's not to say that I'm like in any organization. There were there are some people in FEMSA who didn't like it from the beginning, didn't like the process, and thought that industry had had too much say in in what was going into it. But we did it very quickly. And some of the points of contention, I think, exist to this day. Rhett Dotson And are very difficult to change, if you will. And that was my joke about Moses coming down off the mountain is like, you know, probably the most famous one. We talked about it several times as the figure for it's no longer figure for, but everybody knows it is the figure for it. There are better methods now for determining reassessment intervals, some that have even gone through the research organizations. Mike Rosenfeld put forth a ballot to have it changed to an equation that better reflects corrosion growth. My God, Dave, you to try and get that pass through is like heaven on earth. We've been working. We've been working on it for almost three years. Right. And it is so that glacial pace you see there in that. Right. The I think another one that immediately comes to mind is the permanency of the 21 threats that were existed there. They're almost like the Ten Commandments, literally. It's like there are 21 threats and thou shall have no others. And I don't think when you all wrote it, you intended that. But it's it is amazing that once something like that is put together the permanency and the challenges you can experience as an industry and trying to then modify that after the fact. Dave Johnson Well, and even in how we talk about it, we talk about the 21 threats and we have now regulations and companies have in their policies and procedures on how they do things. These things are all woven throughout that. And to make any sort of significant change is a major upheaval for. A lot of people it's a major change in the regulations, it's major changes in companies, policies and procedures in the written documents and perhaps some major changes in how they have to do things, the things that they have to do. But it those, again, in my opinion, have caused us some issues in how we talk about these things and how we address them. And I in my last couple of years before I, I bailed out of all of this, I was advocating relooking at these and moving closer to two root causes rather than rather than proximate causes Christopher De Leon I.E the why does the coding keep failing not why do you have corrosion on the pipeline, or assessing for corrosion? Dave Johnson Right. Christopher De Leon I want to I want to maybe tie in one of our previous podcast series. So, the one we just finished was called Failure Files, where we looked at several NTSB investigative NTSB investigations and how that led to some of the current regulations that we have. What are some of your thoughts on maybe the role or timing or relationship between industry develops a standard and regulation potentially using that standard to govern versus what I would say over the last 15 years, The trend is really more it feels like we're not leveraging the standard like we did with B 318S 2004, which is still incorporated, but rather we're not really turning to standards anymore. It's really, it's management by consequence. you had a failure on this mode I.E material properties. Now here's regulation 20 your properties. You had a failure on dents. now here's how we're going to regulate dents. You had a failure in a non-HCA. Here's how we're now going to manage non-HCA areas. What are your thoughts about that relationship in the role? And basically, as time goes, the timing right, timing, the standards development. Dave Johnson The timing is difficult. And I think the regulators have a lot of pressure because they get NTSB recommendations from the failures and they get congressional mandates. And they pretty much have to respond to those or they get bad grades and they get their administrator gets, you know, public publicly beat up in congressional committee hearings. And I think, you know, you can go back and find some of that on YouTube and it's painful. Some of those are painful to watch. Now so that they're kind of maybe in it maybe this too strong word, but they're kind of in self-preservation mode. They but they have to respond to those things. But what happens is and I'll use a different dot mode for this TSA and, you know, don't get me wrong, I love TSA. And, you know, I really like they're Christopher De Leon I am very curious where this is going. Rhett Dotson I am so curious. Dave Johnson Their scanners and all that. Yeah, it's really fun especially if you've got a lot of titanium in your body. The, the, some of the things that have been done for safety the by TSA for airlines and this this isn't something I made up Yeah you can find articles on this what their regulations do is prevent the last incident. So, there was there was the shoe bomber got so you know so now you got to regulation. You got to take off your shoes and have your shoes inspected. So, and it it's really kind of understandable because when you have something like that, you want make sure that it doesn't propagate, that you don't have it again. And the of course, the big one for the gas transmission industry was the incident in San Bruno. And that drove a lot of the regulations that have been coming out now. And those regulations were a long time coming from the notice of the advance notice of proposed regulation, which they got comments on in the notice of proposed regulation. And then it was split into multiple parts and had all the comments on that. And that was a long-drawn-out process. Some of the comments that they got, they accepted, some they didn't. That's how things go. But you're right, Christopher. That's the incidents were driving the regulations and it's you know it and I've never been a huge, you know, defender of FEMSA but in this case in many instances it is it's not their doing and it's probably not the way they would prefer to do things. But they get mandates that, you know, you have to okay this these things happened And the NTSB report found these deficiencies. So, you make regulations about those things. Rhett Dotson And, you know, I don't think we have much control over FEMSA and congressional mandates, but we do have control over sometimes where our industry is maybe heading now. And so, as we wrap up this episode, I want to leave our listeners with a thought because they've talked about 318S and it being developed in response to it at that time. Notable failures and the need for regulation and it was rushed. I have my own experiences with again 1183 and these aren't the only issues that we're facing, right? So, as an industry, I want you guys to think we're facing the advent of CO2. There's nothing really governing CO2 pipelines right now, hydrogen and blending, right? There's a huge push to rapidly get an ASME standard to govern that. So, if you're serving in those standards or if you're participating, ask yourself maybe is there a place for that glacial process or where do the principles of that glacial process maybe need to fit to prevent, you know, some of what we talked about here? And that's again, I want to leave the audience at that cliffhanger. I don't want to address that. I just want you to be thinking about that as we close out this podcast and maybe in the rest of your ride home or wherever it is, you find yourself listening to us. But I do want to say, Dr. Dave, thank you so much for joining us. Dave Johnson Thank you, guys. Rhett Dotson Well, this will not be called the Geezer series. This will remain the sage series, but myself. Christopher Dr. Dave, I want to thank you for joining us on Pipeline things look forward to being back to you in two more weeks.