Can I perform an assessment using an MFL tool without also running a deformation tool?
Yes, if certain other actions are taken. MFL tools can detect the presence of dents, but not reliably size them. Thus, PHMSA Pipeline Safety considers that any indication of a dent found using an MFL tool is potentially a defect meeting the repair criteria in the rule, until the contrary is demonstrated. PHMSA Pipeline Safety will accept an assessment conducted using an MFL tool without a concurrent deformation tool run if the operator specifically directs its ILI vendor to identify all potential dents. All such potential dents must then be excavated and examined, and those meeting rule repair criteria must be remediated. If all potential dents are not excavated, then a subsequent assessment using a deformation tool or hydrostatic test must be conducted on an expedited basis.