A decade in the making, but it’s finally here. In the wake of incidents like the 2010 San Bruno pipeline explosion and the 2012 Sissonville rupture, pipeline regulations are being updated to put a bigger emphasis on public safety and the environment. Pipeline owners and operators are well aware of the significant overhaul to the Pipeline And Hazardous Materials Safety Administration’s (PHMSA) regulations, specifically Parts 191 and 192.
The recent changes mean that previous regulatory compliance strategies for assets in the United States may not translate well to this new set of rules, especially considering the much broader scope of the new initiative. The most recent version of the PHMSA regulations, widely referred to as the ‘Mega Rule’, provides changes to many facets of manufacturing, laying, operating, and maintaining pipelines.
The following discussion deals with changes brought about by the ‘Mega Rule’ with a specific focus on corrosion management, including guidance on how to stay ahead of the current and anticipated regulatory requirements.
Addressing the PHMSA ‘Mega Rule’
The ‘Mega Rule’ represents a significant expansion of the scope of PHMSA’s pipeline regulations. While the strict operating conditions of most pipelines ensure that issues are rare, the catastrophic consequences of pipeline failures have been the catalyst for a few distinct changes.
Two of the most cited influences of this change were the San Bruno, CA and Sissonville, WV pipeline explosions, each of which, tragically, resulted in loss of life. In both instances, overly-lenient regulatory requirements were considered a core finding of the post-incident investigations, driving PHMSA to action.
One of the more impactful changes brought about by the ‘Mega Rule’ was the expansion of pipeline integrity management requirements. These requirements previously only focused on pipelines located in High Consequence Areas (HCAs), but the ‘Mega Rule’ changes have both expanded requirements to include Moderate Consequence Areas (MCAs) and expanded the definition of HCAs. HCAs now make up 9% of all PHMSA regulated pipelines in the USA, a 20% increase in mileage compared to HCAs before the ‘Mega Rule’ update.
This expansion is meant to cover instances such as the Sissonville, WV explosion of 2012, which previously didn’t constitute HCA classification, but would now fit into that definition. Likewise, the addition of MCAs is meant to protect the public in more rural settings, such as would have been the case in the 2007 explosion at Interstate 20 near Delhi, LA as well as the 2016 explosion in Westmoreland County, PA.
The ‘Mega Rule’ also features new requirements for records that specify a pipeline’s Maximum Allowable Operating Pressure (MAOP). All pipelines located in HCAs and MCAs with existing MAOP validation records need to be verified by a regulator. If the records do not exist, documentation needs to be created for them. This change will mean testing for all pipelines that fit under §192.465 and do not have up-to-date integrity records, even if they were previously exempt from these requirements.
These changes and others, such as reductions to the allowable pipeline leak response times, are meant to encourage a preventive maintenance approach that focuses on proactive assessment and careful monitoring in order to ultimately improve public safety.
Implications for Cathodic Protection
The significant increase to the length of pipeline regulated by PHMSA and the greater requirement for MAOP testing are just two elements. Other aspects include leak detection requirements and the handling of geohazards. Considering the breadth of the Rule, it may be easy to overlook a subtle change with major implications: that CP monitoring can now be performed largely through remote monitoring.
Voltage and amperage output measurements must still be performed at least six times a year at intervals not to exceed 2-½ months in order to ensure compliance with CP design requirements. Excitingly, §192.465 states that this can now be done through remote measurements, so long as a physical inspection is carried out by an operator at least once per year.
This change to accommodate modern CP data collection techniques means timely continuous monitoring is simpler than ever. While a physical inspection is still expected annually, this change is indicative of a major growth trend toward the use of remote monitoring, along with confidence that the measurements provided by remote monitoring units (RMUs) are accurate and reliable for operators.
As pipeline regulations continue to expand in both scope and stringency, the need to rely on autonomous operations and remote monitoring systems will undoubtedly increase. However, operators may understandably find the unrelenting influx of CP data available from dozens, hundreds, or even thousands of data collection points overwhelming, effectively negating its value. This challenge highlights the need for advanced IIoT software platforms that are coupled with innovative field sensing solutions, such as cloud-based AI (artificial intelligence) and ML (machine learning) systems that can effectively process massive volumes of data and uncover new trends and optimizations. This will empower operators to more easily and effectively manage an expansive CP system as well as meet regulatory requirements, today and in the future.
Future-Proofing Your Integrity Program
The additional safety measures featured by the ‘Mega Rule’ highlight the importance of taking proactive mitigation measures. Regular integrity monitoring gives an early warning for integrity issues, helping pipeline operators to not only prevent pipeline-related safety incidents, but also to reduce overall maintenance costs.
While increased monitoring can create a clearer picture of integrity status for operators, it also adds complexity. Spotting problems, making them actionable, and tracking their status can easily become overwhelming. Selecting a remote monitoring system that is supported by a comprehensive data management platform alleviates the need for operators to perform data analysis themselves and assists in managing and tracking operational deficiencies.
The MOBILTEX CorView Cloud Platform works as an all-in-one cathodic protection data management system, ensuring you can easily access complete and reliable compliance records that meet the data retention requirements of Part 192 of the PHMSA regulations. CorView gives operators round-the-clock access to any of the data collected by MOBILTEX’s full portfolio of RMUs.
MOBILTEX’s CorTalk RMU products can also be used to remotely capture instant-‘off’ data at specific test points or to complete GPS-synchronized interruption of a series of rectifiers in order to make cathodic protection surveys simpler and more accurate than ever before. MOBILTEX offers a holistic approach to cathodic protection monitoring, so you can capture and maintain detailed records of rectifier outputs, test station ‘on’/‘off’ values, coupon readings, and more. MOBILTEX solutions are also being used to monitor and alert operators to potentially catastrophic CP interference from high voltage power lines (HVPLs) and Transit systems. In addition, forward-thinking operators are leveraging this efficient backhaul to add additional remote sensing technologies in areas that have been cost prohibitive or technically impossible in the past.
Refer to the list below for a quick reference of features available in the CorTalk RMU solutions and Contact a MOBILTEX representative today to find out how our products can improve safety, lower operating costs for your operations, while optimizing the performance of your cathodic protection systems.
|CorTalk RMU3||Rectifier interruption, voltage output readings, current output readings, potential readings||Rectifiers|
|CorTalk RMU2||Voltage output readings, current output readings, potential readings||Test posts, rectifiers|
|CorTalk RMU1||Potential readings, coupon readings, bond readings||Test posts|
|CorTalk RMU1-LITE||Potential readings (including instant-‘off’)||Test posts|
|CorTalk RMU1-SUB||Potential readings||Subgrade test posts installed on farmland, in urban areas, or on roadways|
|CorTalk RMU1-ER||ER probe metal loss readings||Pipes and casings|