PHMSA Mega Rule RIN-2 - Changes in Cathodic Protection New Requirements for Interrupted Surveys and Deadlines

THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION (PHMSA) IS SET TO MAKE EFFECTIVE STAGE 2 [RULEMAKING IDENTIFICATION NUMBER 2 – RIN 2] OF THE GAS MEGA RULE REGULATION ON MAY 24, 2023 [SOME LIMITED ENFORCEMENT DISCRETIONS IN PLACE]. THIS UPDATE WILL INTRODUCE SIGNIFICANT CHANGES TO THE REPORTING REQUIREMENTS FOR PIPELINE OPERATORS WITH NEW RULES THAT AIM TO ENHANCE PIPELINE SAFETY AND TRANSPARENCY, FOCUSING PARTICULARLY ON GAS TRANSMISSION PIPELINES.

PHMSA has revised section 192.473 to mandate interference surveys for pipelines affected by stray currents. Presently, operators managing pipelines exposed to stray currents must implement a program to minimize the harmful impact of these currents. Now, operators with these potentially at-risk pipelines must conduct an interference survey to quantitatively assess the presence and intensity of interference currents. The Rule stipulates that an interference survey must be performed when monitoring indicates a substantial increase in stray current or when new potential sources of stray current are introduced.

Operators are required to analyze the survey results to identify the cause of the interference and formulate a remedial action plan to rectify any deficiencies if the current is equal to or exceeds 100 amps per meter squared, or if it hinders the pipeline’s safe operation, or if it could potentially create a condition that negatively impacts the environment or public safety. Operators must complete the remediation as soon as possible, but no later than either 15 months after completing the survey or within six months of obtaining the necessary permits, whichever comes first.

While operators are already obligated under § 192.465(d) to swiftly address any corrosion control deficiencies identified during cathodic protection (CP) monitoring, PHMSA has now introduced a requirement for onshore gas transmission operators to devise a remedial action plan for both localized/non-systemic and widespread/systemic corrosion control deficiencies detected by CP monitoring and apply for the necessary permits, within six months of discovery. Operators must complete the remedial action as soon as possible, but no later than the earlier of (1) the next inspection or test interval; (2) within one year, not exceeding 15 months, or (3) as soon as practicable, not exceeding six months after obtaining any required permits.

In situations where an annual test station reading indicates insufficient cathodic protection below the levels mandated in Appendix D, operators must examine the geographic scope and causes of the low CP levels to determine whether there are systemic/widespread or non-systemic/localized areas of deficient CP. Operators are required to conduct close-interval surveys (CIS) to identify the pipe segments in need of CP remediation. The CIS must be carried out with the protective current interrupted unless technical or safety reasons make it impractical. Following the remediation of pipe segments with inadequate cathodic protection, operators must promptly confirm the restoration of sufficient cathodic protection levels.

One critical aspect of the Mega Rule RIN 2 release involves the survey activities required when captured cathodic protection readings are out of range, necessitating the use of interruption techniques. When captured cathodic protection readings are out of range, pipeline operators are required to perform the following survey activities involving interruptions:

• Instantaneous Off Potential (IOP) Surveys:
  • IOP surveys are used to determine the effectiveness of a cathodic protection system by interrupting the current and measuring the pipe-to-soil potential at the instant when the current is turned off. These surveys provide valuable information about the level of protection achieved and help identify areas where cathodic protection may be insufficient.

• Synchronized Interruption Surveys:
  • These surveys involve interrupting the cathodic protection current simultaneously across multiple points on the pipeline. This enables operators to obtain a clearer picture of the overall system performance and identify any areas of concern where the protection may be inadequate.

• Coupon Test Stations:
  • Operators must install and monitor coupon test stations to measure the effectiveness of the cathodic protection system in real-time. These stations consist of a small, isolated section of the pipeline exposed to the same environment as the main pipeline. By interrupting the cathodic protection current and measuring the potential on the coupon, operators can evaluate the performance of the cathodic protection system and make necessary adjustments.

• Remedial Actions:
  • Based on the findings from the surveys involving interruptions, operators must take prompt remedial actions to address any identified issues. This may involve repairing or replacing faulty equipment, modifying the cathodic protection system design, or implementing additional corrosion prevention measures.

• Follow-up Surveys:
  • After implementing remedial actions, operators must conduct follow-up surveys to ensure that the cathodic protection system is now operating within the acceptable range. These surveys will confirm that the implemented solutions have effectively addressed the issues identified in the initial out-of-range readings.

• Documentation and Reporting:
  • Operators are required to document all survey activities, findings, and remedial actions taken involving interruptions. This information must be submitted to PHMSA as part of the enhanced reporting requirements under Stage 2 of the Mega Rule Regulation. Proper documentation ensures that PHMSA remains informed of the pipeline’s condition and any actions taken to address potential issues.

RIN-2 rules place a greater emphasis on cathodic protection survey activities involving interruptions when readings are out of range. Pipeline operators must proactively identify and address issues to ensure the safety and integrity of their infrastructure. By adhering to these enhanced reporting requirements and conducting comprehensive investigations, operators can minimize the risk of corrosion-related incidents and maintain the highest pipeline safety standards.

The bottom line is gas pipeline operators are now required to have a more rigorous external corrosion management plan in place to limit the effect of electrical interference through additional surveying and assessment activities in order to ensure adequate cathodic protection. The time is now for forward-thinking operators to leverage and expand existing fleets of rectifier and test point remote monitoring technologies into more challenging applications where interruption would be required like extremely remote sections of pipeline, bond locations, co-located assets with High Voltage Power Lines and Transit Systems, and properties requiring permits to install (and retrieve) interrupters temporarily during surveys.  The most advanced RMU platforms have been engineered to deliver powerful automation capabilities to meet these and future requirements, optimize interruption capabilities at both rectifiers and test points, offer a wide range of fit-for-purpose devices, and have the ability to effectively capture readings at much higher resolutions.

The RMU ROI interval is about to decrease dramatically with these new surveying requirements — qualifying the initial CAPEX expenditure is easier than ever before and empowers operators with the data needed to further optimize all aspects of their asset protection program, all while dramatically reducing YoY OPEX expenditures and improving safety for their operations.

Furthermore, operations that move quickly to transition from traditional prescriptive approaches to proactive data-driven RMU platforms, that can effectively leverage AI to predict adverse conditions, will see the greatest overall benefit by adopting the most cost-effective processes to maintain compliance and minimize potentially spurious surveys and assessments on their assets, and also prevent catastrophic failures and ensure the integrity of their systems.

MOBILTEX’s CorTalk RMU Platform Solutions  remotely execute complete GPS-synchronized interruption on a series of rectifiers and test points 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, including Fast Sampling capabilities at challenging at-risk applications. 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.

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 all 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.

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 and future-proof your operations, all while optimizing the performance of your cathodic protection systems.