Internal Corrosion Management
PHMSA’s Mega Rule Requirements for Pipeline Operators on Internal Corrosion
We have the answers: Is your current internal corrosion program effective?
Many operators have already taken strides to incorporate the Mega Rule requirements into their operations and integrity management plans. The Mega Rule requires pipeline operators to manage external and internal corrosion. To prepare for the changes, operators will need to plan, especially if there’s no formal corrosion management program in place.
However, as part of Mega Rule II (Gas Final Rule, August 24, 2022), operators must have a program for managing internal corrosion. Reducing the risk of metal deterioration is paramount. But the Mega Rule is about more than updating mitigation strategies—it’s about transparency and how much the regulator trusts the data behind your integrity decisions.
Learn more about meeting the Mega Rule’s internal corrosion requirements in the following discussion.PHMSA’s Mega Rule Requirements
The Final Rule
The PHMSA final rule amended the Pipeline Safety Regulations 49 CFR parts 191 and 192 to introduce reporting requirements for previously unregulated Types C and R gas gathering pipelines along with safety standards for Type C gas gathering pipelines. This article explores the key requirements and timelines that pipeline companies must adhere to, with a specific focus on managing internal corrosion and ensuring compliance.
Adhering to PHMSA Mega Rule Requirements and Timeline:
To comply with the PHMSA Mega Rule, pipeline companies must meet specific requirements within designated timelines:
By July 21, 2023
Implement an Integrity Management Plan (IMP) and document all required procedures.
By July 3, 2028
Verify 50% of pipeline mileage
By July 2, 2035
Verify 100% of pipeline mileage.
Additionally, this ruling requires that records confirming MAOP (Maximum Allowable Operating Pressure) and material properties be traceable, verifiable and complete.
As part of Mega Rule II (Gas Final Rule, August 24, 2022), operators must have a program for managing internal corrosion. Reducing the risk of metal deterioration is paramount. But the Mega Rule is about more than updating mitigation strategies—it’s about transparency and how much the regulator trusts the data behind your integrity decisions.
How can operators comply with the Mega Rule’s internal corrosion requirements?
Monitoring & Mitigation
Each operator of an onshore gas transmission pipeline with corrosive constituents in the gas being transported must develop and implement a monitoring and mitigation program to mitigate the corrosive effects, as necessary.
Thanks to the Mega Rule, all operators need an internal corrosion program. And for those who do not currently have a program in place, it means creating one. What if you don’t have corrosive constituents in your gas stream? PHMSA still wants monitoring data to prove it.
Creating a program to manage internal corrosion will impact several departments across an enterprise: human resources, pipeline operations, and data management, to name a few. Depending on how you’ve structured your pipeline integrity team, internal corrosion management could fall under the responsibilities of an existing group, or you may need to create an entirely new team.
PHMSA’s Mega Rule has recommendations for internal corrosion monitoring and mitigation. Activities and equipment include:
- Product sampling
- Inhibitor injections
- In-line cleaning pigging
Typically, sampling uses coupons inserted into the gas stream and you may need to install coupon sampling facilities
Mitigation can also drive the installation of physical infrastructure, such as pig launchers & receivers, injection sites, or separators.
To manage all these activities, the regulator expects to see a process around internal corrosion management. Your process should account for sampling results, operational factors, and ongoing mitigation tasks. And, of course, PHMSA may ask for proof that you’re following your procedures.
With a comprehensive data management solution, you’ll be able to track your internal corrosion monitoring and mitigation activities. Accessible record-keeping will smooth workflows and help with proving compliance.
An operator must evaluate the partial pressure of each corrosive constituent, where applicable, by itself or in combination, to evaluate the effect of the corrosive constituents on the internal corrosion of the pipe and implement mitigation measures as necessary. Potentially corrosive constituents include, but are not limited to: carbon dioxide, hydrogen sulfide, sulfur, microbes, and liquid water, either by itself or in combination.
Before you can evaluate the partial pressure of corrosive constituents, you’ll need access to the relevant data. Keeping records in a centralized database (versus multiple spreadsheets) makes corrosion monitoring information easier to access so you can get to the evaluation step faster. Consolidated storage also maintains data integrity by eliminating the disadvantages of data silos.
Internal corrosion-related datasets include:
- Coupon results
- ILI information
- Chemical injections
- Biocide injections
- Pipeline flowrates
Digital record-keeping and tracking have advantages besides speeding up workflows—they also make fulfilling information requests easier. For example, managers, internal stakeholders, or auditors may ask about a monitoring point on a particular day, or for the results of a specific analysis.
—data is king when it comes to regulatory compliance. An internal corrosion program only meets requirements if you can show that it meets requirements.
An evaluation at least once each calendar year, at intervals not to exceed 15 months, to ensure that potentially corrosive gas stream constituents are effectively monitored and mitigated.
As part of the Mega Rule, PHMSA expects operators to evaluate their internal corrosion programs. But it’s up to an operator to define the criteria that determines whether or not their program is effective.
Establishing a comprehensive evaluation process shows you’re committed to assessing your internal corrosion program, which auditors appreciate. With a solid foundation of high-quality, easily accessible data, engineers can dive into program details to examine the state of internal corrosion.
In addition to supporting the evaluation process, digital record-keeping enables an integrity team to answer high-level program questions from internal stakeholders. For example, upper management might ask:
- What does our chemical program look like?
- Are we using enough biocide?
- Is pigging being carried out at the right frequency?
- Aligning monitoring data with other datasets, such as chemical program details, ILI results, and operational info, provides insight into corrosion program effectiveness.
Internal Corrosion Management (ICMS) / CIM
Meeting the Mega Rule’s internal corrosion requirements is no small task, especially if you don’t already have a program in place.
OneBridge’s Internal Corrosion Management System (ICMS) module gives operators a single, intuitive view of what’s happening with their internal corrosion program on a system level. It’s an advanced software platform that helps align, track, and manage corrosion data.
Get in touch
The CMS is an out-of-the-box data management solution that sits within the Cognitive Integrity Management (CIM) platform. Want to know more? Learn more about the benefits of OneBridge’s ICMS and CIM platform.
The Business Value of Dedicated Internal Corrosion Management
Internal corrosion is a threat when water is present; an operator needs program-specific data and analysis to evaluate the effectiveness of mitigation measures. CIM’s Corrosion Management System focuses on internal corrosion management to help fine-tune your strategies to optimize budget and chemical performance.