MEGA Rule, Pipeline Data, Corrosion
Atmospheric Corrosion Control with CIM
Atmospheric Corrosion Control US Regulations
The Code of Federal Regulations (CFR) outline specific requirements for monitoring and controlling atmospheric corrosion on hazardous liquid pipelines under CFR §195.583 and §195.569 and for gas pipelines under CFR §192.459, §192.479, and §192.481.
For hazardous liquid pipelines that are exposed to the atmosphere, each exposed pipe location shall be inspected for the presence of corrosion per the following intervals:
- Onshore pipelines: at least once every 3 calendar years, not to exceed 39 months.
- Offshore pipelines: at least once each calendar year, not to exceed 15 months.
For both hazardous liquid and gas pipelines, a corrosion inspection shall be conducted anytime a buried pipeline is found to be exposed for example, if, during a ROW survey, a portion of the pipeline that was buried is now found to be exposed, an inspection shall be conducted for external corrosion as soon as practical. If a pipe is exposed on a seasonal basis such as a waterbody crossing, it should be added to the operator’s atmospheric inspection list and inspected per the time intervals below.
For known locations where a gas pipeline is exposed, an inspection shall be performed for:
- Onshore pipelines: once every 3 years, not to exceed 39 months.
- Offshore pipelines: once every year, not to exceed 15 months.
- Onshore service lines: once every 5 years, not to exceed 63 months.
These inspections should pay close attention to those areas of the pipeline that are typically prone to atmospheric corrosion, such as soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water. If corrosion is detected, action shall be taken per §195.581 (for hazardous liquid pipelines) and §192.479 (for gas pipelines).
Pipeline operators are tasked with identifying and inspecting pipelines exposed to the atmosphere regularly and mitigate any corrosion that’s found per regulations and best practices. On top of that, recent Rule updates from the Gas Mega Rule Part 2 published August 24, 2022 and the Liquid “Mega” Rule published October 01, 2019 require that operators “gather and integrate” an extensive list of data elements encouraging the industry to “go digital” with all their data. Operators need a robust system that can digitally capture data from atmospheric inspections, analyze said data to determine if mitigation measures are needed and track/manage such actions to close the inspection loop.
Digital Data Collection
Now with CIM’s NEW External Corrosion Module, users can capture data from their atmospheric inspections with a digital form. Informed by input from industry leaders, the form incorporates all relevant data fields to create a comprehensive atmospheric inspection report. This form can also be set up to auto populate certain fields via a seamless integration with Pipeline Open Data Standard (PODS) and Utility Pipeline Data Model (UPDM).
The accompanying mobile data collection application facilitates easy capture and recording of atmospheric corrosion conditions and inspection results. Users can take advantage of on-device camera systems to upload an unlimited number of photos and utilize on-device GPS for precise inspection location information. The form can also be used to capture inspections for various asset types, including above-ground piping & appurtenances, spans, tanks, exposed pipe, and pipe under thermal insulation as well as different coating materials - providing a comprehensive solution for your inspection reporting needs.
Your team of corrosion technicians can now create atmospheric inspection reports straight from their phone. There are no constraint on the number of users, providing flexibility in team size.
Analysis & Mitigation
Once reports are uploaded into CIM, they’re analyzed to determine whether inspection results fail to meet the required standards. To that end, the system mandates users to provide comprehensive descriptions and mitigation strategies when required. These serve as checkpoints, guaranteeing that any inspections yielding subpar outcomes receive immediate attention and appropriate mitigation measures. By enforcing detailed documentation and action plans, our system not only prevents oversight but also fosters a proactive approach to addressing potential issues, thereby bolstering the overall effectiveness and reliability of the corrosion control program.
Dashboard and Reporting
A pre-built dashboard shows assessment results and action items, allowing users to drill up or down for in-depth insights into specific pipeline systems. In addition, users can create a customized Power BI dashboard with all inspection data. Digital reports allow for mapping functions, enabling spatial visualization of the data, and a report in PDF format is readily available to support regulatory audits and internal reviews.
Inspection Planning
Manage your atmospheric inspection program by tracking upcoming inspection dates within the External Corrosion Module, safeguarding against missed inspections. Within this module, each atmospheric inspection location is treated as a distinct assessment, guaranteeing that all historically inspected locations are systematically scheduled.
System Integration
By seamlessly integrating with PODs and UPDM, CIM can incorporate Operator-specific system names and hierarchy into their reports. Furthermore, inspections can be optionally linked to assets within GIS systems.
Manage Your Atmospheric Inspection Program with CIM
What was originally a solution to replace traditional paper and Excel forms for a more streamlined data collection of atmospheric inspections, has evolved into a new External Corrosion Module (ECM) within CIM where you can manage your entire atmospheric corrosion program.
- Digitally collect, analyze and report data while providing workflows to manage any required mitigation tasks.
- View and monitor the status of your atmospheric corrosion program on a system-wide level.
What’s Next?
Managing your atmospheric inspection program is the first step in building out our external corrosion control module. The next phases will focus on helping users analyze and follow-up on other external corrosion control data sets:
- CIS ingestion and alignment with ILI (completed – see graph below)
- CIS: conduct automated analysis with conditions, similar to ILI analysis (Phase 1)
- CP surveys, annual and other, plus rectifier data, data alignment and analysis (Phase 2)
- DCVG/ACVG: integration of ILI and all external corrosion control data sets (Phase 3)
Comments or questions? We’d love to hear from you!