Category Archives: Infrastructure

PHMSA Rule Making Updates – a look at what is ahead on the US Regulatory Front

Overall
The US Pipeline regulatory environment is poised to see several new rules implemented to expand the scope and effectiveness of pipeline regulations with a goal to improve the integrity and safety of hazardous material pipeline. These rule changes were all initiated years ago and have been winding their way through the regulatory process, soliciting input from the industry and from concerned citizens, environmental groups and other interested parties.

The Liquids “Final Rule”
In January of 2017 in the last few days of the Obama Administration, the Department of Transportation’s Pipeline and Hazardous Materials Safety Administration issued a final rule amending its Rule 49 CFR 195 that among other things expanded integrity management and leak detections beyond high consequence areas (HCA’s). The Final Rule tightened standards and broadened data collection and monitoring requirements for pipeline operators. A few days into the Trump administration, the White House issued a directive to federal agencies to freeze sending new regulations to the Office of the Federal Register (OFR) and withdrawing any regulations sent to the OFR. Thus the liquids “Final Rule” that was 6 years in the making was withdrawn and is awaiting resubmittal by the new administration.
While the exact requirements of the Final Rule may be changed, some of the key changes from the withdrawn rule included:

• Assessment of non-HCA pipeline segments every 10 years in compliance with provisions of 49 CFR Part 195.
• Increased use of inline inspection tools for all hazardous pipelines in HCA.
• Requirement for leak detection systems for covered pipelines in both HCA and non-HCAs.

PHMSA anticipates coming out with their revised “Final Rule” in the Fall of 2018.

The Gas “Mega Rule”
On the gas side of the pipeline regulatory environment, 49 CFR Parts 191 and 192, several public meetings have been held regarding PHMSA’s proposed gas rules, often referred to as the Gas Mega Rule. The rulemaking changes originally recommended would have nearly doubled the current number of pages in the regulations. PHMSA has announced that instead of one Mega Rule, the effort would be broken into three separate rules that are expected to be introduced in 2018 and to go into effect in 2019. Part 1 addresses the expansion of risk assessment and MAOP requirements to include areas in non-High Consequence Areas (HCAs) and moderate consequence areas (MCAs.) Part 2 of the rule making focuses on the expansions of integrity management program regulations including corrosion control to gathering lines and other previously non-regulated lines. Part 3 of the gas rule making is expected to focus on reporting requirements, safety regulations and definitions to include expanding into related gas facilities associated with pipeline systems.

Anode Current Ratings and Soil Resistivity

We appreciate the question: “How does soil resistivity impact current rating.”  The short answer is that resistance has nothing to do with anode rating. Here is a more detailed response:

  1. Anode current rating – all anodes have a current rating based on how long they can be expected to operate at a given current rating.  All anodes have some defined expected life based on current output and time – so many Amp-Hours of service life.  For example a magnesium anode may have an expected consumption rate of 17 lb/Amp-year (7.8 kg/amp) so if a 17 lb anode is operated at 0.1 amps it would have a life of 10 years.  For MMO anodes, they too have an expected life.  For our linear anode rated at 51 mA/m it is important to know that that rating is actually 51 mA/m for 25 years.  So a 100m anode segment with this rating would have an expected life of 127.5 Amp-years.  If this anode were operated at 5.1 amps (full rated capacity) it would be expected to operate for 25 years.  IF it were operated at 2.55 amps (50% of rated capacity) it should last 50 years.  The anode life is generally linear.  Please note that resistance has nothing to do with the anode current rating – the anode current rating merely calculates the life of the anode as a function of how many amps for how long of time.
  2. Actual current output – just because you install an anode rated for 5.1 amps for 25 years (our 100m segment of 51 mA/m SPL-FBR) does not mean that the anode will output this amount of current.  It just means that at that current rating you can expect 25 years of life.  The anode is merely one component of the overall cathodic protection circuit.  The actual output of the anode is function of Ohms Law ( Voltage = Current * Resistance).  It would make sense to note that if the system Voltage were zero (the rectifier were turned off or disconnected) then the anode would not have any current output.  Likewise if the 100m anode segment were installed in a very low resistance environment and driven by a powerful rectifier, the current could be much higher than 5.1 amps which would result in a much shorter life.
  3. Why anode rating is important to the CP designer – the CP designer is tasked with protecting a specific structure for a given period of time (protect this pipeline for 30 years.)  The CP designer then calculates, based on actual testing or established guidelines, the amount of current that should be sufficient to achieve appropriate CP levels to protect the structure.  This results in an answer of some number X of amps required.  If the requirements are to protect the structure for Y number of years, then the anode life required is X * Y (# of amps times # of years).  This defines the minimum amount of anode life that is needed.
  4. The next question the CP designer must address, once it is determined how much current is needed, is how to design a system that will generate that amount of current.  Since Ohms Law dictates that Voltage = Current * Resistance (V=IR) then if we know that the Current = Voltage/Resistance (I=V/R.)  Thus the CP designer must understand how to calculate system resistance (R) and must provide sufficient driving force (V)  Several factors affect system resistance (R) including anode geometry – the longer an anode, the lower its resistance – which in many applications is a big benefit to the linear anode.  One of the great benefits of the linear anode is that because of its length, in most applications the soil resistivity plays a lesser role since the anode resistance to earth is generally low for a wide range of soil resistivities due to its length.  For extremely high resistance environments, linear anodes may be the best option since short anodes will not have a low enough resistance.
  5. There are other factors that go into CP design including current distribution and making sure sufficient current is being applied across the entire structure.

CP Design can be very complicated.  I hope that the above explanation is helpful, but if there is a specific application to evaluate, please contact us with the details.  We are also available, for a reasonable engineering fee, to develop and/or review CP system designs.

Ted Huck

VP, Technical Sales

Chief Big Dig engineer is fired over light fixture controversy

Helmut Ernst, the embattled chief engineer of the Big Dig, has been fired, the state transportation secretary said today, as the fallout continued from the controversy over a light fixture collapse earlier this year in one of the project’s tunnels.

Ernst had already been reprimanded and suspended for his role in the state’s failure to notify the public for more than a month after a corroded 110-pound light fixture collapsed onto the highway in the O’Neill Tunnel on Feb. 8.

Transportation Secretary Jeffrey Mullan said the department had finished a review of Ernst’s performance on Friday and concluded he could no longer serve as the District 6 highway director, the former title for his job as a top engineer in charge of the Big Dig tunnels.

Mullan said he offered Ernst other jobs in the transportation department, but Ernst, who has worked as an engineer for the state highway system for two decades, declined to take them.

“As a result of that, we terminated Helmut’s employment at the DOT today,” Mullan told reporters at the state’s highway operations center in South Boston. “It was clear that we lost confidence — I lost confidence — in him, and given some of the issues, someone in a leadership position like that, I would expect more,” Mullan said.

Tom Broderick, currently the chief engineer in the highway division, will replace Ernst while the department searches for a permanent replacement.

The collapse revealed widespread corrosion in lights throughout the 7.5-mile Big Dig tunnel system — and the delay by state officials in notifying the public sparked outrage and concern about the tunnels’ safety.

In an interview in July with the Globe, Ernst said his team of engineers filed no written report about the collapsed light fixtures despite state policy requiring documentation of safety issues. Ernst admitted his engineers had been wary about writing things down since the 2006 collapse of a Big Dig ceiling panel that killed a woman.

“After all the depositions in the ceiling collapse case, we just meet and talk about it … What’s the point of putting it in writing?” he said. He said engineers had been “trained not to.”

Ernst claimed he had called his boss, Frank Tramontozzi — who was forced to resign in March as highway administrator for his own role in mishandling the light fixture collapse — the day after the collapse. Tramontozzi said he didn’t learn about the collapse until Feb. 28.

Ernst also claimed he brought up the collapse at a Feb. 14 senior staff meeting. But seven other staffers, questioned by a staff lawyer at Mullan’s request, said they didn’t remember him mentioning it.

Mullan said he was not pushing out a whistleblower, who had spoken out about problems in the Big Dig. “I don’t think that’s related to it all,” he said.

He said there would not be a chilling effect on other employees, discouraging them from speaking out. “No,” he said. “It just didn’t work out, and sometimes it doesn’t work out.”

Mullan has said he plans to leave his own job by the end of the year, but said today he has not settled on the exact date when he plans to step down.

SOURCE: http://www.boston.com/Boston/metrodesk/2011/08/chief-big-dig-engineer-forced-out/XXfFA4dQ3daU1pNdCO4KHJ/index.html