Category Archives: Safety

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 Thus the liquids “Final Rule” that was 6 years in the making was withdrawn and is awaiting resubmittal by the new administration.
While the exact requirements of the Final Rule may be changed, some of the key changes from the withdrawn rule included: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.

Corrosion Industry Safety and “Captain Obvious”

by Rebecca Haring
Corrosion Industry Safety and Captain ObviousMATCOR Safety & Compliance Manager

 

Quickly, off the top of your head – what’s the most important factor in your daily corrosion industry safety work life?

It’s Y-O-U and Captain Obvious—what a Dynamic Duo!

Safety managers train you. Regional managers establish procedures and rules. Clients require certain clothing. Your supervisor warns you. But the bottom line is: No program, sign or protective equipment will work if YOU elect not to make safety an intentional part of your daily work life.

“But,” you say, “We’re told the job must be done faster and cheaper.” Be sure you include “The job must be completed without a safety event.”

Make no mistake, every job must finish safely. As soon as it doesn’t, safety becomes the MOST IMPORTANT measure of the job; and you become the yardstick.

Let’s review some simple ways for you to practice safety at every job every day.

Enter Captain Obvious to remind you of corrosion industry safety basics:

 

Check your work area frequently.

Look around and listen up! Use your senses to prevent a safety event (and you already do it all day every day). What do you see, hear or smell in your work area? Mobile equipment in use? Materials being moved? Walking area slippery? Cords or ropes in your path? Trash not discarded correctly? Machine making a ‘funny’ noise? Do you smell hydraulic fluid?

Observe how your work area changes during the day. Let those working around you know about the changes. Take an active role in making your job site safer by helping to make others aware of the little changes. Sure, you might sound like Captain Obvious. So what? When it helps everyone go home at the end of the day with nothing but a fatter wallet… then THAT’S a good day!

All MATCOR employees abide by our Stop Work Obligation. Every employee at our job sites has an obligation to intervene and stop work when a situation gets identified that could break one of MATCOR’s Life Saving Rules or cause injury or illness.

Electricity and equipment. Both start with “E” and both kill.

Here’s another one from Captain Obvious. Check your electrical equipment every time you use it. Drills, grinders, reeling machines and irons. If it has to be plugged in or charged, there’s the potential for a cracked case, frayed or cut cords or a short somewhere. Make a quick inspection for wear and tear, and intact strain relief and connections.

For larger equipment, like Pipeline Current Mappers, generators or interrupters, take the time to read the Operator’s/Owner’s Manual at least once before you running the machine. If the manual isn’t available, ask someone who has used the machine for a quick rundown.

Wide open and burning hot.

Many times when we hear about a workplace fatality, it involves some kind of fall…in a hole, from heights, or something falling on a worker. Considering the kind of work we do, every worker needs to be aware of 1) what he or she might fall over/into; and 2) what might fall onto him or her. Falls aren’t always fatal, but often workplace fatalities involve falls. Here comes Captain Obvious, again. Be aware and make others aware of anything that might make you fall; or that might fall on you.

Another situation that could burn us on a job site is fire (sorry for the bad pun there). Anywhere there’s machinery, combustible chemicals, or cad welding, the possibility of fire exists. Open flame, especially on a pipeline right-of-way could turn an ordinary day into a hot time that no one wants. Knowing what to do in the event of a fire at EVERY job site makes sense. Where’s the extinguisher? Do you know how to use it? What about the escape route from the site? Yes, you and your crew should create and review the emergency plan at each job site. After all, knowing the best direction to run IS an emergency action plan.

Where IS that first aid box?

Calling Captain Obvious… Do you know where the first aid kit is in your work area? Can you get to it quickly and easily? When was the last time you checked to see if it needed to be restocked? Though you may think that’s someone else’s job, it will matter most to you when you need to remove a splinter, bandage up a cut or treat a burn. Remember, we’re talking about how Y-O-U have the most important part of job site safety. If the first aid kit isn’t ready and available when you need it, the problem isn’t someone else’s. Check the first aid kit.

Corrosion Industry Safety: The last line of defense.

If we can’t engineer a hazard away, we write a procedure to protect you from it. When engineering or administration doesn’t quite eliminate a hazard, you get personal protective equipment (PPE). Here’s the rub. If you choose not to wear PPE, it doesn’t protect you (OMG, Captain Obvious snuck right in there). Hard hats, safety glasses, gloves, or earplugs might be uncomfortable. Then again, so are skull fractures, blindness, amputations and deafness.

PPE may be a last line of defense when it comes to corrosion industry safety, but that makes it no less important. Make sure you don it every time on every job…and speak up if your co-workers need to be reminded.

Wrap it up.

Workers need to take care at all times and at all job sites. No matter how many machines have guards, or safety policies the company writes, Y-O-U have the biggest impact on your safety. Awareness of your work space, inspecting your tools, knowing how to get out in an emergency or where to find the first aid kit are all factors in YOUR control.

You make decisions every day that impact how, or if, you and your crew go home. Will it be with a fatter wallet? Or will it be with stitches, or in a cast or worse? Captain Obvious knows.

MATCOR takes corrosion industry safety very seriously and maintains an excellent safety record.

Learn more about MATCOR Safety Programs or contact us for additional information.

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

Oil sands critics target a new concern – pipelines

The crude oil that is pulled from Canada’s oil sands is thick and heavy, a black tar-like substance that takes large amounts of energy and effort to make into end products like gasoline and diesel. Even some people in the Alberta energy industry describe it as “nasty” stuff.

But is it also dangerous?

Over the past few months, critics of the oil sands have taken a new tack. They are now arguing that oil sands crude, which contains more contaminants than traditional sources of crude, poses a risk to pipeline safety – and they’ve linked the recent spate of North American oil pipeline spills to what they say is the corrosive content of oil sands products.

It’s an argument that began with environmental groups, but has now been taken up by legislators. Last week, for example, Alcee Hastings, a U.S. Democratic congressman, warned that “the risk of an oil spill from these tar sands pipelines is very real.”

“The oil eats away the pipelines, compromising them and leading to frequent spills,” he said during a debate on the proposed TransCanada Corp. Keystone XL pipeline, which will bring oil sands crude to the U.S. Gulf Coast if it is approved. That echoes a February report from the Natural Resources Defense Council, an influential U.S. environmental group, which called oil sands crude a “highly corrosive, acidic, and potentially unstable” substance that “may be putting America’s public safety at risk.”

That conclusion has always been contradicted by industry, which has maintained that oil sands crude is safe. TransCanada, for example, has argued that it simply would not place at risk its $13-billion Keystone line by filling it with a dangerous substance. Yet the debate highlights the political obstacles that exist for the project, a crucial piece of infrastructure for getting the ever-rising volume of Alberta oil to market.

The two sides have left little middle ground between them. So who is right?

Interviews with academics, engineers and federal officials make clear that oil sands crude does indeed appear to pose additional risks. But those risks are largely borne by refineries that have had to deal with a dirtier and more corrosive substance than industry has been accustomed to.

In pipelines, independent sources suggest that the danger is substantially lower. Indeed, in decades past, thick bitumen was actually used to coat pipelines as protection against corrosion. And pipelines are partly shielded by the fact that they operate nearer room temperatures. Refineries, in contrast, process crude at up to 400 degrees Celsius, and the fierce heat promotes a series of chemical interactions that don’t happen at lower temperatures.

The corrosion question largely surrounds the properties of diluted bitumen, also called “dilbit.”

Oil sands producers generally produce two different products. One, “synthetic crude,” has passed through a sort of pre-refinery, called an upgrader, to transform it into a lighter substance that contains far fewer impurities. Dilbit comes from producers that don’t run upgraders. Instead, they take the oil sands crude and, with minimal processing, thin it with a lighter oil and pump it into a pipeline. As a result, it contains far higher levels of numerous noxious substances, including sulphur, acids, salts and sediments.

That in itself has raised some concerns.

Take sulphur, for example. Oil sands crude contains sulphur levels up to 10 times higher than other oil. But in dilbit, the sulphur is locked up with heavy oil molecules. As a result, it is largely harmless inside a pipeline, said Harvey Yarranton, a professor of chemical and petroleum engineering at the University of Calgary.

“You’d have to put it into reaction temperatures to release that sulphur – and those are above 300 Celsius,” he said.

Acids and salts are also found in substantially elevated levels in dilbit. But both substances are “not corrosive under pipeline conditions,” according to Natural Resources Canada, whose researchers have studied the corrosiveness of different oils. Acids need temperatures above 200 Celsius for corrosion to occur, the government said in a statement.

One area of concern remains sediments – little bits of sand that are embedded in oil. Industry measures these in pounds per 1,000 barrels. Conventional oil might measure 30 to 50 pounds per 1,000 barrels. Scott Bieber, a marketing manager with oil field services giant Baker Hughes Inc., has seen oil sands bitumen hit 500.

Sediments can contribute to corrosion in pipelines – and they have become a significant menace in refineries, where they have proven difficult to remove and help foul wastewater, Mr. Bieber said.

And environmental critics say that with the expansion in the oil sands, more study needs to be done of the effects dilbit has on pipelines. In particular, the thickness of oil sands crude – it’s far more viscous than conventional oil – creates friction inside pipelines that creates higher temperatures.

With Keystone XL, TransCanada has predicted temperatures as high as 55 Celsius. That remains far from the heat in a refinery, but higher temperatures do speed corrosion, and Anthony Swift, an energy analyst with the National Resources Defense Council, said governments both in Canada and the U.S. should take notice.

“There’s enough information out there about [the risks of] this stuff that merits a study,” he said. “The government should be protecting the public, and it’s a huge concern when they turn a blind eye to a potential danger.”

SOURCE: http://www.theglobeandmail.com/report-on-business/industry-news/energy-and-resources/oil-sands-critics-target-a-new-concern-pipelines/article2116408/