Friday, December 5, 2008

TM0497 and SP0169 comments

It would seem that Jim Chmilar (TG-360 Chairman) intends to go out for ballot on the proposed/revised SP0169, before CORROSION 2009. There are many who do not believe in Jim’s version of what the “FOUR criteria” will allow. Those individuals believe the facts remain that the -850 mV “On” criterion has been removed, only the -850 mV “polarized” (actually instant-off) and the 100 mV polarization criteria remain in black and white, the regulators and other auditors will only want to deal with black and white, and other wording (and lack of wording) within the proposed/revised SP0169, as well as the yet-to-be-created proposed/revised TM0497, along with the most likely perceived ambiguity of the 3rd and 4th “criteria” in the proposed/revised SP0169, will almost certainly make it virtually impossible to ever utilize the -850 mV “On” criterion or any other alternative criterion. In other words, there are many who believe that only the -850 mV “polarized” and the 100 mV polarization criteria will end up being allowed.



Everyone does need to read the proposed/revised SP0169 very, very carefully. It is the belief of a number of individuals that everyone needs to formally insist the PRCI studies be completed, fully reviewed and incorporated, before the proposed/revised SP0169 goes to ballot. In addition, they believe that everyone should formally insist that the proposed/revised SP0169 and proposed/revised TM0497 go to ballot simultaneously, once both of these proposed revisions have been completed and appropriate changes/incorporations have been made to both based on the PRCI studies, as well as the consensus determinations of the industries most affected by these documents. These are both supposed to be consensus documents. It appears there are many who believe that objective is not truly being achieved.

TM0497-Reaffirmation

I strongly disagree with your position that proposed changes discussed in my original correspondence do not constitute technical changes to TM0497.



If the procedure to assess the adequacy of cathodic protection using the 850 mV Current Applied Criterion (Method 1) is modified as proposed, the tone / intent of TM0497 changes. In light of the ongoing debate within NACE over the 850 mV Current Applied Criterion and the omission of this verbiage from the working draft of SP0169, these changes would be proclaimed by some as a clear message that NACE no longer considers these techniques to be valid.



I agree with the proposal from Mark Brogger – let the dust settle on SP0169 and then let’s work on TM-0497. Until then, reaffirm as written.



Additional instances of technical changes are as follows.



· Section 8.6.3 (b) has been changed, but this change is not highlighted in the document. This omission is reason enough to pull the ballot, as members are only asked to review changes. It also raises the question as to how many other changes were not highlighted in the document.



The proposed text is as follows:



8.6.3 Cathodic protection shall be judged adequate at the test site if: (a) The pipe-to-electrolyte potential measurement is negative 850 mV, or more negative, with respect to a CSE; and (b) The significance of voltage drops has been considered by applying the principles described in Paragraphs 8.6.1 (reference Paragraph 1.3 for exceptions).



The current text is as follows:



8.6.3 Cathodic protection shall be judged adequate at the test site if: (a) The pipe-to-electrolyte potential measurement is negative 850 mV, or more negative, with respect to a CSE; and (b) The significance of voltage drops has been considered by applying the principles described in Paragraphs 8.6.1 or 8.6.2.



Paragraph 8.6.2 discusses physical evidence of corrosion which relates to Item (d) Determining whether there is physical evidence of corrosion contained in the Note in Section 8.1 and also in SP0169. Deletion of both is a major technical change to TM0497.



The most widespread impact of this change would relate to the use of ILI data to consider the significance of voltage drops in accordance with 8.6.2 (c). Section 8.6.3 of TM0497 currently allows an operator to judge CP as adequate when current applied potentials are more negative than 850 mV and the significance of voltage drops has been considered by verification of ILI metal loss indications in accordance with 8.6.2(c). The proposed technical changes would require additional steps to consider the significance of voltage drops.



· The addition of “Ductile Iron Pipe” throughout the document.



This was never a simple omission (and thus an editorial change).



· The addition of “non-mandatory” to Appendices B and C



TM0497 is a test method which by definition provides description of techniques to determine whether a specific criterion has been complied with at a test site. As the methods described in Appendices B and C are contained within SP0169, I can’t understand how a technically correct procedure that has been recognized by NACE for years could now be reclassified as non-mandatory.



Again, I request that NACE immediately stop balloting on TM0497. We can discuss the path forward in Atlanta .



As you can see, this individual and his company are very concerned. For those who “signed up” to vote, they may want to consider the possibility of sending NACE a similar note. They also need to remember that the voting deadline is December 9, 2008.



Thanks