Very good comments from Kerry Morgan

Yes Richard we have a lot more work to do. As I have done research over the past few months I am becoming quiet disturbed regarding the direction NACE and PHMSA are going.

I have anecdotal evidence from people who have taken NACE corrosion courses over the past few years that -.850 with current applied is not even discussed in the classes. I was under the impression that the purpose of organizations like NACE and its various committees was to research, discuss, and propose revisions to existing standards. I would contend that until a standard has been revised it should be taught as written without preference to one part or another. I for one am not ready to throw Peabody under the bus. There is too much practical and empirical data to support his theories.

I would also contend that PHMSA stands poised to incorporate the SPO169 revision by reference into Federal code. I hope everyone involved understands the implications of incorporation by reference. I am neither a parliamentarian nor an expert on Federal codes and rule making procedures. But if I understand what I read on PHMSA’s website correctly , Congress gave complete authority to the Director of the Federal Register to determine whether a proposed incorporation by reference serves the public interest and approve the agency's IBR request. Does this mean there will be no opportunity to comment on the change to the Federal code?

Further research on PHMSA’s website shows that since 1989 196 significant incidents related to external corrosion were reported. Further research to ascertain if these incidents also involved a violation of current code will take much more time, but I would suggest that significant incidents related to external corrosion were also in violation of existing code.
Revising SPO169 to require -.850 without current applied will not magically prevent violations of code. The costs associated with complying to the revised standard when PHMSA incorporates it will in effect be prematurely fining the pipeline industry before an incident occurs.

Kerry L. Morgan
Senior Corrosion Technologist 5037
NACE 133125