Wednesday, November 18, 2009

Kerry Morgan Comments

What happened to NACE?

You may remember “The National Association of Corrosion Engineers?” I wonder what those eleven men, corrosion engineers in the Pipeline Industry, would think of NACE today. A NACE that today finds itself in the position of writing Federal Code. A NACE that is contemplating changes to the core standard that has effectively and safely served the pipeline industry for the past 66 years. Prudent Operators have used the existing standard to protect the public and preserve valuable and critical assets.

I am not against revising the ST0169. I believe all standards should be under constant review with the goal of improving safety and asset preservation. Supporters of the revision argue that the off -.850 has scientific research behind it and contend that the on -.850 as put forth by Peabody has only empirical data to support it. How many leaks or ruptures have been associated with =<-.850 with current applied. The current revision being contemplated raises valid questions as to whether the off potential is a true IR free reading. Other’s who are far more qualified than I am have raised these questions and made convincing arguments and I will leave that to them.

My question is who should be reviewing and revising ST0169? If revised to the current recommendations this standard has the potential to add hundreds of millions of dollars to the cost of operating the country’s underground pipelines, and only bring about questionable improvements to safety. The stakeholders which include: the public whom the standard is designed to protect, the regulators who have the responsibility of codifying the standard, and the operators, who will have to absorb the cost of implementing the revised standard, should be debating, reviewing and revising the standard.

So back to my original question, what happened to NACE? When did we quit being an industry group with the goal of protecting the public and preserving the national asset that is the underground pipeline system? When did we decide that members who will be under no legal obligation nor incur the cost of complying with the standard get to set the standard? A quick glance at the membership roster of STG 35 shows only about 30% of the members are domestic operators. TG 360, about 30% of the members are domestic operators. Definition of Democracy “two wolves and a sheep voting on what’s for dinner”.

Whose fault is this? Mine, I am the corrosion practiconer working for a domestic operator who has decided that with budget pressures, expanding work load and shrinking staff , I am unwilling to dedicate the time to be actively involved in NACE except for the occasional trip to a conference.

I have been in the pipeline industry for over 30 years, and yet I recognize that with all of the scientific and technological advances made in the past 60 years it is time to move forward and take advantage of these tools. With the advent of high resolution ILI tools and the implementation of the IMP we have actual corrosion data for a segment of pipeline. Let’s incorporate this data into our compliance standard. Why expend time and resources to maintain an IR free -.850 or less with current applied to a segment of pipe that has no corrosion? With the baseline assessment nearing completion and reruns starting next year we will have accurate corrosion rates to work with. Give us credit for the hundreds of millions of dollars the industry has spent running high resolution ILI tools, give us credit for the hundreds of millions of dollars the industry has spent remediating to ASME B31.8S. Which would better ensure the safety and integrity of a section of pipeline, actual known corrosion data from an ILI or an electrical reading that at best tells us what the potential for corrosion is.

To summarize, if we are going to revise ST0169 then let’s revise it using all of the technological and scientific advances available to us today.

Kerry L. Morgan
Senior Corrosion Technologist 5037
NACE 133125

Comments on Voting for next ballot

I think it’s important to make the distinction between those in the balloting list and those who voted on the ballot. Anyone who responded “yes” to the correspondence that NACE sent out asking if they would like to join the balloting list can vote on the next ballot. The balloting list will remain the same. Not everyone who is on the balloting list voted on the ballot. The next ballot will not be restricted to solely those who voted, but it will be restricted to those who are part of the balloting list.

Daniela Matthews

Program Coordinator

NACE International