Form U1 vs U2

[alexander123]

All-
I have an in-service non-standard pressure vessel (no National Board Number)with no U1 and no manufacturing drawings. Per State (jurisdiction ) rules, I cannot weld to the vessel shell. What I have elected to do is install the new 3" nozzle and riser through a new 16" manway cover. The manway cover will be bolted to the existing manway nozzle, thus satisfying state requirements. The new piece is to be registered with the National Board. The new piece is simply a 3" nozzle welded to and protruding through a 16" 150# manway cover/blind flange.

Question-Does the Section VIII code prevent me from registering this on a U1? Some manufacturers have said it is a part and thus a U2 from is required. I do not think the text exists in the code that specifically prohibits this from being registered with a U1.

Additionally, the code requires that a U2 for be attached to a U1 form, which I don't have. This would make the U2 form out of code.

I am waiting to hear back from a couple of AI's about registering this with a U1. That would be my preference. Then I have all my ducks in a row for state requirements.

 

[metengr]

This vessel must be considered a "State Special" if there was no U1 form or Code stamping, and it is on current operation. As such, any parts fabricated by welding would fall under the National Board Inspection Code.

For your situation, I would think that Part RC-1050 "Replacement Parts" would be applicable and Form R-3 "Report of Parts Fabricated by Welding" would be more appropriate.

What exactly does your State board require for this vessel?

 

[aclark]

I agree with metengr.

The best solution is for you to have an "R" stamp holder fabricate the part and complete an R-3 form. One word of caution, many R stamp holders have excluded supply of R-3(this is for non ASME vessels) parts from thier Q C program.

I know that when I perform an R stamp Joint Review I always ask if they intend to supply those parts and if the answer is no a statement is placed in the Q C Manual to that effect.

 

[alexander123]

Thanks, guys.

This vessel is not a State Special as of yet because it is operating under the original installation, grandfathered before the state rules came into effect. We operate it under an API owner-user program. If we do not weld on the vessel, increase pressure, decrease MDMT, etc,or perform other repairs or alterations, then it does not require a state special.

I do not have the paperwork to gain a state special and am not allowed to weld the nozzle to the vessel. This is the reason for the unusual approach. Sorry I didn't mention that in the original post.

Is there an answer to the original question? thanks

 

[metengr]

Ah..ha, a grandfathered vessel. Well, it should not matter. I would fabricate the part under the NBIC, and use a Form R-3. This form applies to a fabricated (welded) part not installation.

Using Section VIII, Div 1 is also permitted. Why do you want to use a Form U-1? All you would need is to have a Form U-2 for this fabricated component and install it. Since there is no welding to the vessel, either a Form R-3 (under the NBIC) or a From U-2 is all you would need.

 

[alexander123]

metengr-

Unless I am wrong, and I quite often am, NBIC 1050 requires the item to "be inspected and stamped as required by the applicable section of the ASME code.", and it was built to ASME, it has a "U" stamp on the nameplate. So the R3 item would also have to be stamped to at least a U2.

Also, as I read the code, a U2 from is required to be attached to the U1 form, which I do not have. I also want the piece hydotested before I get it, so I can install it right away.

Thus the original question.

Can I get this piece of equipment as a U1 form equipment?

I have one AI who says he would do it. But he seems a little worrried about it.

 

[metengr]

No, to your question.

Let me put it in a different perspective. First, talk to your Jurisdiction. They set the rules and can pick and choose what they desire for this type of situation. PLEASE Re-read RC 1050 d) last sentence - if the vessel was NOT built to ASME Code,.. and …… when not possible or practical to certify... you can still fabricate a replacement part subject to external or internal pressure in accordance with the NBIC, using FORM R-3.

Since you do not have a Code vessel, there is not much more you can do OTHER than to assure that the part being fabricated is supplied in accordance with the NBIC. Again, talk first with the Jurisdiction - if you get them involved up front you stand a better chance of heading in the right direction.

 

[aclark]

The R-3 is intended to provide a way to document a part for a vessel that was NOT fabricated in accordance with the ASME Code.

As an AI I would NOT sign a U-1 or a U-2 data report. As an Inspector and ASME/National Board Team leader working for a Jursdiction in the mid west you should call the Chief Inspector of your state and get him involved. We have many vessels in this state that have been grandfathered. Couple of questions, was this vessel built to the API/ASME Code in the 1950's, and is it registered with the state?

 

[alexander123]

All-

Thanks.
The resolution, including the AI and the jurisdiction:

The part was built with a U2 and a NB number. The R3 was not required as the part was NB stamped.

The State had to allow in writing the U-2 from, since per code it is required to be attached to a U-1. As stated above, we do not have the U-1.

My reasoning for pursuing the U-1 in the first place was to eliminate the need for State involvemnt.

I cannot find the code text that defines what a "part" is vs "pressure vessel", and neither the jurisdiction or the AIs I talked with.

But they all said it couldn't be on a U1. And they admitted there was not a code reason for their answer.

So what happened was: The Jurisdiction allowed a non-code activity (a U-2 to be submitted without attachment to a U1), but they wouldn't allow a non-prohibited code activity (registering this vessel or "part" on a U-1 form).

Well, I am not an AI, (yet, I have not retired from my actual job, so I still have health insurance)so I am not priveledged to some of the secret code requirements, I just go along with the jurisdiction and the AIs working for insurance.
Thanks all for your input.

PS-sorry about the rant at the end, just frustrated cuz I was beat by the boss over this whole thing.

 

[GenB]

I am confused, first you said theat you did not have a NB stamping. if that is true you can not do anything with the NB but just the Jurisdiction, if they allow the work is their problem.
(Non Code vessels are not allowed in California.

Last you said that you ave a NB # and registered U2 cetification.
If you are adding a nozzle that is an "ALTERATION" and an
R1 will be required, then you can reg. with the NB if you wish to,
with the concurrence of your AI.
Post if you need more assistance.
Can you tell us What State?
ER

 

[alexander123]

All-

I'll try to wrap this up nice and clean.

We have an existing vessel built in 1960 that has a "U" stamp but no NB stamp. Therefore, it is a non-standard vessel that requires a state special to weld on it.

We do not have an original U-1 form or other manufacturers data and cannot gain the data (manufacturer is out of business). Therefore, I cannot gain a state special (no proper documentation).

In order to follow state rules, and not being able to gain a state special, we opted to have a new piece made. (The new cover plate with a nozzle welded throught the plate).

The question was this:
Can this new part be manufactured with a U-1 form, as opposed to a U-2 form?

The AIs and the State said "no", but they could not tell me why, only that it is not a "pressure vessel". They could not tell me where in the code a physical description of a "pressure vessel" vs a "part" is located.

A "part" per code section UG 120 requires the U-2 to be attached to the U-1. I do not have a U-1, so could not, per code, be given a U-2. And that is the issue.

The NBIC plays no role as this is new construction.

My reasoning for pursuing the U-1 in the first place was to eliminate the need for State involvemnt.

The resolution, including the AI and the jurisdiction:

The part was built with a U2 and a NB number. The R3 was not required as the new part was NB stamped.

The State had to allow in writing the U-2 form, since per code it is required to be attached to a U-1. As stated above, we do not have the U-1.

My reasoning for pursuing the U-1 in the first place was to eliminate the need for State involvemnt.


So what happened was: The Jurisdiction allowed a non-code activity (a U-2 to be submitted without attachment to a U1), but they wouldn't allow a non-prohibited code activity (registering this vessel or "part" on a U-1 form).

Hope that clears it up.

Well, the job is done, the state is satisfied, and everyone is happy. Except me......I still have code questions.....

Thanks all

 

[GenB]

ha! the problem with your vessel is that anything you do to it is an alteration, even if you add a legally stamped part.- it is an stamped vessel but you do not have any documentation, so the State or Insurance Co wants NO-responsibility.
If I was the Jurisdiction or the AI, I would had allowed the addition of the part stamped and registered with the U1, it was no harm.
Also was not harm in allowing the nozzle replacement if it was done to the original Code year of Construction, then the Insurer was to jump and a no-no would be the result
because it could not have registration with the NB but but only the certification filing with the Jurisdiction.ER