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Is R-1 form required when bolting together U-2A components?

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InspectorJohn

Petroleum
May 5, 2009
7
One of our suppliers is claiming that the National Board requires all pressure vessel components to be tracked by issuing a R-1 form when you bolt together components from different manufacturers...despite the fact that each component has it's own U-2A form, and as such, was constructed in accordance with ASME Sec VIII, D1. I find no such Nat'l Bd requirement, so figured I'd ask the experts here.

Background
Very often we order replacement parts for pressure vessels. For purposes of this thread, let's use a heat exchanger as an example. Let's say we order a replacement channel for a typical TEMA-AES heat exchanger. We have the component built to ASME Sec VIII, D1, and when the component arrives from the manufacturer, we bolt it up to the existing heat exchanger shell, perform a tightness (hydro) test at operating pressure, and then we place it in service. We do not contract the services or a repair organization (aka "R" stamp holder) to document the bolting together of these components, and as such, no R-1 form is ever issued. We've done it this way for as long as my plant has been in existence.

Issue
Fast forward to now. Recently we ordered a new heat exchanger, and had two different manufacturers involved. One manufacturer made the channel/bundle assembly (a u-tube and integral channel assembly), and another manufacturer made the shell. The manufacturer of the channel/bundle assy followed all of the code requirements, conducted the necessary proof/hydrotest, and provided us with complete data package which included a U-2A (partial manuf data report) for the assembly. The channel/bundle assembly was then shipped to the other manufacturer....who simply bolted it up to the shell that they made. The shell manufacturer also provided a complete data package along with a U-2a form for the shell. However, they also issued an R-1 (repair) form and affixed a "repair" nameplate to this new heat exchanger simply because they bolted the components together. They are claiming that this was necessary to allow the National Board to track the components. We don't think the R-1 form, nor nameplate, were necessary. It just seems really odd for us to have brand new heat exchanger with a repair nameplate affixed...simply because one manufacturer decided it was necessary because they bolted together components from two different manufacturer's. The cynic in me thinks this manufacturer was quite happy to bill us more for this "repair"...but we don't think it was required, as the bolting together of components does not constitute a repair. What do you think?

Thanks in advance,
John
 
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