Mech Seal Coolers - ASME B&PVC Sect VIII, Y or N

[MechEng Dan]

The question pertains to the applicability of ASME B&PVC Sect. VIII for pump mechanical seal coolers. Specifically, I'm seeking other's opinions as to whether ASME B&PVC is a REQUIREMENT, not if it is a prudent choice to ensure product quality.
B&PVC U-1(c)(2) & (-c) states the following:

(2) ...the following classes of vessels are not included in the scope of this Division; however, any pressure vessel which meets all the applicable requirements of this Division may be stamped with the Certification Mark with the U Designator:
(-c) pressure containers which are integral parts or components of rotating or reciprocating mechanical devices, such as PUMPS, compressors, turbines, generators, engines, and hydraulic or pneumatic cylinders where the primary design considerations and/or stresses are derived from the functional requirements of the device

Just to be clear, I'm considering this for instances where a horizontal pumpset is provided as a skided unit with the pump, motor, coupling, seal coolers w/ piping all mounted on a common frame. Can it be reasonably argued the seal coolers are an "integral part or component" of the pump?

 

[Heaviside1925]

OP,
The US customers I have worked with typically used the 1.5 ft3 requirement as the deciding factor on stamped seal system components. I can understand a prudency for design quality, but I would be concerned the poor folks having to track a bunch of stamped sub-components. I have had customers specify that any fabricated components of a system, such as a cooler, meet Sec VIII fabrication and testing requirements but not be a stamped asset.