NBIC Applicable to Building Services Steam Piping ?

[tc7]

Do the NBIC rules of Part 3 for repair apply to low pressure steam distribution piping for heating systems in commercial buildings?

Background: The building is equipped with a steam boiler rated at 150psig; the pressure is reduced and conducted into the piping system at 9psig. We are sure the building services piping was originally designed/constructed IAW ASME B31.9. Most parts of the distribution piping was originally welded and only the terminal heat exchangers and condo pumps have threaded connections so any piping repairs may necessarily incur welding (with some exceptions).

I assume that my state (NJ) has adopted the rules of the NBIC (although I have not been able to confirm this) and if so, then NBIC is tantamount to law but I am not sure if NBIC is applicable to low pressure building services steam pipe.

Thanks for reading, thanks for any advice offered.

 

[david339933]

If you go to nationalboard.org and search synopsis...then select NJ, this will tell you whether NB has been adopted by the state.
That being said, you should check the local regulations...as it may exempt steam piping at that low a pressure. For example the regulations in Canada exempt steam piping with a psv set at 15psi or lower.

 

[SnTMan]

Might check with your insurer as well.

Regards,

Mike

The problem with sloppy work is that the supply FAR EXCEEDS the demand

 

[metengr]

The NBIC, Part 3 rules can be applied to these types of repairs. Enforcement, meaning required to be used is dependent on the local Jurisdiction. In this case, the NBIC rules should be followed along with a repair organization having a valid R-Certificate.

http://www.nj.gov/labor/lsse/content/bbpvc.html

 

[tc7]

Following David's suggestion to search "synopsis" on the National Board site I did indeed find that NJ has adopted the NBIC rules.

But what do you mean by "local Jurisdiction", who are they ? If the State has adopted the NBIC, is it not up to the county or city (or whoever issues permits) to apply and enforce the State's rules?

 

[metengr]

I used the term local to highlight where the piping is located. Jurisdictions can be a city or State, as defined in the NBIC.

I doubt that the enforcement of the NBIC applies to industrial steam piping below 15 psi pressure or even higher pressure under B31.3 or non-boiler external piping under B31.1. My point was good engineering and safety practice would suggest using a contractor who has a current Certificate of Authorization issued by the National Board for weld repairs.

 

[tc7]

Fully agree with the good engineering and safety practice but it comes down to the question of what is mandatory. I've done a lot of research on this and short of calling on the insurer (could be a disaster for me) I have not seen any exclusions for piping systems under 15 psi as you and David have alluded to. I only have the 2007 version of the NBIC Part 3 and there seems to be no exemptions based on pressure that I can find.

If such an exclusion existed in your areas where would it typically be found?

 

[metengr]

TC
In the link I provided look for weld repairs under boiler and pressure vessel rules. The requirements I briefly reviewed were only applicable for boiler and pressure vessels, as most Jurisdictions regulate. I think this piping is exempt.

 

[metengr]

Contact the Jurisdiction directly to get their official recommendation.

 

[tc7]

Yes metengr, I have corresponded with the state Chief Inspector's office but have not heard back from them yet. They are either very busy or I have stumped them with my questions

Since the NBIC(2007)Part 3, paragraph 1.2(a)re-invokes the original construction standard for repair & alteration of any "pressure-retaining item" and paragraph 1.2(e) specifically addresses steam piping and also re-invokes the original code of construction my opinion is that if downstream low pressure steam piping isn't specifically excluded then it must be included.

Ultimately what I am after is to force any and all welding repairs on low pressure piping to be accomplished by qualified people done iaw qualified weld procedures and tested/inspected by competent and qualified NDT professionals. This presents huge and costly organizational changes when the prevailing wisdom (or prevailing ignorance) has always been that low pressure piping repairs don't require higher levels of skill and oversight. I am waging the same battle on the structural side where, in my opinion, AWS requirements need to be adhered to.

Thank you, I very much appreciate everyone's ideas.

 

[tc7]

Finally received a reply from the state Commissioner to the question of applicability of NBIC Part 3 for repairs on building services steam heating distribution piping; the response, not as direct as I would have liked, is as follows:

". . . there is no requirement within the NBIC for any type of piping that is non-code, in other words falling outside the boundaries of the ASME specific standards, in this case B31.9 code boundary as detailed in the standard at Figure 900.1.2. Anything outside the noted boundary would not be included in the NBIC welding requirements. "

I don't know whether his reply is a brilliant political sidestep to my question or whether he is just stating that which is blatantly obvious !! Based on this reply and with reference to Figure 900.1.2, I conclude that the steam heating distribution piping that I am concerned about is classified as "Nonboiler External Pipe (NBEP)" and does indeed fall within the Code boundary jurisdiction of ASME B31.9 by paragraph 900.1.2(a), which specifically lists, "(3) steam or other condensate". The only noted exclusion which falls outside of the B31.9 jurisdiction is the heat exchanger which is listed in paragraph 900.1.3.

Ergo, repairs to low pressure steam heating distribution piping must comply with NBIC Part 3 and performed by an R-stamp activity.

Perhaps I am I not reading Figure 900.1.2 correctly?
Comments please?
Thank you.

 

[metengr]

NBEP is not within the scope of the NBIC. Can you use the NBIC to make repairs? Yes. I can use an R-Stamp to repair garbage cans, there is no prohibition. The issue is the Jurisdiction and what enforcement is required. They have spoken and stated it is not within their regulations. This is very common.

 

[tc7]

Hello metengr,
Thank you for responding. I, along with many Eng-Tip'sters, revere your vast array of knowledge and your willingness to help. But I really need you to explain, "NBEP is not within the scope of the NBIC". The issue of Jurisdiction and enforcement is exactly what I have been searching for. The State has not said it is not within jurisdiction, all they said was, " Anything outside the noted boundary would not be included in the NBIC welding requirements. "

If there is verbiage inside of NBIC Part 3 that excludes NBEP I have not been able to find it - quite to the contrary: paragraph 1.2(e) specifically addresses steam piping and also re-invokes the original code of construction.

what am I missing?

 

[metengr]

tc7:
Thanks for the kind words. The way this works is that many Jurisdictions across the US have their own rules that specify what is enforced, and what is not enforced. For boilers and pressure vessels, it is mostly ASME Section I, and ASME Section VIII. BEP - boiler external piping is included within the scope of Section I for enforcement by Jurisdictions. This is where ASME B31.1 comes into play.

Beyond this, the Jurisdiction may have additional rules regarding other pressure retaining items. This is case by case specific.

The NBIC is an in-service, inspection, installation, repair/alteration and PRD code book. It says nothing about enforcement, it is intended to be used for repair of pressure retaining items. The Jurisdictions can adopt a Code book under law, like the NBIC, to address items under what they specifically regulate. Just because the NBIC deals with requirements for repair and alterations, it is only as good as those who enforce it.

Your Jurisdiction in question does not enforce this specific piping system, as they do for boilers and pressure vessels. With that said, the NBIC can't invoke it's own use in a Jurisdiction. What can be done, as you the owner, is to require the NBIC as part of your own internal specification or contract requirement for a repair organization.

 

[Wyzzard]

After reading this chain of posts I can see why you were (are) frustrated. The short answer to your question is that NBEP is outside the scope of NJ boiler law. So you do (or did) not need to have the repair performed to the NBIC. I woill add another bit of info for you. NJ has their own R certificate as well.

In the future if you have any repairs to make (or question) PLEASE go to your insurance inspector or their HO for help and clarification.