Relief Valve testing requirements 2

[dwene]

Our company is located in Louisiana. We are an LNG facility with approximately 140 relief valves. My past experience is to always use a third party inspection company to do our annual relief valve testing (annual because one of the LNG codes requires it).
Our company is going to have our mechanics test the relief valves this year in order to save money. My question is...are we allowed to test our own relief valves? We have no certifications.

All of our relief valves have inlet and outlet blocks and bleeds and the systems are such that we can easily prepare the valves to be safely tested in line using nitrogen as the test media.

My "gut" tells me we should stick with the NBIC approved third party but I cannot back this up.

Any thoughts?

David Wene, P.E.

 

[Duwe6]

Your company can do the work internally If They hold a 'VR' ASME code-stampas an Owner-User.

Lacking a Code Stamp, you can 'Test Only' -- absolutely no repairs, resetting, lapping of nozzles, etc. Every PRV that fails your in-house 'Test Only' will need to be sent to a certified Code Valve shop.

Basically, I would either send all the PRV's out [or bring a Test & Repair trailer on-site], or aquire the expertise & training to sucessfuly apply for an "Owner-User" VR stamp. Trying to do any work on Code PSV's without the knowledge is criminal. Alternatively, if you spend the time and money to train up and buy the test equipment and knowledge & experience to properly perform the work, go ahead and become Code-certified. Trying to stand in the middle leaves untrained, uncertified people working on Code safety items. You are messing with the last device between the system and catastrophic release and/or fire, with resultant damage in the $$ millions, and probable maiming and/or death. The risk is immense, the cost savings is puny compaired to the new, added risk exposure. Refer your in-house 'genius' to any good AI or Insurance underwriter.

Alternatively, ask your genius if he would let some $8/hr immigrant laborers work on the brakes of his wifes car. Same idea.

 

[dwene]

Excellent response. Any other have input? FYI - we would send any that fail our internal test to the VR shop down the road.

I would appreciate as many responses as possible. I've lost the first round of debate and would like to be better armed with for my next argument.

 

[don1980]

Qualified and trained personnel are a definate requirement, but I'm not sure that means the repair facility must have a VR stamp. I know of some global operating companies that have internal valve shops (non-VR rated) that repair safety valves. These are skilled valve specialists, but they just don't have VR certification from the National Board.

Refer to API 510. That explains the qualification requirements. Possibly it would be Ok for your internal folks to do the pop test and visual inspections, but I'd leave all repair tasks to a qualified valve technician.

BTW.... Duwe6, some of us married folks might not answer that break repairman question the same way as you would

 

[Duwe6]

To meet ASME Code, any and all valve repairs are to be done under a VR codestamp.

You can 'pop-test'and reset your own valves w/o a VR stamp, but everything else requires the Stamp. Fully trained and qualified people, but lacking certification; or a fully equipped, properly calibrated valve test bench without a VR stamp are not allowed to work on Code valves. This is a legal requirement. Thus my firm suggestion that dwene refer his boss to an AI or Insurance underwriter. Wouldn't hurt to have the corporate legal advisor to look at this too. Might want to have a de-fibrillator standing by -- this proposal may give Legal a heart attack.

 

[dwene]

Quick update...I made my recommendations and the bosses disagree with me. They said we don't need to check with insurance or legal and have canceled the PO that we gave to the RV shop I've used for years.
What do I know...I just the only PE at our site.

 

[Duwe6]

Try copying off all of this discussion and submitting it to your CEO [your boss's boss, or higher]. Maybe he/she will have enough sense to see that this is NOT a place to try to same money.

Alternatively,QUIT. IMMEDIATLY.

Nobody will hire anyone from the [2005] MI dept of BP after the debacle in Houston that killed 15 & injured 108 in 2005. Don't let this be you.

 

[don1980]

Duwe6...please cite your source for saying this is a legal requirement. I'm not saying you're wrong, but I haven't seen this in my review of ASME & API documents.

In God we trust.....everyone else ought to cite references.

 

[Duwe6]

NBIC - "National Board" requires that all repairs to Code pressure relief devices be made by a Code-Certified shop possessing a "VR" stamp. ASME and NBIC have been incorporated into USA and Canadian law.

In USA, the only non-Code states are Idaho and Wyoming [all Canadian provences mandate Code]. In the rest, ASME & NBIC have force-of-law. Thus, using 'Joes Valve and Fender shop' to repair your Code PRV's is a legal violation, [assuming Joe doesn't hold a VR stamp].

 

[don1980]

Duwe6... are you're comments based on ASME Sec I and Sec VIII or just for Sec I?

For Sec VIII there are states other than those you mentioned which are not code states. For example, the OP is in a state (Louisiana) which isn't a code state.

 

[BenThayer]

i think the "not a code state" argument is a red herring. OSHA's general purpose clause basically says you need to follow good engineerig practices or GEP.

as far as i am concerned, GEP is defined by the codes. not sure i would quit over it but i would have it fully documented via e-mails, etc.

the problem i have when good people quit is that those that remain are even less likely to do anything right. this can be the beginning of a "death spiral"

on the other hand, if you are of retirement age anyways, you might consider the whistleblower card if you can snag a % of the fines. i think this has a better likelihood of a pay-out than most lotteries.

 

[BenThayer]

fyi, a pfizer whistleblower hit the jackpot for over $50 million:

http://www.mesrianilaw.com/Pfizer-Whistleblower-Gets-More-than-51.5-Million.html