Sec VIII Div 1 Appendix 47 1

[JamesKerr]

Hello,

I'm looking for input regarding the how people are interpreting the new 2021 appendix 47. This is a preliminary draft I've written and was wondering what you folks thought.

(Note I work for a div 1 company, but found the Div 2 appendix to be a much more comprehensive guide)

For the purpose of our manual we use Technical Manager in lieu of Certifying engineer. We have a few professional engineers (Registered in Canada) all of whom will be fulfilling the role and are experienced to be Certified Engineers. At least for now there seems to be no reason for our company to divide things into the three new categories; Engineer, Certified Engineer, Designer.



4.1) All pressure vessel design and engineering shall be done and certified by the Technical Manager TCM
4.2) The TCM shall have experience documented on Record of Experience for TCM, exhibit F19.1, describing the complexity and scope of the individuals experience
4.3) The QCM shall appoint the TCM based on their experience as documented on exhibit F19.1. The appointment shall be in writing on Certification of Personnel in Responsible Charge exhibit F19.2.
4.4) The TCM shall be a Registered Engineer in the province of Quebec, who has completed the equivalent of a 4 year engineering degree and have 4 years of experience in the design of pressure vessels.
4.5) TCM Record of Continuity Form 19.3 shall be used to track a minimum frequency of once every 36 months in the following design categories.
4.5.1)Numerical Analysis
4.5.2)Fatigue Assessments
4.5.3)Seismic reactions
4.1.1)Quick-actuating closures

4.1.2)The TCM shall design at least one vessel per each category once every 36 years months.
Appendix 47-6 (3) SEC VIII Div 2 2-J.4.2

4.2) The TCM shall have training in the use and understanding of any numerical analysis computer programs from one of the following:
4.2.1) Two years or more of experience performing design analysis
4.2.2)have received instruction in the use and understanding of any numerical analysis computer programs from one of the following:
• the developer of the computer program (e.g., the software vendor)
• A training course acceptable to or licensed by the developer
• A Certifying Engineer with requisite knowledge of the computer program and qualifications to train others on its use


4.3) To maintain the active status in a design category the engineer may perform a mock design.
4.4) Activation and reactivation in the case of expiry may be done by one of the following methods
4.4.1)Continuity of the design activity for 1 month period
4.4.2)Completion of 8 or more hours of training relative to the category.
4.4.3)Taught or attended a training course or seminar covering the design aspect.
4.4.4)Attend a technical society meeting related to the topic
SEC VIII Div 2 2-J.4.3
4.5) The TCM shall maintain a continued education of at least 30 hours per 2-year period.
4.6) The User Designated Form from appendix KK shall be completed for all SEC VIII Div 1 designs with one of the following criteria.
4.6.1)Superimposed static reactions UG-22(c)
4.6.2)Cyclic or dynamic reactions UG-22(e)
4.6.3)Loadings due to wind, snow, or seismic reactions UG-22(f)
4.6.4)Impact reactions UG-22(g)
4.6.5)Temperature effects UG-22(h)
4.6.6)Abnormal pressures UG-22(i)

Looking forward to your feed back.

James.

 

[VQ35]

Hi James,

I'm surprised to find this thread so quiet, I'd been assigned the same task as you in my organization. Things got busy towards the end of the year and this task got pushed.

What is your take on Table 47-5-1, specifically "Design due to seismic reactions"? The sub-bullets a) and b) both refer to Dynamic Analysis Procedures which we do not perform. We regularly consider seismic loads, and our software performs Equivalent Static Force calculations, I would understand this activity is not intended to be included as part of Table 47-5-1.

Ken

 

[IdanPV]

Hello,

CIS GmbH Consulting Inspection Services has published a very good design personnel qualification form which I think you may find helpful,

https://www.cis-inspector.com/downloads/Design_Personnel_Qualification_Rev-6.pdf

 

[JamesKerr]

Ken,

I took the lack of response to mean that everyone was equally confused...

My shop is in the same situation for the seismic calculations and came to the same conclusion as you.

Regards
James

 

[dig1]

James/Ken,

There is another issue which you will need to address which ASME likely misspoke about with respect to installations in the United States. Once the 2021 Code is adopted by a State it then becomes law in that jurisdiction. However, States also have licensing Boards for professional engineers. Now that it is a legal requirement that a design be stamped by a PE (via the adoption of the 2021 edition) the State licensing law/rules will kick in and the engineer needs to be licensed in the State of installation (not the State of manufacture). Regardless of what Appendix 47 states it cannot supersede/contradict the State licensing law. If a State allows engineers from other jurisdictions to seal instruments of service with another jurisdictions seal then that would be another matter; however, I don not know of many, if any, instances where this is acceptable.

Pressure vessels requiring calculations and/or drawings to be stamped by a PE (the State engineering rules/laws will stipulate what items/documents need to be stamped and it is likely both calculations and drawings need to be stamped) are now like a manufactured metal building (think of a Butler style building) that may be manufactured in one State but need drawings and calculations to be stamped by an engineer licensed in the State of installation. State Building Code laws require structural building drawings to be stamped by a licensed engineer; now the branch of the State governing pressure vessels is requiring in some instances that the design of the vessel be stamped, again via adoption of the 2021 Code. Also, any claim for an industrial exemption very likely won't apply in generic cases.

Because the laws regulating professional engineers are set by the individual States an ASME Code Interpretation or Code Case or what your AI says doesn't count to determining if an engineer from one State can stamp a design for a vessel going to a State where the stamping engineer is not licensed (i.e. an engineer from PA cannot stamp calcs and/or drawings for a vessel going to NC).

I have no idea how this is going to play out. Currently I'm preparing an inquiry to my home state licensing board for clarification.

BR,

Patrick

 

[JamesKerr]

Very interesting Patrick,
I'd appreciate it if you could keep me informed of any news you hear back from your inquiry.
James