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What ASME section covers in-service repairs and alterations? 1
- Thread starter KernOily
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74Elsinore-
No, the ASME Code stops when the U stamp goes on. After that you're in API 510 or NB-23 (NBIC) territory. If you are in California (Lake Elsinore?), you'll have to dredge up a copy of the 1992 edition of the NBIC to be, strictly speaking, legal. In that edition, you'll want to check out Appendix C-R on page 125. See also
jt
No, the ASME Code stops when the U stamp goes on. After that you're in API 510 or NB-23 (NBIC) territory. If you are in California (Lake Elsinore?), you'll have to dredge up a copy of the 1992 edition of the NBIC to be, strictly speaking, legal. In that edition, you'll want to check out Appendix C-R on page 125. See also
jt
Although... the ASME does have some post construction activities (perhaps more in line with FFS, API-579) in the works:
jt
jt
The in-service repairs of pressure retaining items does NOT fall under ASME Boiler and Pressure Vessel (B&PV). ASME B&PV Code is a construction code, not an in-service inspection or repair code. In -service inspection, repair and alteration activities are either governed by API (petrochemical) or by the National Board Inspection Code (NBIC) NB-23. You should first determine what the Jurisdictional requirements are where the object is installed because some Jurisdictions do not regulate pressure vessels.
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I don't get it. Why is it the R-1 form looks just exactly like a U-1A if it's not an ASME document? Um... I think I just answered my own question... the U-1A in Sec VIII says "Suggested Format" at the top, so I guess you don't HAVE to use their format; they don't 'own' it, per se.
OK - can anybody give me a working definition of an alteration?
You wouldn't believe how much misinformation is out there on this topic...
THanks for your help ! ! !
Thanks!
Pete
OK - can anybody give me a working definition of an alteration?
You wouldn't believe how much misinformation is out there on this topic...
THanks for your help ! ! !
Thanks!
Pete
74Elsinore-
Well, the formal definition is in the NBIC. Basically, an alteration is any change to the pressure containing envelope of the vessel that isn't classified as a repair. Adding small nozzles or nozzles identical to existing ones are examples of repairs. Changing information on the U1 form would generally be an alteration. A change in dimensions, material, pressure, temperature (rerate/derate), etc, even if no physical work is done would be an alteration. A repair using physically identical parts but using new allowable stresses would be an alteration. For example, the old head fabricated in 1980 is 1" thick (new) SA516-70. It has corroded and is replaced with a 1" thick SA516-70 head. I have two choices: 1) call it a Repair (use the 1980 allowable stress) and keep the original CA, or 2) call it an Alteration (use the current allowable stress), and increase the CA on the head. I chose option 2. It buys us more time with the new head before it wears out and needs to be replaced.
Well, the formal definition is in the NBIC. Basically, an alteration is any change to the pressure containing envelope of the vessel that isn't classified as a repair. Adding small nozzles or nozzles identical to existing ones are examples of repairs. Changing information on the U1 form would generally be an alteration. A change in dimensions, material, pressure, temperature (rerate/derate), etc, even if no physical work is done would be an alteration. A repair using physically identical parts but using new allowable stresses would be an alteration. For example, the old head fabricated in 1980 is 1" thick (new) SA516-70. It has corroded and is replaced with a 1" thick SA516-70 head. I have two choices: 1) call it a Repair (use the 1980 allowable stress) and keep the original CA, or 2) call it an Alteration (use the current allowable stress), and increase the CA on the head. I chose option 2. It buys us more time with the new head before it wears out and needs to be replaced.
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Hey jte - thanks for the terrific reply.
Here is my situation; I'd like to hear your comments. My client has an idle vessel in his boneyard that he wants to return to service but in a different service from the one for which the vessel was originally built. Metallurgy, MAWP, etc., all is OK for the new service. The vessel has some internals consisting of pipe downcomers and risers, and partitions and weirs made from plate and expanded metal. The new service requires no internals so the client wants to remove them all by cutting them all out and grinding the attachment welds smooth.
I say this is not an alteration because (1) these changes have no affect on any pressure-containing part; (2) these changes do not affect any of the information on the original U-1A. What do you think? Thanks ! ! !
Thanks!
Pete
Here is my situation; I'd like to hear your comments. My client has an idle vessel in his boneyard that he wants to return to service but in a different service from the one for which the vessel was originally built. Metallurgy, MAWP, etc., all is OK for the new service. The vessel has some internals consisting of pipe downcomers and risers, and partitions and weirs made from plate and expanded metal. The new service requires no internals so the client wants to remove them all by cutting them all out and grinding the attachment welds smooth.
I say this is not an alteration because (1) these changes have no affect on any pressure-containing part; (2) these changes do not affect any of the information on the original U-1A. What do you think? Thanks ! ! !
Thanks!
Pete
74Elsinore-
Funny, I was poking around our boneyard about an hour ago and in passing admired a few of the vessels and exchangers we have there. A sorry lot, indeed.
In your case, assuming a VIII Div. 1 vessel, I fully agree with your interpretation for both of your reasons. Just be sure to not grind into the shell. You might suggest that your client consider cutting the internals back to about 1/4" away from the shell to avoid inadverdent gouging of the shell. If you have a Div. 2 vessel, some additional pondering might be in order.
After a thorough inspection, internal and external (with insulation removed to check for CUI), the vessel should be good for continued service. I'd strongly consider either a Code minimum hydrotest (not necessarily the shop hydro pressure) or some other water test ("service test") at MAWP or slightly higher.
Funny, I was poking around our boneyard about an hour ago and in passing admired a few of the vessels and exchangers we have there. A sorry lot, indeed.
In your case, assuming a VIII Div. 1 vessel, I fully agree with your interpretation for both of your reasons. Just be sure to not grind into the shell. You might suggest that your client consider cutting the internals back to about 1/4" away from the shell to avoid inadverdent gouging of the shell. If you have a Div. 2 vessel, some additional pondering might be in order.
After a thorough inspection, internal and external (with insulation removed to check for CUI), the vessel should be good for continued service. I'd strongly consider either a Code minimum hydrotest (not necessarily the shop hydro pressure) or some other water test ("service test") at MAWP or slightly higher.
74Elsinore -
Regarding your specific situation, I would call your local Jurisdiction to make them aware of this situation. If the vessel was idle that means it once was in service, and is registered with the National Board. To return a vessel to service, it will probably require a Jurisdictional inspection by a commissioned NB Inspector. They will make the call regarding specific inspection requirements and review of operating and maintenance logs prior to recommending an operating certificate. If you don't have a Jurisdiction, your insurer will determine specific inspection requirements and review of data prior to returning to service.
Questions like how the vessel was stored, operating and maintenance history will need to be addressed as a minimum.
Regarding your specific situation, I would call your local Jurisdiction to make them aware of this situation. If the vessel was idle that means it once was in service, and is registered with the National Board. To return a vessel to service, it will probably require a Jurisdictional inspection by a commissioned NB Inspector. They will make the call regarding specific inspection requirements and review of operating and maintenance logs prior to recommending an operating certificate. If you don't have a Jurisdiction, your insurer will determine specific inspection requirements and review of data prior to returning to service.
Questions like how the vessel was stored, operating and maintenance history will need to be addressed as a minimum.
I concur with metengr with regard to jurisdiction issues. I just recovered my copy of NBIC and you are correct that the action planned by you does not constitute repair or alteration.
A couple of thoughts though:
1. It might happen that during the removal process someone gauges into the shell. That willl immediately change the operation into repair. You have to be prepared for that. Use special procedure like gouge away from shell and grind smooth or something similar. Have a WPS ready and a repair procedure to cover potential mishap and not to ba caught with your belt down when it happens. I find it easier to negotiate with the Jurisdiction if I have a plan ready.
2. You are using a vesel that was meant for another service. Does your new service require the same or, maybe, higher corrosion allowance? That could potentially require new vessel calculations and re-rating of the vessel that constitutes alteration.
3. Also operating temperatures: minimum and maximum, original and intended should be considered. You say metallurgy is ok so I assume you have already considered that.
Putting Human Factor Back in Engineering
A couple of thoughts though:
1. It might happen that during the removal process someone gauges into the shell. That willl immediately change the operation into repair. You have to be prepared for that. Use special procedure like gouge away from shell and grind smooth or something similar. Have a WPS ready and a repair procedure to cover potential mishap and not to ba caught with your belt down when it happens. I find it easier to negotiate with the Jurisdiction if I have a plan ready.
2. You are using a vesel that was meant for another service. Does your new service require the same or, maybe, higher corrosion allowance? That could potentially require new vessel calculations and re-rating of the vessel that constitutes alteration.
3. Also operating temperatures: minimum and maximum, original and intended should be considered. You say metallurgy is ok so I assume you have already considered that.
Putting Human Factor Back in Engineering
Well, its ok to be conservative, but I'd make a couple of points here: First, the vessel may or may not be NB registered. In any case, as long as the nameplate wasn't removed and the NB notified that the vessel was scrapped, it doesn't matter. Idleing a vessel is not something which the NB has any jurisdiciton over. Changing a vessel's service also does not invoke any NB jurisdiction.
Second, I'd like to see chapter and verse where it states that a Jurisdiciton or an AI must be involved in this case. I don't believe it exists. The plant's regular inspection program (no AI's necesserely involved here) must satisfy itself that the vessel is fit for continued service. The plant's engineering staff or consultant must satisfy itself that the vessel is fit for the proposed new service. The corrosion allowance will not necessarily have to be changed. The corrosion rate may change with the new service, but that may simply mean that the vessel will reach its retirement thickness a bit earlier (unless derated for lower T/P to increase CA). That's up to the plant's engineering and metallurgist and inspection and management. No AI or jurisdictional involvemnt req'd.
jt
Second, I'd like to see chapter and verse where it states that a Jurisdiciton or an AI must be involved in this case. I don't believe it exists. The plant's regular inspection program (no AI's necesserely involved here) must satisfy itself that the vessel is fit for continued service. The plant's engineering staff or consultant must satisfy itself that the vessel is fit for the proposed new service. The corrosion allowance will not necessarily have to be changed. The corrosion rate may change with the new service, but that may simply mean that the vessel will reach its retirement thickness a bit earlier (unless derated for lower T/P to increase CA). That's up to the plant's engineering and metallurgist and inspection and management. No AI or jurisdictional involvemnt req'd.
jt
jte;
<<Second, I'd like to see chapter and verse where it states that a Jurisdiction or an AI must be involved in this case. I don't believe it exists. The plant's regular inspection program (no AI's necessarily involved here) must satisfy itself that the vessel is fit for continued service. The plant's engineering staff or consultant must satisfy itself that the vessel is fit for the proposed new service.>>
Have you dealt with Jurisdictions? From your response above it does not sound like you have dealt with any. The bottom line is that the NBIC mentions in many places that the Jurisdiction or Jurisdictional Authority takes precedence over the NBIC. As far as I am aware, any Jurisdiction in the US that regulates boilers AND pressure vessels typically issues operating certificates under their own set of rules and regulations. Thus, you need to have the Jurisdiction on board and in agreement with placing a vessel back in service. Those are the rules to live by -plain and simple.
The only exception to this is if the vessel is on Federal property or under an owner-user program. If this vessel is under an owner-user inspection program, I will bet that the Inspector ( a National Board commissioned) will follow the advice of the NBIC (see Section RB) in addition to reviewing previous operating history, operational and maintenance logs and will provide additional supplemental requirements, period.
<<Second, I'd like to see chapter and verse where it states that a Jurisdiction or an AI must be involved in this case. I don't believe it exists. The plant's regular inspection program (no AI's necessarily involved here) must satisfy itself that the vessel is fit for continued service. The plant's engineering staff or consultant must satisfy itself that the vessel is fit for the proposed new service.>>
Have you dealt with Jurisdictions? From your response above it does not sound like you have dealt with any. The bottom line is that the NBIC mentions in many places that the Jurisdiction or Jurisdictional Authority takes precedence over the NBIC. As far as I am aware, any Jurisdiction in the US that regulates boilers AND pressure vessels typically issues operating certificates under their own set of rules and regulations. Thus, you need to have the Jurisdiction on board and in agreement with placing a vessel back in service. Those are the rules to live by -plain and simple.
The only exception to this is if the vessel is on Federal property or under an owner-user program. If this vessel is under an owner-user inspection program, I will bet that the Inspector ( a National Board commissioned) will follow the advice of the NBIC (see Section RB) in addition to reviewing previous operating history, operational and maintenance logs and will provide additional supplemental requirements, period.
Some vessels are deswigned fore a specific service and is the new service is not comparable, that alone will be an alteration, i have done that several times and 2 out of 5 you can not alter the vessel for the new service.
I suggest you contact CALIFORNIA DOSH ion anaheim CA.
ask for the Authorized field inspector,
R stamp is needed for repairs and alt.
ASME and Natl Bd are like Brothers, they do not ge along well thou.
ER
I suggest you contact CALIFORNIA DOSH ion anaheim CA.
ask for the Authorized field inspector,
R stamp is needed for repairs and alt.
ASME and Natl Bd are like Brothers, they do not ge along well thou.
ER
metengr-
Hmmm... I'm on a first name basis with the Chief Inspector in my state, two state AI's, and one AIA AI... Deal with the Jurisdiction several times a year, usually with regards to difficult or unusual situations or more routine repairs/rerates/alterations. Usually find that we can reach an agreement on our issues, sometimes after a vigorous discussion quoting chapters and verses of the Code. I guess we just have different experiences with our Jurisdictions.
generalblr-
Been there, done that. But the California Department of Industrial Relations, Divison of Occupational Safety and Health, Pressure Vessel Unit's Anaheim office, adjacent to Anaheim Stadium and the Amtrak station (unless they've moved) is just the So. Cal. branch office. Since I don't live 5 miles away from there anymore, I tend to deal with the head office in Oakland. As for designs for a specific service, that's why I mentioned that a Div. 2 vessel would require additional effort. Service (other than lethal) does not enter into Div. 1 code work, though it should be considered in the design and evaluation for re-use - but by the owner's engineer or consultant, not the AI.
jt
Hmmm... I'm on a first name basis with the Chief Inspector in my state, two state AI's, and one AIA AI... Deal with the Jurisdiction several times a year, usually with regards to difficult or unusual situations or more routine repairs/rerates/alterations. Usually find that we can reach an agreement on our issues, sometimes after a vigorous discussion quoting chapters and verses of the Code. I guess we just have different experiences with our Jurisdictions.
generalblr-
Been there, done that. But the California Department of Industrial Relations, Divison of Occupational Safety and Health, Pressure Vessel Unit's Anaheim office, adjacent to Anaheim Stadium and the Amtrak station (unless they've moved) is just the So. Cal. branch office. Since I don't live 5 miles away from there anymore, I tend to deal with the head office in Oakland. As for designs for a specific service, that's why I mentioned that a Div. 2 vessel would require additional effort. Service (other than lethal) does not enter into Div. 1 code work, though it should be considered in the design and evaluation for re-use - but by the owner's engineer or consultant, not the AI.
jt
jte;
From your post, I see that you understand how to deal with a Chief Inspector and Jurisdictional issues. My only point to my responses above is that not all companies or personnel have these types of close relationships. Oh by the way, I am an NBIC main committee member, and I also know about half of the Jurisdictional Chiefs in the US. Relationships are everything in this business.
From your post, I see that you understand how to deal with a Chief Inspector and Jurisdictional issues. My only point to my responses above is that not all companies or personnel have these types of close relationships. Oh by the way, I am an NBIC main committee member, and I also know about half of the Jurisdictional Chiefs in the US. Relationships are everything in this business.
As well as the jurisdictional authority one thing not mentioned is that the facilities' insurance carrier, whose AI you will use, will have to sign off on any change in service. If you have any doubts read your policy a little closer.
We have an internal inspection group that does all of the vessel inspections for the site. We have the AI involved in about 80% of the inspections by either by participating or review. We are an owner-user and have an U and R stamp which requires our fab shop to have the AI involved. We have all this in a non-code state that only requires operating permits for fuel storage tanks.
During my whole career we always worked with our AI though we accepted different AI's inspection, specific vendor requirements, for outside vendors on new equipment and offsite repairs. This work is reviewed by our AI.
In the US you had better have an AI involved, as well as all the paperwork you can muster, if there is ever an event with the subject vessel.
We have an internal inspection group that does all of the vessel inspections for the site. We have the AI involved in about 80% of the inspections by either by participating or review. We are an owner-user and have an U and R stamp which requires our fab shop to have the AI involved. We have all this in a non-code state that only requires operating permits for fuel storage tanks.
During my whole career we always worked with our AI though we accepted different AI's inspection, specific vendor requirements, for outside vendors on new equipment and offsite repairs. This work is reviewed by our AI.
In the US you had better have an AI involved, as well as all the paperwork you can muster, if there is ever an event with the subject vessel.
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