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Industry Newsletter Articles

All industry newsletter articles are editorials, and the opinions expressed herein are those of CodeWest alone

 

 

Pressure Vessel Laws Repairs and Alterations - API or NBIC?
by John M. Richardson, President, CodeWest

I recently attended a meeting of engineers and inspectors involved in maintenance and reliability of petrochemical facilities. The format was a four member panel that took questions from those in attendance. The first topic that came up was the pros and cons of a pressure vessel law in Texas.

I don't like laws but we have to have a few since people are people and tend to do what they have to do and not a lot more. However, applying the same standard to a large industrial plant with an inspection program and a small dry cleaner, school system, or theater is not quite right either. Some jurisdictions have laws that make allowances for large plants that have the expertise to manage the risks of failure responsibly. Extensions on boiler run times are fairly common and more and more jurisdictions are recognizing API 510 for vessels and not applying the simple time based inspection criteria that forces a shutdown no matter what the condition of the equipment every year or two.

The future will hold some conflicts. New technologies, such as Risk Based Inspection, will provide opportunities for even longer run times for specific systems. RBI may show shutting down to meet regulatory requirements creates a higher risk of failure. Since many of the regulations we deal with are actually “laws” some jurisdictions will be hard pressed to allow use of the new technologies as it will require a change that must be sent through the state legislature. That may sound simple but it is far from it. No technical reason for a change can protect a boiler & pressure vessel law from politicians bent on increasing state revenues. The lawyers and the lobbyists decide what goes to the legislature and no one is going to give those guys a shot at adding yearly operating and permit fees for every vessel in Texas (or your state) no matter how good the reason is for changing the law. Good boiler and pressure vessel laws should allow the introduction, development, and use of new inspection technologies. Laws that are restrictive, discourage innovation and limit the market for services should be replaced or, even better, eliminated.

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Repairs & Alterations: API 510 or NBIC?

The discussion took the inevitable turn toward what to use for Repairs and Alterations....API or NBIC?

There is a myth about the NBIC, “R” Stamps and maintaining “Code integrity” of pressure equipment so let's put it to rest right now within the context of pressure vessels as most questions seemed to center on API 510 vs. NBIC. The ASME Boiler and Pressure Vessel Code is written for new construction only. The name plate, code symbol stamp, and data report only cover new vessels and the activities of designing, fabricating, and testing new vessels. (The old joke is that the four leaf clover around the ASME “U” symbol is for good luck once you get it in service.) Once you repair or alter the vessel it is no longer in its original condition. It is still an ASME vessel but you have changed it to some extent. The rules under which you work on the vessel and who makes the required inspections during that work seem to be the point of controversy.

Both API 510 and NBIC contain rules for repairs and alterations and NBIC recognizes API 510. Both require an inspector who has passed an examination perform and sign off on the work performed. The quality program requirements in both are almost the same and the intent is identical even if the words are not. Under both documents you are required to assure that whatever is done results in a vessel which will operate safely for the intended service.

However, NBIC does require that the organization performing the repairs hold an “R” Stamp issued by the National Board of Boiler and Pressure Vessel Inspectors and that the work be inspected by an inspector holding a National Board Commission. API 510 allows the Owner/User to choose whatever repair organization it approves (which may be its own maintenance department, an “R” Stamp holder, or a local welding contractor) and for the API 510 inspector to make the inspections required and sign for the repair.

Does the vessel lose any of its “codeness” if an “R” Stamp holder and NB Inspector are not involved? No, the ASME Code ended when the name plate was attached. Now the governing documents are API 510 or NBIC.

Will you get as good a job if you use an API 510 Inspector rather than an NB Inspector? That all depends on the inspector and the repair organization. In theory there should be no difference either way. However, most things in life come down to individuals - not this code or that code.

My personal experience is that regardless of what code you use or what certification an inspector has the quality of the work performed will be determined by the quality of the people involved. It was my experience when I was a National Board Inspector and National Board ASME AI Supervisor that most repairs got inspected at the hydro. Although the AI was to be called prior to work beginning, a complete plan of the work to be performed reviewed with him, and an inspection plan set up; this seldom occurred. Normally someone called you up in the middle of the night and said something like: “We've got a hydro, why aren't you here?” That would generally be the first I'd heard about it. I would arrive there in the dark never having been on the site before and be expected to look at a hydro, sign an R1 Form, and leave just a happy as I could be. I wasn't a real “popular” AI. Getting them to come up with design information, material reports, PQR's, WPS's, WPQ's, PWHT charts, NDE procedures & personnel certification papers, calibration papers, and so on and so forth at 2 AM was generally frowned on. Some people would try to handle the situation by calling me endearing names like “Mother” and “Son” but flattery generally got them nowhere.

The one thing that always seemed to be true in a petrochemical plant (and generally saved the day, or night) was that there was a guy who worked for the Owner/User who had been following the job anyway. He would be familiar with the vessel, the process, the repair organization, and almost always had all the information I needed in a file. Sort of an Owner/User duplicate of the guy with the National Board Commission.

Sound kind of like an API 510 Inspector? Well it should and that is just what an API 510 Inspector is except that he had a big advantage over me. He was there when the job started, he had a staff of engineers familiar with the process to rely on for detailed advice, he had access to the job throughout the entire process. He also had a vested interest in the quality as his life and his coworkers lives depended on it.

The bottom line is you can get a good job either way. API 510 will serve you as well or better than the NBIC. It will assure good engineering practices are followed. Since you use your own personnel you will probably save money as you aren't paying for an outside NB AI or an “R” Stamp. You will not have to hold up the job waiting on an NB AI, and you will be involved and in charge of all aspects of the work.

Several years ago one refinery in Colorado estimated a savings of over $100,000.00 per year by using API 510 instead of the NBIC. How much can your plant save?

 

Do You Have the Experience to Qualify for the API Inspector Certifications?

One of the most common questions we get from students is about completing the experience portion of the API examination applications. The API 653 application specifically requires one year of experience in inspection and the others will probably add this requirement in the future. So what is “one year of experience in inspection”? The only API inspection code that currently outlines an inspection program is API 510. Paragraph 4.3 outlines the required written procedures that must be developed in order to have a true API 510 system. This list may also be used to help determine your experience level.

Review the areas covered in the outline and determine if you have been active in those areas. Just because your job title is not “Inspector” doesn't mean you haven't been participating in the inspection process. Activities such as positive material verification, assuring correct dimensions, assuring proper welder and NDE personnel qualifications, performing calculations to evaluate equipment, and auditing records are all inspection activities if they are related to assuring the mechanical integrity of pressure vessels, process piping or atmospheric aboveground storage tanks.

Another common question is “Do you think I can pass the exam with my background and education?” That's probably the harder of the two questions to answer. Generally speaking the more experience you have with the specific type of equipment the exam covers the better you will do. One area that concerns most candidates is the evaluation part of the exams commonly known as the “math” or “design” portion. These portions of the exams require you to be well versed in mathematical notation but you do not need to know how to perform any algebraic functions such as transposing formulas. It is usually more difficult to determine the proper formula to use and the values to use in the formula than it is to perform the mathematics involved.

Welding can also be a tough topic to master. The current exams require you to review welding procedures and qualification records to ASME Section IX and the requirements of the inspection and design codes. Unless you have specific experience in this area you will need training to master this task. Not knowing each individual personally makes it impossible to determine in a telephone conversation just how well they will do in any area. However, after presenting these courses for almost 10 years to over 2000 candidates in public courses alone I can say that if you meet the requirements to obtain the certification, come to class prepared, and study hard you have an excellent chance of passing the examinations.

The final decision as to the adequacy of your qualifications will be made by the API staff during the review of your application at API. If you have any serious doubts or questions you should contact them at (202) 682-8183 for specific guidance.

The old problem of needing the experience to get the certification and needing the certification to get the experience is still with us; but a reasonable review of your actual job function with a comparison to the API inspection documents will probably show that you have more "inspection" experience than you thought.

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More on Exams, Codes, Addenda and Supplements
by John Richardson, President, CodeWest, May, 1999

We always get questions on what codes and other publications to use for a course or examination. Each exam is written to specific editions including addenda or supplements. Knowing how the different publications work will help you to maintain your codes in a way that will allow you to build a library that will become more valuable as the years go by. Please keep in mind that the information in this article is dated and the rules used by the various societies that publish standards do change from time to time.

ASME Boiler and Pressure Vessel Codes
The ASME Boiler and Pressure Vessel Codes are issued as a new edition every three years. ASME recently changed the process for issuing the new edition and we now have the 1998 edition of the B&PV codes issued in July 98 rather than the traditional December. There are no colored addenda pages issued with the new 1998 edition. The new edition does contain some revisions and they are marked in the margins just as they are in the colored addenda pages. You will need to carefully review this new edition so revisions are not missed. The plan is to have only two yearly addenda issued on the colored pages to each edition with the initial addenda incorporated into the new edition. However, things do change.

ANSI/ASME Piping Codes
B31.3 & B16.5 are the two codes covered on the API 570 exam. These do not have the same edition and addenda schedule as the B&PV codes. (You may notice that we now use the 1996 edition of B31.3 while we are on the 1995 edition of the B&PV codes.) B31.3 does have editions issued every 3 years and addenda issued every year but not on a fixed date as the B&PV codes. The addenda to B31.3 are issued between mid September and mid October and become mandatory 6 months later. B16.5 does get a new edition every 3 years but has no regularly scheduled addenda.

API Inspection Codes and Recommended Practices
Inspection Codes: (510, 570 and 653) The API inspection codes are on a five year cycle. Revisions to these codes are called supplements rather than addenda and are issued yearly if one is issued at all (some years there is no need to issue a supplement). These supplements are usually dated December of the year issued but normally are actually printed and issued a bit later (as late as June). New editions come out every 5 years.

Recommended Practices
RP's are on a 5 year cycle as well. Supplements to RP's are generally not issued and the documents remain the same for the 5 year cycle. RP's contain recommendations as opposed to requirements so do not require changes as often. RP's may be “reaffirmed” after 5 years and reissued as is or they may undergo extensive revisions. Recently revised RP's include 651, 652, and 574.

What to use for an exam
The API ICP exams are written in exam construction sessions at the API Refinery Division meetings held twice yearly. These are normally in March or April and September or October. The exams for March and June of 1999 were constructed in late September of 1998. The June 98 570 exam did not cover supplement 2 as it was not available when the exam was written in the fall of 1997. The June 1999 570 exam will not cover the fall addenda to B31.3 (yellow) as it was not available in late September when the exam team met. The team does complete a form specifying the exact editions, addenda, and supplements used during an exam construction. This is made into the “Effectivity Sheet” for each exam by the API ICP personnel and is issued for each specific exam.

Why use those exact documents?
Changes in the technical content is the biggest reason but there are others as well. During the editing and revision of our courses we check each reference to any specific paragraph to be sure the information is the same and in the same place. Instructors commonly refer to information by paragraph and page number. If you do not have the correct documents you may not have the correct information and you will certainly end up on the wrong page sooner or later. It is in your best interest to have the exact edition, addenda and supplement specified by API for each exam. Your learning experience will be enhanced and so will your grade on the exam.

How to Handle Addenda, Supplements and Errata
I've had several calls recently from 510 candidates for the June 1999 510 exam about our 510 Pre study Guide. They were calling to tell me the answer key to the questions was off a bit and it was usually by just a subparagraph or two. The candidates were wrong due to a common and logical mistake. When they received their copy of API 510 from API publications it came with a supplement and they inserted the supplement into the 510 document. The problem is the supplement is not covered on the exam. The exam was “constructed” in October of 1998 - before the supplement was issued so no information could have been included from that supplement on the exam. In addition the lists issued by API and CodeWest show only the base document as required. This mistake was compounded by throwing away the old pages from the original 510 and the document could not be reconstructed. In addition to the exam being written prior to the issue of the addenda; there is a general rule of thumb used for inclusion of supplements and addenda when constructing API ICP exams: nothing gets used until it has been out one year. This may seem to be a long lead time at first but it really makes sense. Changes to technical documents often seem like a great idea when written and everyone on the committee certainly thinks they understand them when they vote for them. However; changes often turn up problems once they hit the streets.

I'm sure the inclusion of new Charpy requirements in ASME Section VIII, Div. 1 in the late 1980's seemed pretty straight forward to the guys who wrote it. However, over the next couple of years we saw several exceptions added to the code to accommodate those instances where the new requirements simply were not applicable or reasonable. A recent change in a formula in API-653 dropped the fill height of a brand new AST by 1 foot or made no significant difference at all - depending on who you spoke to. It often makes sense to wait before using a revision on an exam.

The downside is that the documents often get updated for “real world” use and the old pages are thrown away and gone forever. If you had a copy of API 510 and made inspections with it for a year and threw out the “old” pages when you put in the new supplement you would have no way of showing anyone why you had done the inspections the way you had in the previous year. You would have nothing to back up your past decisions. The same is true of all technical documents - ALL OLD PAGES SHOULD BE RETAINED WHEN REVISIONS ARE INSERTED - ALWAYS. This gives you a history of the requirements.

It is pretty easy to keep up with the changes to the ASME Codes since most come on different colored sheets of paper. The API documents are harder since all the pages are white and you have to hunt for those little notes in the margins to see which one you've got. Before I put any changes into an API document I mark each new page of the change with a colored marker and put a color code in the front of the document or I run a sheet or two of labels and put them on the pages. I also do the same to the “old” pages so I'll know what the document used to say and when it said it as well.

GET your addenda and supplements: First you have to actually GET your addenda and supplements to be able to put them in at all (much less do it properly). If your address changes call the supplier you got the codes from so your updates will be sent to the your new address. That's good advice on your ICP certification as well. API can not remind you to renew your 510, 570 or 653 certifications without a current and correct address.

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API 653 Certification Examination Major Changes in 2000

Major changes to the API 653 examination specification will become effective on the March 25, 2000 API 653 Exam. In addition to new evaluation techniques which have been added to API 653 over the past few years some other areas will be covered in more detail. This combination of changes has prompted us to expand our offering for API 653 Examination Preparation Training.

We will have completed a major revision of the CodeWest API 653 Exam Prep Course to accommodate these changes, and added the required amount of instruction to assure proper coverage of the additional material and activities that will be on the new API 653 Exam. We will also add some techniques that have proven their value from other CodeWest Exam Prep Course curriculum and presentations. This new CodeWest Exam Prep Course will represent the best and most complete coverage of the information specified in the Body of Knowledge for API 653 we have ever presented.

The CodeWest API 653 Exam Prep Course is scheduled to complete right before the API 653 Exam to reduce travel expenses for course participants. The schedule has been altered to allow more travel time for course participants wanting to take the API 653 Exam at a site other than Houston. The price has increased, however, this exam prep course still represents a very high value for the investment.

If you plan to take the API 653 Examination on March 25, 2000, contact CodeWest at 281-392-4540 and we will forward a complete CodeWest Exam Prep Course registration and information package. Be sure to note all registration deadlines as well. You must be registered with the API Individual Certification Program by one of the deadlines shown to take the Exam on March 25th. The next API 653 Exam will be given on September 23, 2000.

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