agenda - the national board of boiler and pressure vessel
TRANSCRIPT
Date Distributed: June 14, 2013
SUBCOMMITTEE REPAIRS and ALTERATIONS
AGENDA
Meeting of July 17, 2013 Columbus, Ohio
The National Board of Boiler & Pressure Vessel Inspectors 1055 Crupper Avenue
Columbus, Ohio 43229-1183 Phone: (614)888-8320 FAX: (614)847-1828
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1. Call to Order – 8:00 a.m. 2. Announcements 3. Adoption of the Agenda 4. Approval of Minutes of January 16, 2013 5. Review of the Roster (Attachment 1)
Mr. David Martinez would like to become a member of the subgroups Repair and Alteration General and Specific. Please see his attached resume. A vote will be taken. (Attachment 1, pp. 2-4)
Mr. Marty Toth would like to become a member of the subgroups on Repair and Alteration General and
Specific. Please see his attached resume. A vote will be taken. (Attachment 1, pp. 5-6) Mr. Randal Cauthon would like to become a member of the subgroups on Repair and Alteration
General and Specific. Please see his attached resume. A vote will be taken. (Attachment 1, pp. 7-10) Messrs. Ed Ortman and Walt Sperko are eligible for reappointment to both SGs Repair and Alteration
General and Specific. A vote will be taken.
6. Interpretations (Attachment 2) IN13-0301 - Part 3, 3.2.2 c)SC on Repair and Alteration, - Question 1: Does Part 3, 3.2.2 c) prevent an "R" Certificate Holder with the capabilities within his shop from rolling and welding a shell or other such items as headers, nozzles,(flange to pipe) for replacement in a vessel or boiler has is repairing or altering? Answer 1: No (Attachment 2, pp.11- 13) Question 2: If the answer is No to the above question, if the same Certificate Holder could not fabricate the replacement items within his capabilities and received these parts from an outside source then these items would have to be fabricated by an organization holding the appropriate Code Certificate of Authorization. Answer 2: Yes. January 2013 The SC reviewed the Inquirers question and reply. The SC discussed the item along with several past interpretations. The SC developed a new question and reply based on existing NBIC text and with a proposed code change to further clarify that an “R” Certificate Holder during manufacturing of parts with welding or fabrication for an ASME component can be done provided the same “R” Certificate Holder installs the welded part. A motion was made and the proposed question and proposed code change to further clarify the interpretation and reply were passed unanimously. This item was returned to the subcommittee by the NBIC Committee as the proposed question and reply was lost electronically. July 2013 Mr. Wielgoszinski is expected to report. IN13-0401 - Part 3, 3.2.5, SC Repair and Alteration- Question 1: Is it the intent of the requirements in paragraph 3.2.5 that calculations be both completed and also made available to the Inspector for review prior to the start of any physical work? Answer 1: Yes (Attachment 2, pp.14- 20) Question 2: Does the requirement in paragraph 3.2.5 that calculations be completed and also
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mean that the calculations as required by paragraph 3.2.5 be an "R" Certificate Holder? Answer 2: No. However the R-Certificate holder responsible for executing the "Design Certification" portion of the R-2 Form, must assure himself that the design complies with the NBIC and by signing the Design Certification accepts responsibility for the design. Alternate Proposed Reply Question 2: Yes; "the organization" in paragraph 3.2.5 refers to the "R" Certificate holder responsible for preparing and executing "Design Certification" portion of the R-2 Form. This does not preclude the "R" Certificate Holder from having the calculations prepared or otherwise obtaining the calculations from others, but the "R" Certificate older must assure himself that the design complies with the NBIC and by signing the Design Certification accepts responsibility for the design. Question 3: If an alteration involves the Installation of a replacement part (as defined in Paragraph 3.2.2 c) that has been designed, fabricated, inspected and stamped in accordance with the original code of construction and for which the part fabricator has documented on the partial data report that they have certified the design of the part for a specific set of design conditions (MAWP,MAWT,MDMT, corrosion allowance, etc.), must the "R" Certificate Holder responsible for executing the Design Certification on the R-2 Form obtain the calculations from the part fabricator and make available for review by the Inspector? Answer 3: No, however the "R" Certificate holder responsible for executing the Design Certification must assure that the design conditions certified for the new part are consistent with the original vessel design conditions. Additionally the R Certificate holder would be responsible for assessing whether the installation of the new part impacted in any manner the existing components in the overall vessel design and for completing any calculations that might be required to address such impact. January 2013 This Inquiry was reviewed by the SC and because of the complexity related to how review of calculations and approval of calculations is made, the SC assigned R. Cauthon as Project manager to develop a new question and reply. This is considered a Progress report. July 2013 Mr. Cauthon is expected to report. IN13-0501 - Part 3, 3.3.3 and 3.4.2 SC Repairs and Alterations - Question: May a R and U Certificate Holder make either a repair or an alteration to a pressure vessel by installing an new expansion joint, either over, or in place of an existing expansion joint that may have failed, or is damaged and may be expected to fail; by fabricating a new expansion joint as a U stamped Part in complete accordance with Section VIII Div. 1 Appendix 26,, then cutting this new Part into two pieces longitudinally so that it may be installed by field welding two new longitudinal welds without disassembly of the pressure vessel if: a) the two new longitudinal welds are typed 1 per table UW-12. b) the installation does not permit radiographic examination, c) the backside of the weld is not accessible for either visual or penetrant examination, d) design calculations of these welds at .6 WJE are adequate to the existing design and, e) the vessel is satisfactorily hydrostatic tested at 1.3 times MAWP? Condition 1: A new expansion joint of a larger diameter will be installed over the existing joint. Condition 2: The old joint is removed and one of the same diameter will be installed in its place. Reply: Yes if acceptable to the Inspector and when required the Jurisdiction. Condition 1 being an alteration and Condition 2 being a repair. (Attachment 2, pp.21-24)
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7. Action Items (Attachment 3) NB08-0322 - Part 3 3.2 SG R/A General - Add a new paragraph to 3.2 General Requirements for Repairs and Alterations to address change of service for a pressure vessel. These requirements should caution inspectors, owners, repair organizations and jurisdictional authorities of the inherent dangers involved when changing service. A new supplement should be added to address the specific requirements for repairs and alterations of pressure vessels that have been converted from one service to another. A task group representing all three parts of the NBIC has been formed under the leadership of Bob Wielgoszinski. Task group members from R & A are P. Edwards and B. Schulte. (Attachment 3, pp. 25-35)
July 2008 A task group was assigned. July 2011
A report was provided by Bob Wielgoszinski. The TG has made progress on this item and may provide a proposal before the January, 2012 NBIC meeting.
January 2012 A progress report was provided by B. Schulte and a goal of having a proposal for the July 2012 meeting was discussed. July 2012 A progress report was provided by Mr. Paul Edwards. January 2013 It was unanimously approved to send a comment only letter ballot to all committee members regarding this item. July 2013 Mr. Wielgoszinski is expected to report. NB10-0110 - Part 3 S6.19.1 TG DOT- Combine and clarify requirements within S6.15 for TR Forms, S6.18 Preparation of TR-Forms and S6.19 for Reports of Repairs, Alterations and Modifications. (Attachment 3, pp. 36- 41) July 2010 Mr. Stan Staniszewski presented a progress report. The task group of Stan and Jim Riley are aiming to present by the January 2011 meeting. January 2011 No report was presented. July 2011 No report was presented. January 2012 A progress report was provided by S. Staniszewski and he indicated the DOT had a working draft and was restructuring Whole Forms, Section 6. A task group working on it consists of S. Staniszewski, Greg McRae and Jim Riley. July 2012 Mr. Staniszewski sent a progress report to the NBIC Committee Secretary.
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January 2013 A progress report and proposal was given by S. Staniszewski. A motion was made to send a Review letter ballot to the R/A SC and R/A SG Specific. The motion passed unanimously. July 2013 Mr. Staniszewski is expected to report. NB11-0701 - Part 3, S3 5.4 SG Graphite- Address Graphite Tube replacement. (No Attachment) January 2011 Mr. Charles Withers presented a progress report. July 2011 Mr. Galanes reported that Francis Brown reported that they should have something ready for the January 2012 meeting. January 2012 A progress report was provided by C. Withers and a goal of having a proposal for the July 2012 meeting was discussed. July 2012 A progress report was provided by Mr. Francis Brown. January 2013 Mr. Galanes had nothing to report at this time. July 2013 Mr. Galanes is expected to report. NB11-1001 - Part 3, 3.3.4.9 SG R/A Specific- Tube plugging for fire tube boilers. (Attachment 3, pp. 42-44) January 2011 Mr. James Pillow presented a progress report. The committee is in agreement that guidelines are needed in the code. More work regarding proposed guidelines will be done for the next meeting. July 2011 A progress report was provided by George Galanes based on the SG meeting notes. It was recommended to continue working this item from the perspective of providing guidance to control installation versus design guidance. January 2012 A progress report was provided by J. Pillow and a task group consisting of J. Pillow (Chair), Angelo Bramucci, W. Jones and R. Miletti was formed. July 2012 A progress report was provided by Mr. Jim Pillow. January 2013 A progress report was presented to the SC by A. Bramucci. His report described the struggle of the TG to define what requirements are necessary to control tube plugging.Currently some fire tube boiler manufacturers do not endorse tube plugging.
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July 2013 Mr. Bramucci is expected to report. NB11-1201 - Part 3, 1.8, SG R/A General - Revise Part 3, 1.8 “NR” Accreditation requirements to include repairs to ASME Section III stamped components. (Attachment 3, pp. 45-47) January 2011 Mr. Charles Withers presented a progress report. A task group of C. Withers, P.Edwards, B. Schaefer, and B. Wielgoszinski (or a designated HSBCT Representative) and P. Nightengale was assigned to take a look at the NR Program. July 2011 Mr. Withers gave a progress report. January 2012 A progress report was provided by P. Edwards and a task group consisting of P. Edwards (Chair), B. Schaefer, B Wielgoszinski, P. Nightengale, Clay Smith, Rick Swain and C. Withers was formed. July 2012 A progress report was provided by Mr. Ben Schaefer. January 2013 A progress report on this Action Item was given by P. Edwards. A proposal will be presented at the July, 2013 meeting. July 2013 Mr. Edwards is expected to report NB12-0403 - Part 3 R/A Specific CSEF Weld Repair Options using temper bead welding. (No attachment) July 2012 Mr. George Galanes gave a presentation on NB12-0403 to the Subcommittee. This item was taken as a progress report. January 2013 Mr. Galanes gave a progress report and presentation. July 2013 Mr. Galanes is expected to report.
NB12-0801 Part 3, SG R/A Specific Repair and Alteration of Gasketed PHE’s in the field.(Attachment 3, pp. 48-49)
January 2012
A progress report was provided by J. Pillow and a task group consisting of E. Ortman (Chair), J. Pillow G. Galanes and B. Wielgoszinski was assigned. July 2012 A progress report was provided by Mr. Jim Pillow.
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January 2013 A progress report was given by E. Ortman Manager. The Task Group will continue to gather
information for the next meeting. July 2013 Mr. Ortman is expected to report. 9. New Business NB13-0502 Part 3, 2.5.3 e), SG R/A Specific Clarify the wording in this section to state, “After the
finished weld has reached ambient temperature and when required by the specific welding method, the surface temper bead reinforcement layer has been removed substantially flush with the surface of the base metal, the weld shall be examined again by either of the above methods to determine that no defects exist using acceptance standards acceptable to the Inspector or original code of construction. (Attachment 3, pp. 50-51)
July 2013 Mr. Galanes is expected to report. NB13-0503 Part 3, 5.7.2 c) and 5.7.3 SG R/A General Add wording in these sections to address
attaching nameplates. (Attachment 3, pp. 52-64) July 2013 Mr. Miletti is expected to report. NB13-1401 Part 3, S.9.2, SG LB Add wording in this section regarding boiler tube welding.
(Attachment 3, p. 65.) July 2013 Mr. Reetz is expected to report. NB13-0403 Part 3, S1.9.2 SG LB Installation of Boiler and Arch Tubes. (Attachment 3, pp. 66-67) July 2013 Mr. Reetz is expected to report. NB13-1404-A Part 3 S1, SG LB Fillet welded staybolts. (Attachment 3, p. 68) July 2013 Mr. Reetz is expected to report. NB13-1405 Part 3, S1.2.9 SG LB Throttle pipes, dry pipes, superheater headers and front end steam
pipes. (Attachment 3, pp.69-70) July 2013 Mr. Reetz is expected to report. NB13-1406 Part 3, S1, SG LB Superheater units. (Attachment 3, p. 71) July 2013 Mr. Reetz is expected to report. NB13-1407 Part 3, S1 SG LB Bolts, nuts and studs. (Attachment 3, p. 72)
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July 2013 Mr. Reetz is expected to report. NB13-1408 Part 3, S1 SG LB- Threaded boiler studs-Taper thread and straight thread types. (Attachment 3, p. 73) July 2013 Mr. Reetz is expected to report. NB13-1501 Part 3, 1.2 f) SG R/A General Add wording to this section regarding transport tanks. (Attachment 3, pp. 77-75) July 2013) A report is expected. 10. Future Meetings January 13-17, 2014, San Antonio, TX July 15-18, 2014, Columbus, Ohio 11. Adjournment Respectfully Submitted, Jim McGimpsey, Secretary :rh H:\ROBIN-Active Documents\NBIC Secretarial Documents\Committees\SC on Repairs and Alterations\Agenda\Agenda RA 0713.doc
SC on Repairs and AlterationMember Title ExpirDate Interest Category
Boseo, Brian 8/31/2015 NB Certificate Holders
Bryan, Chad Wayne 8/31/2015 Jurisdictional Authorities
Edwards, Paul D. 8/31/2015 NB Certificate Holders
Galanes, PE, George W. 8/31/2015 UsersChairman
Hopkins, Craig 8/31/2016 NB Certificate Holders
Jones, Wayne 1/31/2015 Auth Inpection Agencies
Larson, James P. 8/31/2015 Auth Inpection Agencies
McGimpsey, Jim Secretary
McManamon, Larry 1/31/2015 Organized Labor
Miletti, Ray 2/14/2016 Manufacturer
Ortman, Edward 8/30/2013 Manufacturer
Pillow, James T. 7/31/2013 General InterestVice Chair
Schulte, Bryan 8/31/2015 Users
Sekely, James 8/31/2015 General Interest
Vallance, William 1/31/2015 Jurisdictional Authorities
Webb, Michael 8/31/2015 Users
Total Members: 15
Monday, June 17, 2013 Page 1 of 1
NBIC Committee Action Block
Subject Change of Service
File Number NB 08‐0321 (Inspec) NB 08‐0320 (Install) NB 08‐0322 (R &A)
Prop. on Pg.
Proposal Part 2: Add a new Supplement 9, Requirements for Change of Service, and add a new paragraph 1.6 that includes a reference to Supplement 9 Part 1: Add a new paragraph 1.5 that makes reference to Part 2, Supplement 9 Part 3: Add a new paragraph 3.2.7 that makes reference to Part 2, Supplement 9.
Explanation
Various segments of business and industry that utilize boilers and pressure vessels face issues where the functional aspects or purpose of the equipment have changed. Sometimes due to economics existing vessels are subject to new environments, usage, or different commodities. There are several standards in place that may have specific rules for specific change conditions to vessels. And some may even prohibit the operation of vessels with certain commodities. For example, NFPA 58 prohibits the use of anhydrous ammonia in vessels that have continually operated with propane, or 49 CFR prohibits using DOT railway cars in stationary service after they have served their usefulness. These may be severe or extreme cases. But there are many other situations that could cause peril that are not so obvious. And further, there is no single document that would provide advice to users of the risks associated with changing the service environment without making a thorough review or evaluation of the effects on the equipment. So, this addition to the NBIC is intended to provide that needed guidance to boiler and pressure vessel users. This supplement includes general advice, some of the criteria to be evaluated, and a few examples of what would be considered a change of service condition. June 14, 2013: The proposal was letter balloted for comment‐purposes‐only to all Subcommittees. There were 3 technical comments submitted. The comments and responses are as follows:
Comment Response
Great document, I would support it. Only one comment. Maybe I missed something in the details, but it seems there should be a clear requirement for cleaning and/or decontamination of the vessel as appropriate for any change in lading fluids. Richardson,John
Thanks for the comment. I’ll add the comment to S9.3.3.
S9.1, second paragraph ‐ Either delete the phrase "when applicable" or move it to the next sentence. S9.3.6.e ‐ correct typo changing "of" to "or". Sekely,Jim
S9.1. To avoid any controversy in the field of when it would be applicable or not, I’ll just delete the phrase. S9.3.6.e. Good catch. I’ll make the change.
I reviewed the proposed change of service supplement and agree with the intent and proposed location. I have attached suggested editorial revisions for your consideration. Galanes PE,George ‐ S9.3.2.c add ”or both effects
combined”. ‐ S9.3.6.e correct typo. “of” to “or”. ‐ S9.4, 2nd sentence. Add “of the PRI”.
Agreed to all changes. Thanks for the suggestions.
All changes have been made and are incorporated into revision 7 of the proposal.
Project Manager
Robert Wielgoszinski
Task Group Negatives
TG Meeting Date
Change of Service
Rev 7 June 14, 2013
RVW
Supplement 9 Requirements for Change of Service
S9.1 Scope:
This Supplement provides requirements and guidelines to be followed when a change of service or
service type is made to a pressure retaining item.
Whenever there is a change of service, the local jurisdiction where the pressure retaining item is to be
operated shall be notified for acceptance. Any specific jurisdictional requirements shall be met.
S9.2 Classification of Service Changes
S9.2.1 Service Contents
A change in service contents is considered to be any modification to the commodity or contents
that the pressure retaining item was originally intended to contain when the pressure retaining
item was constructed.
For example, a change:
a) From LP gas service to ammonia service.
b) From lethal to non lethal service.
S9.2.2 Service Type or Change of Usage
A change in service type is considered to be a change of how the pressure retaining item is being
used.
For example, a change:
a) From above ground service to underground service for LP gas tanks.
b) From mobile or transport use to stationary use
S9.3 Factors to Consider
Before a change of service is to be made, the owner or user shall consider and evaluate the effects of
the new operating conditions or environment on the existing condition and suitability for service of the
pressure retaining item. Various factors will have an impact on the reliability of the pressure retaining
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Change of Service
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RVW
item in its new service environment. Changes can be successfully adopted providing there is an
understanding of the effect on the pressure retaining item. However, there are some cases where
changes are detrimental to the existing pressure retaining item. The owner or user should seek
technical guidance of experienced personnel in appropriate areas affected by the change of service (e.g.
design, metallurgy, or operations of the pressure retaining item).
The following is a listing of criteria that should be evaluated as appropriate. The criterion is not limited
to that listed herein. Other factors may be considered as necessary;
1) Design Consideration:
a) Thickness of existing vessel material
b) Vessel or system flow rate or pressure
c) Weight of vessel with new contents
d) Existing or additional loads imposed on nozzles and highly stressed areas
e) Change in pressure or temperature cycling
f) Compliance to product or industry standards, such as ANSI K61, API 579, or NFPA 58
2) Material Consideration:
a) Chemical and mechanical properties of existing material or any new material to be added or
replaced to assure it has the required strength and toughness to withstand the pressure and
temperature effects of the new environment.
b) Effects of erosion or corrosion
c) Time dependent effects on service life ‐ creep or fatigue, or both effects combined.
3) Environment
a) Physical condition of the pressure retaining item
b) Overpressure protection needs
c) Regulatory environment ‐ Verification of compliance to new or existing jurisdictional rules or
regulations.
d) Vessel cleanliness – When changing lading fluids or contents consideration should be given
to cleaning or decontaminating the vessel as appropriate.
4) Operational History
a) A review of current and past operational logs or records should be made to assure that no
conditions existed where any further use would render the pressure retaining item
hazardous or otherwise unsafe.
b) Records to be obtained and reviewed would include Data Reports, Repair and Alteration
Forms, Inspection reports.
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5) Repairs and Alterations Made:
a) A review of any repairs, alterations, reratings, or reconfigurations that have been performed
on the pressure retaining item, so as to assure that they will not have a detrimental impact
on the intended use.
6) Proposed rework
a) Any physical work to be performed to restore the material to the existing or intended state
or to meet any requirements for the new operating conditions.
b) Repairs and alterations shall be performed in accordance with NBIC, Part 3.
c) The effects of heat applied as a result of welding or heat treatment on the material or
shaped parts.
d) The method and extent of any physical or non destructive examination should be
considered.
e) Any physical testing or pressure testing to be performed to determine or verify leak
tightness or structural integrity of the pressure retaining item.
f) The pressure retaining item shall meet the Code requirements for the new environment at
the time of change.
7) Documentation
a) Review existing records that are required to satisfy customer, user, or legal requirements.
b) Review the need for any marking, stamping, or labeling required for the intended service.
c) Review the need for developing or revising an inspection plan to ensure safe operation.
Refer to Part 2, Section 1.5.2.1 Inspection Plan.
S9.4 Some Examples for Change of Service
The following is a typical list of examples of what constitutes a change in service and some factors to
consider. Note: This list is not all inclusive. There may other service changes not mentioned.
Also, the listing of “Factors to Consider” is also not all inclusive. There may be other elements that can
influence the safe and reliable operation of the pressure retaining item.
The Owner shall check with the Jurisdiction where the pressure retaining item is to operate in the new
environment, and review local building Codes, laws, and regulations for additional requirements or
prohibitions against a change of service.
Some examples of Change of Service conditions
Change Some Factors to Consider
LP gas to ammonia PWHT of vessel during construction
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Change of Service
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Some examples of Change of Service conditions
Change Some Factors to Consider
Wet‐fluorescent magnetic particle testing (WFMT) on all internal surfaces
Internal access of vessel is necessary. May need to install manhole.
Ammonia to LP gas NFPA‐58, paragraph 5.2.1.5 should be consulted. i.e. restriction on maximum volume
Wet‐fluorescent magnetic particle testing (WFMT) on all internal surfaces
Internal access of vessel is necessary. May need to install manhole.
Also see, NBIC Part 2, 2.3.6.4
LP gas service: from above ground to underground
Requires alterations (additional nozzles).
Corrosion protection
See NFPA 58
LP gas to air receiver Assurance of vessel cleanliness. i.e. removal of mercaptan.
Appropriateness and number of inspection and drain openings.
Corrosion allowance
Boiler service: Steam to Hot Water
May require replacement of smaller steam outlet nozzle with larger nozzle to accommodate condensate carryover
Change of Pressure Relief Device
Boiler Service: High Pressure to Low Pressure
Additional controls required by the LP boiler Code
Safety valve change
Need for larger opening for safety relief valves
Sulfur dioxide service. Sweet to sour gas service.
Concern over hydrogen cracking
Inert to Oxidizing atmosphere
Inspection for damage mechanisms that may be present from previous service life that is detrimental to the vessel in the new environment.
Cleanliness of hydrocarbons
Lethal service to non‐lethal
Design conditions and suitability for service
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Some examples of Change of Service conditions
Change Some Factors to Consider
DOT railcars or ICC transport tanks to stationary service
Prohibited by DOT regulations (49 CFR 180) for permanent service.
Temporary stationary service permitted as per NFPA 58
Inspection for damage mechanisms that may be present from previous service life that is detrimental to the vessel in the new environment.
S9.5 Documentation of Change of Service
Any records, forms, or reports required documenting the change of service event that may be required
by contract or the jurisdiction where the pressure retaining item operates shall be completed as
specified. Such documentation should be retained by the owner or user for future reference or use as
needed.
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1) If Original Code of Construction does not call for PWHT & ONLY requires Visual examination : Does a pluggingof a Carbon Steel Heat Exchanger Tube of size NPS 5 and smaller by Mechanical Repair method will fall under Routine Repair? 2) If Original Code of Construction does not call for PWHT & ONLY requires Visual examination : Does a plugging of a Carbon Steel Heat Exchanger Tube of size NPS 5 and smaller by Mechanical Repair method will fall under Repair? 3) If Original Code of Construction does not call for PWHT & ONLY requires Visual examination : Does a pluggingof a Carbon Steel Heat Exchanger Tube of size NPS 5 and smaller by Mechanical Repair method will fall under Alteration?
Answers:
1)No
2)No
3)Yes
Background :
Carbon Steel Air cooled Heat Exchanger in service is having leakage thru tubes. (Tube size = 25.4 mm O.D.) In original construction, the Tube to Tubeplate joints are by Expansion only. End User is planning to Plug the leaking Tubes. The plugging will be done by inserting expandable plugs so as no welding will be required for plugging the tubes. Reference points from NBIC 2011: 1)Glossary of Terms : " Mechanical Assembly" & "Mechanical Repair Method" -- (Included since Addenda 08.) 2)Form R-1 - Line 7 : Repair type : Welded, Graphite Pressure Equipment, FRP Pressure Equipment. 3)3.3.2 - Routine Repairs 4)3.3.3 - Example of repairs 5)3.4.3 -Example of alterations 6)Section 6- Repairs and Alterations - Supplements 1 to 7 After referring thru sections as mentioned above in 1 to 6 - I was unable to decide on the answers of the referred questions.
Except reference in Glossary of Terms - The term "Mechanism assembly" and "Mechanical repair method" are not referred anywhere else in Part 3.
The R1 Form does not refer to "Mechanical Repair" i.e. Form R-1 - Line 7 only reads repair types as : Welded, Graphite Pressure Equipment, FRP Pressure Equipment.
And other above mentioned sections does not cover the situation explained at the beginning of this background.
Hope that I have put the query in correct manner.
Request your kind action.
Thanks and regards
Shrinivas Sohani
Velosi LLC
Oman
+968 95607334
