July 2017 NBIC Committee Meeting Minutes

Transcription

1 Table of Contents July 2017 NBIC Committee Meeting Minutes NBIC Committee Attendance July NB SC Inspection NB SC Inspection NB SC Inspection SC Inspection IN SC RA SC RA SC RA SC RA SC RA NB SC RA NB SC RA NB SC RA SC RA SC RA SC RA SC RA SC RA NB SC PRD NB SC PRD SC PRD SC PRD Cox Negative Rationale SC PRD SC PRD SC PRD SC PRD IN SC Installation NB SC Installation NB SC Installation NB SC Installation NB SC Installation SC Installation

2 NBIC Committee Attendance July 2017

3 NBIC Committee Attendance July 2017

4 NBIC Committee Attendance July 2017

5 NBIC Committee Attendance July 2017

6 NBIC Committee Attendance July 2017

7 NB SC Inspection Action Item Request Code Revision or Addition: NB to Part 2, S2.14 The requestor, Mr Don Cook, Chief Inspector, State of California has been seeing occasions in his state where historical boilers are being fired with liquid or gaseous fuels and is asking the Committee to provide some cautionary guidance in NBIC to address these important safety issues related to that activity. PROPOSE: New paragraph, Part 2, Supplement S : FIRING OF HISTORICAL BOILERS WITH LIQUID OR GASEOUS FUELS. Hand firing of historical boilers with liquid or gaseous fuels poses significant additional safety concerns beyond those encountered when firing with solid fuels for which these boilers were originally designed, such as coal, straw or wood. The cautionary notes listed below are provided as examples to remind the owner or user that additional safety concerns do exist when firing historical boilers with these alternate fuels. These notes are not meant to be all inclusive so each boilers fuel system should be designed appropriately. a) JURISDICTIONAL ACCEPTANCE: The owner or user should shall check with the Jurisdiction as applicable to determine if this alternative firing method is allowed. b) OWNER OR USER KNOWLEDGE: The owner or user shall have an extensive knowledge of the fuel used, fuel transfer system, on board fuel storage, burner, firing controls, emergency shut off devices and procedures. c) PURGING: To prevent a firebox explosion, it is essential to ensure that the furnace is purged of combustible gasses prior to applying the fuel ignition source to prevent flame outs. d) FLAME IMPINGEMENT: Direct flame impingement of the metal surfaces within the furnace can damage the boiler. Installation of refractory or fire brick in the firebox is a common practice to prevent this potential damage. e) LOW WATER: The owner or user must shall have a plan and method to immediately shut off the fuel supply to the burner when a boiler low water condition occurs. f) FUEL CONTAINMENT: The fuel storage system must shall be suitably designed with the appropriate shut off devices for the specific fuel product. The mounting method and proximity of the fuel storage container to the furnace must shall be considered to prevent the fuel from accidental ignition. g) FUEL SYSTEM: The fuel delivery system from fuel source to the burner shall be suitably designed for the specific fuel product including appropriate emergency shut off devices. The routing of the fuel delivery system should be a consideration as well. h) FUEL AIR MIXTURE: The burner utilized shall be designed to operate within the confines of the boiler furnace and provide the proper fuel/air mixture. i) SAFETY VALVE: The boilers minimum relieving capacity shall be computed for the type of fuel used. j) COMPRESSED NATURAL GAS (CNG) vs LIQUID PETROLEUM GAS (LPG): CNG is lighter than air and LPG is heavier than air. The owner or user should understand the properties of the fuels to ensure the gas will not accumulate in the boiler (see Purging above).

8 NB SC Inspection NB Withdrawn LB Attachment Page 5 Part 2 Section d d) Any damage to the cylinder or closures can lead to premature failure. Frequent visual inspection should be made of internal and external surfaces of the cylinder, frame and closures. A thorough examination should be completed if any visually apparent damage is identified or if any excursion beyond design temperature or pressure occurs. In addition, surfaces of the cylinder and closures should be examined by dye penetrant or magnetic particle method at intervals based on vessel remaining life. Closures may require ultrasonic examination of passageways. As part of this inspection guideline for wire wound pressure vessels, periodic inspection of the following items should include be reviewed: 1) Verify no change in the process, such as thechanges of the processing fluid, that might may adversely impact vessel integrity. 2) Review the vessel manufacturer smanufacturer s inspection recommendations for vessel, closures and frame. If manufacturer s recommendations are not available, the owner should obtain recommendations from a recognized wire wound vessel service provider. 3) Verify any repairrepairs to pressure retaining items has beenshould be completed by a National Board authorized service provider having wire wound vessel expertise. 4) Verify overpressureoverpressure protection with appropriate set pressure and capacity is should be provided protection as described in the original code of construction with the appropriate set pressure and capacity is to be in place with no observable compromise to the intended service.. Rupture discs are commonly used for pressures exceeding 14,500 psi (100 MPa) to avoid valve seat leakage. Overpressure protection devices are frequently replaced to avoid premature operation. 5) If there are no manufacturer s recommendations available for the vessel, the following are additional recommended inspections that should be conducted to ensure vessel integrity and safety. a. Conduct annualannual visual and dimensional vessel inspections with should be conducted using liquid penetrant examination of maximum stressed areas to ensure that the surfaces are free of defects. Conduct ultrasonic Ultrasonic examination of the vessel should be conducted after every 25% of the design cycle life or every five years, whichever comes first, to detect subsurface cracks. Special attention should be given to the roots of threads and closures using threaded head retention construction. Other geometric discontinuities that are inherent in the design or irregularities resulting from localized corrosion, erosion, or mechanical damage should be carefully examined. This is particularly important for units of monoblock construction. [Type text] Attachment Page 1

9 NB SC Inspection NB Withdrawn LB Attachment Page 6 b. The closure mechanism of the vessel end-closure is may be opened and closed frequently during operation. It should be, therefore, the closure mechanism should be closely inspected for freedom of movement and proper contact with its locking elements. Wire wound vessels must have The presence of yoke-type closures should be verified a n dso the yoke frame will need to be closely inspected on a regular basis. 6) Gages, Safety Devices, and Controls a. Verify that the The vessel is should be provided with control and monitoring of pressure, temperature, the electrical system, fluid flow, liquid levels, and all variables that are essential for the safe operation of the system. If the vessel is automatically controlled, manual override should be available. Also, safety interlocks should be provided on the vessel closure to prevent vessel pressurization if the vessel closure is not complete and locked. b. Verify that allall safety device isolation valves are should be locked open if used.as allowed by the code of construction, e.g. ASME Section VIII Div 1, UG-135. c. Verify appropriate Appropriate pressure relief devices is should be installed with the setpoint at the lowest pressure possible, consistent with the normal operating pressure, but in no case higher than the maximum allowable working pressure design operating pressure of the vessel. Rupture discs are normally considered more suitable for these types of applications, since pressure relief devices operating at pressures above 14,500 psi may tend to leak by their seat. d. Verify that pressure Pressure and temperature of the vessel coolant and vessel wall is should be controlled and monitored. Interlock devices should be installed that will de-energize or depressurize the vessel at established setpoints. e. Verify audibleaudible and visual alarms are should be installed to indicate unsafe conditions. [Type text] Attachment Page 2

10 NB SC Inspection NB Withdrawn LB Comments Attachment Page 7 NB Withdrawn LB Comments Attachment Page 7

11 NB SC Inspection Attachment Page 11

12 NB SC Inspection NB Part 2, S RIVET HEAD TYPES Common Ffinished rivet heads are shown in NBIC Part 3, Figure S Note that a riveted seam may have more than one type of rivet to, for example, provide necessary clearance during operation, or for provision for equipment assembly and maintenance.

13 SC Inspection NBIC Subcommittee R&A Action Block Subject Revision to 2015 Edition, NBIC Part 2, 1.3 Item Prop. on Pg. Proposed Revision Statement of Need See below Project Manager Galanes SubGroup Negatives 0 SG Meeting Date Need; Update reference documents in Part 2 of the NBIC to include a new, EPRI free publication on Applications of Fracture Mechanics Methods to Fossil-Fueled Boiler Components, Having this reference will enable Users or repair organization to utilize tools for evaluation of defects in pressure retaining items. See below for proposed revision in Part 2 of the NBIC, page 2; 1.3 add new (v) below (v). Electric Power Research Institute (EPRI) publication (Applications of Fracture Mechanics Methods to Fossil-Fueled Boiler Components)

14 IN SC RA IN Rev.2 Subject: 2013 Edition, Replacement of bolting material Q1. Is a mechanical repair consisting of the replacement of bolting material, with like material (see Part 3, paragraph s), as listed on the Manufacturer s Data Report considered a repair that needs to be documented on an R 1 form? R1. No. Q2. Is the replacement of bolting material with a different allowable stress, nominal composition (see Part 3, paragraph g) or configuration other than that listed on the Manufacturer s Data Report considered an alteration? R2. Yes.

15 SC RA Subject: 2015 edition, Surface repairs to corrugating rolls Question: Is an R stamp required to be applied to a corrugating roll after a surface repair by welding, such as restoration of broken flutes, steam cut trunnion flanges, or a worn surface of a trunnion journal? Reply: Yes, unless the repair meets the conditions for a routine repair in Part 3, paragraph

16 SC RA Proposed Interpretation Inquiry No. NB Source S.Chaîné Subject NBIC Part 3 Scope Edition 2015 Question: Question 1: Are nameplates and stamping required for routine repairs? Question 2: Are nameplates or stamping required for repairs other than of a routine nature? Reply: Committee s reply: Response 1: No, subject to acceptance of Jurisdiction and the concurrence of the inspector Response 2: Yes Rationale: Is my interpretation right, that, for a repair as per NB 23 part 3 article 5.7.2b), the requirement of adding a repair nameplate can be waived in some consideration depending the extent and the type of the repair? Yes or No This was the question as submitted. The question was changed into 2 specific questions as shown above.

17 SC RA Subject: NBIC 2017 Edition, Part 3, Section 1, Table c) Question: In Table 1.5.1c), does the phrase the continuity records are subject to review during each National Board triennial certificate review mean that the continuity records developed since the last review are to be retained and made available for review during the next review? Reply: Yes

18 SC RA Request for Interpretation, NBIC Part 3 Robert V. Underwood 7/18/2017 The Hartford Steam Boiler Inspection & Insurance Company Purpose: To clarify how to determine whether a repair or alteration activity is practicable. Background: The term practicable is used over twenty times throughout the NBIC Part 3. It is used in relation to repair and alteration activities such as welding, alternative PWHT methods, alternative NDE Methods, pressure testing, and in several supplements. Authorized Inspectors receive many questions each year about what practicable means. Practicable is an adjective that means capable of being put into practice or of being done or accomplished. Some R certificate holders and Owners have attempted to use practicable in an effort to save time and/or money. Existing NBIC Interpretation relates to liquid pressure testing of repair activities and the reply states that the determination of practicable is based on technical consideration of the nature and scope of the alteration activity and not a desire to save time and/or expense. This response is pretty good and I have used this interpretation to support my opinion of what practicable means, however the interpretation relates only to liquid pressure testing and alterations. I believe a new interpretation should be approved that covers all repair and alteration activities to ensure owners, certificate holders, and AIAs are on the same page. I am proposing an interpretation of how determine what is practicable. Proposed Question/Answer: See page 2 with proposed interpretation

19 SC RA EXISTING INTERPRETATION PROPOSED INTERPRETATION Subject: NBIC Part 3, 2017 Edition, Application of the word Practicable Question: May the desire to save time and/or expense be used solely in determining if a repair and/or alteration activity is practicable? Reply: No. The determination of practicable shall be based on technical consideration of the nature and scope of repair and/or alteration activities.

20 NB SC RA NB Rev. 4 Records Retention Part 3, Table 1.6.1(c) Existing Text: Part 3, Table 1.6.1, c) CODE REVISIONS OR ADDITIONS Add the following sentence to the text regarding Minimum retention Period. Continuity records shall be retained for a minimum of 5 years. Statement of Need Because there is no established retention period for continuity records for those employed by the Certificate Holder, the Certificate Holder may be expected to retain continuity records from the date of initial qualification onward. This can be as long as 10 to 20 years, or longer. This is an unnecessary burden on the Certificate Holders. Background Information The burden of records retention varies amongst the various Certificate Holders. For example, it may be of little or no burden for a Certificate Holder that employs a limited number of welders, bonders or cementing technicians on a continuous basis, but for a Certificate Holder that employs hundreds, perhaps thousands, of welders, bonders or cementing technicians for short periods of time, such as needed for site repairs and alterations, record retention becomes quite burdensome. Is verification of continuity maintenance dating back longer than 5 years needed to assure safety? I don t believe so. The NBIC has built in safeguards when a person s skill comes into question. These safeguards are provided in Part 3, Section I, paragraph b and c, Section 6, S b, S6.8.6.b, and S b. These paragraphs require qualifications to be revoked when there is specific reason to question the person s ability to meet the specification requirements. Please note that ASME Section VIII requires welding records to be retained for at least 3 years. Section I just approved a revision to be published in the 2017 Edition that states that continuity records need not be retained for more than 5 years (See following page).

21 NB SC RA NB Rev. 4 Records Retention Part 3, Table 1.6.1(c) ASME Item Records Retention Rev 4 A , PW 28.4 and PB 29.3 INFORMATION ONLY Existing Text A Records Retention. The Manufacturer or assembler shall have a system for the maintenance of radiographs and Manufacturers Data Reports as required by this Section. PW 28.4 The Manufacturer shall maintain qualification records of the welding procedures, welders, and welding operators employed, showing the date, results of the tests, and the identification mark assigned to each welder. These records shall be certified by the Manufacturer by signature or some other method of control in accordance with the Manufacturer s Quality Control System and be accessible to the Authorized Inspector. PB 29.3 The Manufacturer shall maintain qualification records of the brazers and brazing operators showing the date and result of tests and the identification mark assigned to each. These records shall be certified by the Manufacturer by signature or some other method of control in accordance with the Manufacturer s Quality Control System and be accessible to the Inspector. Proposed Revision A Records Retention. The Manufacturer or assembler shall have a system for the maintenance of radiographs (PW 51.4), UT reports (PW 52.2), and Manufacturers Data Reports (PG 113.3), and qualification maintenance records for welders and welding operators (PW 28.4) and brazers and brazing operators (PB 29.3) as required by this Section. PW 28.4 The Manufacturer shall maintain qualification records of the welding procedures, welders, and welding operators employed, showing the date, results of the tests, and the identification mark assigned to each welder. These records shall be certified by the Manufacturer by signature or some other method of control in accordance with the Manufacturer s Quality Control System and be accessible to the Authorized Inspector. Continuity records showing that the qualifications of the welders and welding operators have been maintained need not be retained for more than 5 years. PB 29.3 The Manufacturer shall maintain qualification records of the brazers and brazing operators showing the date and result of tests and the identification mark assigned to each. These records shall be certified by the Manufacturer by signature or some other method of control in accordance with the Manufacturer s Quality Control System and be accessible to the Inspector. Continuity records showing that the qualifications of the brazers and brazing operators have been maintained need not be retained for more than 5 years.

22 NB SC RA NB /13/17 Request for NBIC Part 3, Section 4 Revision Robert V. Underwood The Hartford Steam Boiler Inspection & Insurance Company Purpose To change the maximum test pressure requirement when performing liquid pressure tests of repair and alteration activities. Scope: To revise paragraph 4.4.1(a)(1) and 4.4.2(a)(1) of the NBIC Part 3 to require maximum liquid test pressure be in accordance with the original construction Code. Background For liquid pressure testing of repairs and alterations, paragraphs 4.4.1(a)(1) and 4.4.2(a)(1) of the NBIC Part 3 require a maximum test pressure of 150% of the maximum allowable working pressure (MAWP) stamped on the pressure retaining item, as adjusted for temperature. However, repairs and alterations of DOT vessels are required to be tested at a minimum of 150% of design pressure which makes it virtually impossible to comply with the NBIC maximum requirement. Further, repairs and alterations to DOT ammonia transport vessels made from UHT materials require a test pressure of 200% of design pressure (49CFR (b)(6) and ). Obviously, this is in violation of the NBIC Part 3. Paragraph UG 99 of ASME Section VIII, Div. 1 does not not specify a maximum test pressure for hydrostatic tests. Therefore, I am proposing to revise paragraphs 4.4.1(a)(1) and 4.4.2(a)(1) to remove the maximum test pressure of 150% of MAWP. Both paragraphs will have new wording (similar to existing paragraph 4.4.1(b) for pneumatic testing) which states test pressure shall not to exceed the maximum test pressure of the original code of construction. Proposed Revision See page 2 and 3 with proposed revisions.

23 NB SC RA EXISTING WORDING IN 4.4.1(a)(1) FOR LIQUID PRESSURE TESTING PROPOSAL OF REVISION TO 4.4.1(a)(1) 1) Pressure tests shall be conducted using water or other liquid medium. The test pressure shall be the minimum required to verify the leak tightness integrity of the repair. The test pressure shall not exceed the maximum liquid test pressure of the original code of construction. When original test pressure included consideration of corrosion allowance, the test pressure may be further adjusted based on the remaining corrosion allowance.

24 NB SC RA EXISTING PARAGRAPH 4.4.2(a)(1) of NBIC Part 3 PROPOSAL OF REVISION TO 4.4.2(a)(1) 1) A pressure test as required by the original code of construction shall be conducted. The test pressure shall not exceed the maximum liquid test pressure of the original code of construction. When the original test [pressure included consideration of corrosion allowance, the test pressure may be further adjusted based on the remaining corrosion allowance. The pressure test for replacement parts may be performed at the point of manufacture or point of installation.

25 NB SC RA NB Category 2 Paragraph n) 2) f. Non Destructive Examination reports, including results of examinations, shall identify the ASNT, SNT TC 1A, CP 189, or ACCP name and certification level of personnel interpreting the examination results. as ASME Section XI.

26 SC RA NB Purpose Scope: Request for NBIC Part 3, Supplement 2 Revision Robert V. Underwood The Hartford Steam Boiler Inspection and Insurance Company Robert_Underwood@hsb.com Revise S2.11 of NBIC Part 3, Supplement 2 to address examination and testing requirements of repairs and alterations to historical boilers. The title of S2.11 will be revised to Nondestructive Examination and Testing and S2.11 will be broken into sub paragraphs (a) and (b). Existing paragraph S2.11 will be in S2.11(a) and be revised to now address NDE for alterations and also refer back to paragraph 4.2 of NBIC Part 3 which has detailed NDE requirements for all repairs and alterations. S2.11(b) is a new paragraph that will address the requirement of an examination or test of all completed repairs and alterations. It will also refer back to paragraph 4.4 of NBIC Part 3 which has detailed exam and test requirements for all repairs and alterations. Background An R Certificate Holder called to question whether a pressure test was required upon completion of a welded repair to a riveted boiler. S2.8 requires the Inspector to verify any NDE or witness a pressure test of the completed repair. S2.13(d) states that a single hydrostatic test be performed after seal welding a tube. However, there is no mandatory requirement that an examination or pressure test be performed after completing a repair or alteration. As written, one could argue that seal welding of tubes is the only repair that would require a pressure test or examination. Proposed Revision See following page

27 SC RA PROPOSED REVISION OF S2.11 OF NBIC PART 3, SECTION 6, SUPPLEMENT 2 S2.11 NONDESTRUCTIVE EXAMINATION AND TESTING f) The integrity of repairs and alterations shall be verified by examination or test as required by Part 3, 4.4

28 SC RA Scribner NBIC Part d) The pressure retaining item has been pressure tested, as required, for the new service conditions. Any insulation, coatings, or coverings that may inhibit or compromise a meaningful pressure test shall be removed, to the extent identified by the Inspector. The pressure test may be waived if the original pressure test as recorded on the Manufacture s Data Report is at least equal to the calculated test pressure required to verify the integrity of the pressure retaining item for the new conditions. If the pressure test is waived it shall be documented on Form R 2 with this statement in the Remarks section : Pressure test waived in accordance with NBIC d) NBIC Part Based on the nature and scope of the alterations activity, one or a combination of the following examination and test methods shall be applied to alterations (unless waived in accordance with d) of this Part) and replacement parts use in alterations. Statement of Need The changes to NBIC Part 3, d) seem to conflict with NBIC Part 3, Additionally the lack of the requirement for the statement in the remarks section make it impossible for National Board administrative staff to determine if all required fields are completed on the Form R 1. Gary L. Scribner Manager of Technical Services

29 SC RA Galanes Part 3, Existing 2). The welding shall be limited to the SMAW or and/or GTAW processes,.

30 SC RA NB Purpose; Revise Welding Method 2 and Welding Method 4 to allow for full thickness weld repairs to HRSG tube to header welds in steam service. As more HRSG s are being repaired, there is growing need for temper bead repairs on tube to header welds that are full thickness. See proposed revisions below based on need from EPRI membership Existing WELDING METHOD 2 When using this method, the following is required: 3) For P-No. 4 and P-No. 5A materials, the minimum preheat, interpass temperature, and technique shall be in accordance with NBIC Part 3, The repair depth for temper bead repairs to pressure retaining items of P-No. 4 and P-No. 5A materials is limited to welds not penetrating through full thickness. 4) For ASME Section VIII, Division 2 pressure vessels, where application of PWHT on inservice vessels has been demonstrated to cause harm to vessel material, full thickness temper bead repairs are permitted to pressure-retaining items of P-No. 4 and P-No. 5A materials. They shall be completed per NBIC Part 3, with the following requirements: a. The full thickness repair weld shall be verified as being the full penetration. b. Volumetric examination of the full thickness weld shall be performed. Proposed Revision Underlined WELDING METHOD 2 When using this method, the following is required: 3) For P-No. 4 and P-No. 5A materials, the minimum preheat, interpass temperature, and technique shall be in accordance with NBIC Part 3, The repair depth for temper bead repairs to pressure retaining items of P-No. 4 and P-No. 5A materials is limited to welds not penetrating through full thickness. 4) Full thickness temper bead weld repairs are permitted to pressure retaining items of P-No 4 and P-No 5A materials under the following conditions; a) ASME Section VIII, Division 2 pressure vessels, where application of PWHT on in-service vessels has been demonstrated to cause harm to vessel material.

31 SC RA b) For tube to header welds in steam service. Full thickness weld repairs above shall be completed per NBIC Part 3, with the following requirements: 1. The full thickness repair weld shall be verified as being the full penetration. 2. Volumetric examination of the full thickness weld shall be performed WELDING METHOD 4 When using this method, the following is required: a) This method is limited to repair welds in pressure retaining items for which the applicable rules of the original code of construction did not require notch toughness testing. The repair depth for temper bead repairs to pressure retaining items is limited to welds not penetrating though the full thickness. For ASME Section VIII Division 2 pressure vessels, where application of PWHT on in-service vessels has been demonstrated to cause harm to vessel material, full thickness temper bead repairs are permitted. They shall be completed per NBIC Part 3, with the following requirements: 1) The full thickness repair weld shall be verified as being full penetration. 2) Volumetric examination of the full thickness weld shall be performed. Proposed Revision Underlined WELDING METHOD 4 When using this method, the following is required: a) This method is limited to repair welds in pressure retaining items for which the applicable rules of the original code of construction did not require notch toughness testing. The repair depth for temper bead repairs to pressure retaining items is limited to welds not penetrating though the full thickness. Full thickness temper bead weld repairs are permitted under the following conditions; 1) ASME Section VIII, Division 2 pressure vessels, where application of PWHT on in-service vessels

32 SC RA has been demonstrated to cause harm to vessel material. 2) For tube to header welds in steam service. Full thickness weld repairs shall be completed per NBIC Part 3, with the following requirements: 1) The full thickness repair weld shall be verified as being full penetration. 2) Volumetric examination of the full thickness weld shall be performed.

33 SC RA Withers NBIC Part 3 Add additional wording to paragraphs r); r) and r): r) Audits The provisions identified in ASME NQA 1, Part 1, and Requirement 18 shall apply and shall include the following: A comprehensive system of planned and periodic internal audits of the NR Certificate Holder s Quality Assurance Program shall be performed by the NR Certificate Holder. Audits shall include internal audits by the Certificate Holder and audits by the Authorized Inspection Agency. Audit frequency shall be specified in the organization s Quality Assurance Manual. Audits shall be conducted at least annually for any ongoing code activity to verify compliance with Quality Assurance Program requirements, performance criteria and to determine the effectiveness of the Quality Assurance Program. When no code work has been performed, the required annual audit need only include those areas of responsibility required to be continually maintained such as training, audits, organizational structure, and Quality Assurance Program revisions. The Quality Assurance Manual shall as a minimum describe the following: 1) Audits shall be performed in accordance with written procedures or checklists by qualified audit personnel not having direct responsibility in areas being audited; 2) Audit personnel shall be qualified in accordance with the current requirements of ASME NQA 1; 3) Audit results shall be documented and reviewed by responsible management; 4) Requirements for follow up actions shall be specified for any deficiencies noted during the audit; 5) Audit records and applicable documentation shall be made available to the Authorized Nuclear Inspector for review; 6) Audit records shall include as a minimum; a. Written procedures; b. Checklists; c. Reports; d. Written replies; and e. Completion of corrective actions.

34 NB SC PRD NB NR Task Group One update by NR task group page 3: 7/17/19 2. Two updates to S6.1 and S6.3 on page 1: 7/19/17 SUPPLEMENT 6 PROCEDURES FOR REPAIRS TO ASME NV STAMPED PRESSURE RELIEF DEVICES OF NUCLEAR SAFETY RELATED PRESSURE RELIEF VALVES S6.1 SCOPE ASME Code NV Class 1, 2, or 3 stamped pressure relief devices,nuclear safety related pressure relief valves and power operated pressure relief valves which have been capacity certified by the National Board, may be repaired provided the following requirements are met. Valves being repaired under these provisions are intended to be those protecting the nuclear pressure boundary. Other pressure relief valves in the nuclear power plant (such as pressure relief valves on air compressors and auxiliary boilers) shall be repaired as required by the applicable Jurisdiction. S6.2 DEFINITIONS Safety Related As used in this supplement and when applied to nuclear power plants, safety related means a structure, system, or component or part thereof that affects its safety function necessary to assure: a) The integrity of the reactor coolant pressure boundary; b) The capability to shut down the reactor and maintain it in a safe shutdown condition; or c) The capability to prevent or mitigate the consequence of accidents which could result in potential offsite exposures. S6.3 NUCLEAR SAFETY RELATED VALVE GROUPS These rules classify nuclear safety related pressure relief valves into three groups based upon the original code of construction and capacity certification status. Group 1: ASME Section I and Section VIII pressure relief valves accepted by the Jurisdiction for use used in nuclear safety related service with National Board capacity certification. Group 2: ASME Section III NV stamped Class 1, 2, or 3 pressure relief valves with National Board capacity certification. Group 3: Pressure relief valves not addressed in Group 1 or Group 2. This group shall include pressure relief valves without National Board capacity certification and/or pressure relief valves constructed to codes or standards other than ASME (see NBIC Part 3, Category 3). The term pressure relief valve includes power operated pressure relief valves. Replacement of rupture disks in rupture disk holders or in systems is not considered a repair activity under the scope of this supplement. S6.42 ADMINISTRATIVE PROCEDURES a) The repair organization shall hold obtain a valid VR Certificate of Authorization and stamp. b) The repair organization shall obtain a National Board NR Certificate of Authorization and stamp. The requirements for said certificate and stamp include, but are is not limited to the following. The repair organization shall: 1

35 NB SC PRD ) Maintain a documented quality assurance program that meets the applicable requirements of NBIC Part 3, 1.6. This program shall also include all the applicable requirements for the use of the VR stamp; 2) Have a contract or agreement with an Authorized Inspection Agency that is qualified in accordance with the requirements of ASME QAI 1, Qualifications for Authorized Inspection to provide inspection of repaired nuclear NV stamped pressure relief devices valves by Inspectors who have been qualified in accordance with the requirements of ASME QAI 1, Qualifications for Authorized Inspection; 3) Successfully complete a survey of the quality assurance program and its implementation. This survey shall be conducted by representatives of the National Board, the Jurisdiction wherein the applicant s repair facilities are located, and the applicant s Authorized Inspection Agency. Further verification of such implementation by the survey team may not be necessary if the applicant holds a valid ASME NV certificate and can verify by documentation the capability of implementing the quality assurance program for repair of NV stamped pressure relief devicesvalves, covered by the applicant s ASME NV certificate. c) The application of the NR Certificate of Authorization and stamp shall clearly define the scope of intended activities with respect to the repair of Section III, NV stamped nuclear pressure relief devicesvalves. d) Revisions to the quality assurance program shall be acceptable to the Authorized Nuclear Inspector Supervisor and the National Board before being implemented. e) The scope of the VR Certificate of Authorization shall include repair of NV stamped nuclear pressure relief devicesvalves (denoted on the VR Certificate as Section III). f) Verification testing of valves repaired by the applicant shall not be required provided such testing has been successfully completed under the applicant s VR certification program for the applicable test fluids. g) A survey of the applicant for the VR Certificate of Authorization and endorsement of the repair of NV stampednuclear pressure relief devicesvalves may be made concurrently. h) S6.53 GENERAL RULES a) Group 1 and Group 2 pressure relief valves ASME Code Section III, NV stamped pressure relief devices, which have been repaired in accordance with these rules, shall be stamped with both the VR and NR stamps. They shall be classified as either NR Category 1 or Category 2 as applicable. Group 3 pressure relief valves which have been repaired in accordance with these rules shall be stamped with the NR stamp. They shall be classified as either NR Category 2 or Category 3 as applicable. b) The VR and NR stamps shall be applied only to NV stamped (Class 1, 2, or 3) National Board capacity certifiednuclear safety related pressure relief devicesvalves that have been disassembled, inspected, and repaired as necessary, such that the valves condition and performance are equivalent to the standards for new valves. c) All measuring and test equipment used in the repair of pressure relief devicesvalves shall be calibrated against certified equipment having known valid relationships to nationally recognized standards. d) Documentation of the repair of NV stampednuclear safety related pressure relief devicesvalves shall be recorded on the National Board Form NVR 1, Report of Repair/ Replacement Activities for Nuclear Pressure Relief Devices, in accordance with the requirements of NBIC Part 3, 1.6. The original code of construction and capacity certification status shall be identified on the NVR 1 form. 2

36 NB SC PRD e) When an ASME V, UV or NV stamped pressure relief device requires a duplicate nameplate because the original nameplate is illegible or missing, it may be applied using the procedures of NBIC Part 4, provided concurrence is obtained from the Authorized Nuclear Inspector and Jurisdiction. In this case the nameplate shall be marked SEC I, SEC. III, or SEC VIII to indicate original ASME Code stamping. f) Repair activities for pressure relief devicesvalves shall not include rerating of the device. Set pressure changes within the range of the valve manufacturer s capacity certification and the design pressure of the valve (see NBIC Part 4, 4.7.3) are permitted, provided the new set pressure and capacity rating are reconciled with the design of the system where the device will be used. These Set pressure changes are not considered to be rerating. g) Conversions of pressure relief devicesvalves as described in NBIC Part 4, 4.2 b) are permitted as part of repair activities. h) Set pressure changes or conversions of pressure relief devicesvalves shall be described in the Remarks section of Form NVR 1. File: NB updated final.docx 3

37 NB SC PRD NB Proposal 7/18/17 PART 4, (PART g))valve ADJUSTMENTS a) If a set pressure test indicates the valve does not open within the requirements of the original code of construction, but otherwise is in acceptable condition, minor adjustments (defined as no more than twice the permitted set pressure tolerance) shall be made by a qualified organization accredited by the National Board VR or T/O Certificate Holder to reset the valve to the correct opening pressure. All adjustments shall be resealed with a seal identifying the responsible organization and a tag shall be installed identifying the organization and the date of the adjustment. Qualified organizations are considered to be National Board VR Certificate Holders, or organizations authorized by the Jurisdiction to make adjustments. See Supplement 3 for more information. PART 4, (PART ) ESTABLISHMENT OF SERVICE INTERVALS b) Pressure relief valves are mechanical devices that require periodic preventive maintenance even though external inspection and test results indicate acceptable performance. There may be wear on internal parts, galling between sliding surfaces or internal corrosion, and fouling which will not be evident from an external inspection or test. Periodic re-establishment of seating surfaces and the replacement of soft goods such as o-rings and diaphragms are also well advised preventive maintenance activities that can prevent future problems. If the valve is serviced, a complete disassembly, internal inspection, and repair as necessary, such that the valve s condition and performance are restored to a like new condition, should be done by a National Board VR Certificate Holder.an organization accredited by the National Board.

38 SC PRD Item Proposal PART 4, (PART 1, 2.9.1) GENERAL REQUIREMENTS a) Only direct spring loaded, pilot operated, or power operated pressure relief valves or pilot operated pressure relief valves designed to relieve steam shall be used for steam service. b) Pressure relief valves are valves designed to relieve either steam or water, depending on the application. cb) Pressure relief valves shall be manufactured in accordance with a national or international standard. dc) Deadweight or weighted-lever pressure relief valves shall not be used. ed) For high temperature water boilers, pressure relief valves shall have a closed bonnet, and valve bodies shall not be constructed of cast iron. fe) Pressure relief valves with an inlet connection greater than NPS 3 (DN 80) and used for pressure greater than 15 psig (100 kpa), shall have a flanged inlet connection or a welding-end inlet connection. The dimensions of flanges subjected to boiler pressure shall conform to the applicable standards. gf) When a pressure relief valve is exposed to outdoor elements that may affect operation of the valve, the valve may be shielded with a cover. The cover shall be properly vented and arranged to permit servicing and normal operation of the valve.

39 SC PRD Item Proposal PART 4, (PART 1, 2.9.6) INSTALLATION AND DISCHARGE REQUIREMENTS e) When two or more pressure relief valves are used on a boiler, they should shall be mounted installed either separately or, as twin valves made by placing individual valves on a Y-bases, or duplex valves having two valves in the same body casing. Twin valves made by placing individual valves on Y-bases or duplex valves having two valves in the same bodyif twin or duplex valves are used, they shall be of equal size. f) When two valves of different sizes are installed singly, the relieving capacity of the smaller valve shall not be less than 50% of that of the larger valve. g) When a boiler is fitted with two or more pressure relief valves on one connection, this connection to the boiler shall have a cross-sectional area not less than the combined areas of inlet connections of all the pressure relief valves with which it connects. h) All pressure relief valves shall be piped to a safe point of discharge so located or piped as to be carried clear from running boards or platforms. Provision for an ample gravity drain shall be made in the discharge pipe at or near each pressure relief valve, and where water or condensation may collect. Each valve shall have an open gravity drain through the casing below the level of the valve seat. For iron- and steel- bodied valves exceeding NPS 2 (DN 50), the drain hole shall be tapped not less than NPS 3/8 (DN 10).

40 Cox Negative Rationale Re: NB J Alton Cox to: TBeirne 07/19/ :59 PM Tom: I voted Negative because I believe the size of the Twin PRVs needs to be defined. I suggest it be the capacity, not the Inlet NPS. Thank you. Best Regards, J. Alton Cox JAC Consulting, Inc alton@jaltoncox.com

41 SC PRD Item Proposal PART 4, (PART 1, S5.7.6) INSTALLATION h) A suitable condenser that will condense all the vapors discharged from the pressure relief valve may be used in lieu of piping the vapors to the atmosphere.

42 SC PRD ITEM PROPOSAL PART 4, (PART 1, 3.9.2) PRESSURE RELIEF VALVE REQUIREMENTS FOR STEAM HEATING BOILERS a) Pressure relief valves shall be manufactured in accordance with a national or international standard. b) Each steam boiler shall have one or more National Board capacity certified pressure relief valves of the spring pop type adjusted and sealed to discharge at a pressure not to exceed 15 psig (100 kpa). c) No pressure relief valve for a steam boiler shall be smaller than NPS 1/2 (DN 15). No pressure relief valve shall be larger than NPS 4 (DN 100). The inlet opening shall have an inside diameter equal to, or greater than, the seat diameter.

43 SC PRD Item Proposal PART 4, (PART 1, ) INSTALLATION Temperature and pressure relief valves shall be installed by either the water heater manufacturer or installer or the manufacturer before a water heater is placed in operation.

44 SC PRD Item Proposal PART 4, (PART 1, 4.5.6) f) Pressure relief device discharges shall be arranged such that they are not a hazard to personnel or other equipment and, when necessary, lead to a safe location for disposal of fluids being relieved.all pressure relief devices shall relieve to a safe point of discharge.

45 IN SC Installation Item Number: NB NBIC Location: Part 1 No Attachment General Description: Is it standard operating procedure (per NBIC) to do hydrostatic pressure tests on installed ASME Section IV boilers at 150% of the rated pressure as part of the installation inspection? Question: If a pressure test has been performed and documented on the applicable Manufacturer s Data Report for a boiler, pressure vessel or piping, is an additional pressure test required prior to initial operation? Reply: NO Interpretation IN Proposed Interpretation Inquiry: IN Source: NB Subject: Pressure Testing - Part 1 Edition: 2015 NBIC Question 1: Is it standard operating procedure (per NBIC) to do hydrostatic pressure tests on installed ASME Section IV boilers at 150% of the rated pressure as part of the installation inspection? Reply 1: Committee s Question: Committee s Reply: Rationale: If a pressure test has been performed and documented on the applicable Manufacturer s Data Report for a boiler, pressure vessel or piping and the Jurisdiction does not require additional pressure tests, is an additional pressure test required prior to initial operation? No Power Boilers, Heating Boilers, 4.6 Pressure Vessels, 5.4 Piping SC Vote NBIC Vote It is not the intent of the code to mandate post construction testing at 150% of the rated pressure. Passed Unanimous

46 IN SC Installation PRESSURE TEST Prior to initial operation, the completed boiler, including pressure piping, water columns, superheaters, economizers, stop valves, etc., shall be pressure tested in accordance with the original code of construction. Any pressure piping and fittings such as water columns, blowoff valves, feedwater regulators, superheaters, economizers, stop valves, etc., which are shipped connected to the boiler as a unit, shall be hydrostatically tested with the boiler and witnessed by an Inspector PRESSURE TEST Prior to initial operation, the completed boiler, individual module, or assembled module, shall be subjected to a pressure test in accordance with the requirements of the original code of construction. 4.6 TESTING AND ACCEPTANCE a) The installer shall exercise care during installation to prevent loose weld material, welding rods, small tools, and miscellaneous scrap metal from getting into the vessel. The installer shall inspect the interior of the vessel and its appurtenances where possible prior to making the final closures for the presence of foreign debris. b) The completed pressure vessel shall be pressure tested in the shop or in the field in accordance with the original code of construction. When required by the Jurisdiction, owner or user, the Inspector shall witness the pressure test of the completed installation, including piping to the pressure gage, pressure relief device, and, if present, level control devices. 5.4 EXAMINATION, INSPECTION, AND TESTING The owner shall ensure that all examinations, inspections, and tests required by the code of construction have been performed prior to operation.

47 IN SC Installation

48 NB SC Installation NB Rev AUTOMATIC LOW-WATER FUEL CUTOFF AND/OR WATER FEEDING DEVICE FOR STEAM OR VAPOR SYSTEM BOILERS a) Each automatically fired steam-or vapor-system boiler shall have an automatic low-water fuel cutoff so located as to automatically cut off the fuel supply when the surface of the water falls to the lowest visible part of the water-gage glass. If a water feeding device is installed, it shall be so constructed that the water inlet valve cannot feed water into the boiler through the float chamber and so located as to supply requisite feedwater. b) Such a fuel cutoff or water feeding device may be attached directly to a boiler. A fuel cutoff or water feeding device may also be installed in the tapped openings available for attaching a water glass directly to a boiler, provided the connections are made to the boiler with nonferrous tees or Y s not less than NPS 1/2 (DN 15) between the boiler and water glass so that the water glass is attached directly and as close as possible to the boiler; the run of the tee or Y shall take the water glass fittings, and the side outlet or branch of the tee or Y shall take the fuel cutoff or water feeding device. The ends of all nipples shall be reamed to full-size diameter. c) In addition to the requirements in a) and b) above, a secondary low-water fuel cutoff with manual reset shall be provided on each automatically fired steam or vapor system boiler. d) Fuel cutoffs and water feeding devices embodying a separate chamber shall have a vertical drain pipe, extended to a safe point of discharge, and a blowoff valve not less than NPS 3/4 (DN 20), located at the lowest point in the water equalizing pipe connections so that the chamber and the equalizing pipe can be flushed and the device tested.