[Sent from someone who wants to remain anonymous. -PB]
paul,
I dont know if this should be posted, its pretty strong. If you decide to I
would only ask you post it anonymously.
You have expounded further very clearly on why in my opinion (as I stated)
re-rating practice in many instances
(generally without the necessary requisite committments)
is that it is not worth it anymore from a third party standpoint... even as
an "employee" (not third party) doing the sign off
under someone elses umbrella.
The expectaton is always clear , but the committment is absent.
I agree your remarks are profound. What you are signing off on, and
accepting responsibility for is that
the changes fully comply (in every respect) with the intent and requirements
of the Code in full.
The code (piping and vessel) does allow "other methods" of design if you can demonstrate and have them accepted as equivalent or better. This is actually a tall order. But it is common practice to rework something , rehydro it and operate it higher or lower or different in some way... whatever your definition of "re-rated" is.
The first time i encountered this was in rescuing a costly pipeline and by fracture mechanics and FEA ,to show it was still serviceable. Very risky exercise fraught with many dangers, not well understood by the participants, including myself (fully) at the time.. But it is still operating. Many millions and much hardware and resources have been saved and re-used by many peoples efforts. I'm sure everybody knows of such cases, but that doesnt make it run of the mill and the widespread trivialization of the practice is disturbing.
In these situations all my (and your) comments about risk and knowledge of
what you are doing apply in full.
What is scary is the participants (and perpetrators) do NOT "seem" to
understand what this means. Many statements I have heard are just horrific.
I am very glad this is being discussed and your wisdom is out there because
it seems nobody (precious few) understand these issues. Am i overstating
this. NO.
I have the transcript and recently sat with a group of experts in a Civil
Trial from a big failure listening to an ENGINEER PhD from a prestigious
university tell the judge the Codes were "irrelevant", & "guidelines" and
could be over-ruled by him and vicariously therefore by the others involved
(essentially at will). He cited his opinions as acceptable practice (without
his involvement in the project, knowledge or responsilibity) directly in
contradiction to the clear statements of the code rules. When such
perspectives are out there unchecked we are all in trouble.
When the court awards two $50k education funds for the deaths of workers in
a negligent refinery disaster we are all in trouble. When a Sour gas
facility is approved for a
dense residential area with no identifiable plan or mitigation we are all in
trouble.
As codes go less prescriptive this will get worse. The Longhorn Disaster
book describes similar as does much other literature. These days we dont see
most reports/postmortems because of gag orders. We used to see far more
postmortems and they are enormously valuable learning exercises. This itself
is a
tragedy.
The worst is when owners and "players" make changes or alterations and want you to stamp and anoint them with "holy water" (and more) "after the fact".
Worse they wont co-operate in helping mitigate the risk in undertaking such an exercise. Bottom dollar is not the way to do this, but it is what is expected.
They resent the effort and questions and wont co-operate in trying to gather the answers you need to make the assessment. You know the code words and turns of phrase.
These situations are occuring more and more often, in fact now increasingly
we are asked to stamp and signoff with
NO work done (or precious little) and NO information. I could cite many
examples.
If I sound frustrated, I think its clear why..... The overtures are always that the hurricane will only come on the other/next guys shift.
>>
>> On Sep 9, 2005, at 11:57 AM, aluser2 wrote:
>>
>
>>> > chris, it is legit under the code.
>
>> I don't think so, but if you can cite me chapter and verse, I'll
>> consider it.
>>
>> First, the Code doesn't 'rate' anything. The pressure vessel codes are
>> a set of rules to be followed in the construction of pressure vessels.
>> If the AI finds that all the applicable rules are followed for the
>> construction and service conditions, the vessel may be stamped with the
>> ASME cloverleaf for a specific MAWP. The Code plate isn't a 'rating;'
>> it simply indicates that the vessel construction accords with Code
>> rules. Once the stamp is applied, construction ends and that's the end
>> of the Code's purview. There is no 'rating,' just a statement of
>> compliance. This is covered in the Foreword to Section VIII, and I
>> suspect you'll find similar language in the piping codes. You can't
>> convert a non-Code vessel into a Code vessel just by doing numbers or
>> with a hydro-test, and you can't make a Code vessel stamped with a MAWP
>> of 250 psi into a Code vessel stamped with a MAWP of 275 psi--once the
>> stamp is applied the Code has no more to say.
>>
>> Moreover, the code can't 'rate' a vessel because it makes no statement
>> of suitability for a given service. The owner takes that responsibility
>> when he installs the vessel. That's covered in the Foreword, too.
>>
>> After installation, modifications are governed by the jurisdictional
>> rules. If the jurisdiction is loose, the owner or his agent might
>> 're-rate' or fiddle to his heart's content, up to the point where
>> injury or property damage occurs and the insurors or the courts take
>> over. But the ASME Code has nothing to do with it, because it only
>> governs new construction. The National Board Inspection Code part RA
>> may apply to modifications or repairs, again depending on the
>> jurisdiction. But not the ASME Construction codes. If the jurisdiction
>> is tight or OSHA rules apply, the owner who operates a Code-stamped
>> vessel at a pressure higher than the MAWP may face fines or loss of
>> insurance coverage
>>
>> That said, I don't think any jurisdiction can prevent an owner from
>> contacting someone to run numbers or do tests and make a judgment that
>> a vessel can be used at some other pressure than that found on the Code
>> plate. To that extent 're-rating' up or down is possible. But it is not
>> in compliance with the Code because the Code only applies to new
>> construction. And the parties involved necessarily assume all liability
>> in the event that things don't work out, including civil penalties for
>> violating any jurisdictional requirements mandating Code rules for
>> pressure vessels. That's because the ASME Code represents the standard
>> of care for pressure vessel design in the US and Canada. When you take
>> liberties with the Code rules you're sticking your neck way out. If
>> you're running a Code vessel stamped for a MAWP of 250 psi at a service
>> requiring 300 psi, you're ignoring the standard of care, and if
>> anything happens, you're on the hook for it--the Code won't save you.
Received on Sun Sep 11 02:17:00 2005
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