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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?
ASME FAQ
Q: I am relocating my Shop facility (currently listed on the ASME Certificate of
Authorization) to a new location. Do I need an ASME relocation review at the new
shop facility in order to have my ASME Certificate of Authorization revised to
show the new shop location?
A: Where there is no change in jurisdiction or Authorized Inspection Agency (AIA) and
the distance involved is small enough to ensure that there are no changes in upper
management or QC personnel affecting the companys quality Control Program have
occurred, an ASME review may be replaced by an audit by the Authorized Inspection
Agency of Record if the relocation is within the same jurisdiction. Certificates Holders
who are relocating within the same jurisdiction should contact ASME at ca@asme.org if
they wish to have an AIA audit conducted in place of an ASME review.
Q: For a Change in shop Location how does a Certificate Holder comply with the
requirements in the above Question if they are not required by the Code to use
the services of an AIA?
A: For Certificate Holder's of V, HV, UV, UV3, TV, UD, and TD Certificates of
Authorization, ASME will require the ASME Designated Organization to conduct an audit

of the Certificate Holder to provide written verification of the following; 1. The address of
the new location, its distance from the previous shop location and that the new shop
location is within the same jurisdiction as the current location listed on the Certificate(s)
of Authorization; 2. That there are no changes in upper management or QC personnel
affecting the companys quality Control Program; 3. That there has been no change in
the scope of manufacturing activities as currently listed in the scope of the Certificate(s)
of Authorization; 4. That there is no major equipment change; 5. A summary of the audit
conducted by the ASME Designated Organization at the new shop location to ensure
that the Certificate Holder is implementing their Quality Control System, previously
accepted at the last ASME review; and 6. That the ASME Designated Organization has
tested two pressure relief devices per test medium manufactured/assembled at the new
shop location and the tested pressure relief devices have met the applicable
requirements of the ASME Boiler Code. The Certificate Holder will have the option of
either having the audit for a revision to their existing Certificate(s) conducted or a review
for early renewal of their Certificate(s).
For H (Cast Iron or Cast Aluminum) a renewal review is required.
Q: I am waiting to be assigned my ASME renewal review dates, or the renewal
review is scheduled to occur less than 6 weeks prior to the expiration date of my
certificate(s). What steps can I take to ensure that I can continue to fabricate and
code stamp components until my new certificate(s) or Authorization are
received?
A: Please review the information contained on the ASME webpage, listed under
"Additional Information" titled "Notice on Request for Extension of Expiration Dates for
Certificate(s)" - In addition, if the renewal review is conducted less than 6 weeks prior to
the certificate expiration date you can request the ASME Team Leader to fax the
Qualification Review Report (QRR) to ASME along with the Team Leader's
recommendation as to whether an extension should be granted by ASME.
Q: Due to a postal redesignation of the address of our current shop, I need to
obtain a revised Certificate Authorization. What procedure do I need to follow?
A: The Certificate Holder needs to inform ASME of the address change due to postal
redesignation of the building number, street name, zip code, etc. ASME will issue a
revised Certificate of Authorization provided the Certificate Holder's AIA of record
provides sufficient documentation to ASME to support the Certificate Holder's request.
Where there is no AIA involved in the Certificate Holder's Code activities, documentation
from the postal authority and/or the jurisdictional authorities where the shop is located
would be needed to support the request. There is no charge to revise Certificates of
Authorization due to postal redesignation.
Q: I recently changed my AIA of record. Do I need to inform ASME or does the AIA
take care of notifying ASME?

A: It is the Certificate Holder's responsibility to immediately inform ASME as soon as


they make a change in the AIA of record. Also, ASME should receive notification from
the previous AIA of record that they no longer have an inspection agreement with the
Certificate Holder and a letter from the new AIA of record indicating that the new AIA has
a contract to perform inspection services at the facility located at the address listed on
the Certificate Holder's Certificate of Authorization. The Certificate Holder may be
required to provide ASME with sufficient documentation to verify that they had a valid
contract with an AIA at the time that all components were ASME Code Symbol stamped.
This may be required if there a gap between notification of the change of AIA of record
and the date the new inspection contract is signed. ASME copies the Certificate
Holder's AIA of record on most correspondence to the Certificate Holder. Failure to
provide ASME with the name of your current AIA of record may result in the new AIA not
receiving notification of important information, or even loss of certification.
Q: My Companys name was recently or is going to be changed. How do I go
about getting a Certificate of Authorization with the new name on it?
A: See "Process to Request Name Change on Certificate(s)" Note: Name changes are
available for companies undergoing a reorganization or wishing to change the "brand
name" on their Certificate, where all essential QC personnel and workforce involved in
code activities has essentially remained unchanged and there has been no change in
continuity in their quality program meeting ASME quality control requirements. A name
change is not available to a company that only purchases the physical assets (i.e.,
building, equipment) of a Certificate Holder. Certificate and stamps cannot be
transferred from one corporate entity to another corporate entity. A full ASME review is
required for a different corporate entity to get an ASME Certificate of Authorization and
stamp. When requesting a name change the corporate entity requesting the name
change is required to submit a letter to ASME on the letterhead of the Corporate name
stating that the newly named corporate entity accepts all responsibility for ASME
stamped items produced under the certificate of authorization bearing the "new"
company name but containing the certificate number previously issued under the "old"
company name.
Q: I recently received an ASME U or S Certificate of Authorization. At the time of
the review I did not apply for additional Certification. I would now like to apply for
an A, PP or UM Certificate. Do I need to have another ASME review?
A: A full ASME review is not required for a Holder of an ASME S who applies for an A or
PP Certificate. A full ASME review is not required for a holder of an ASME U or S
Certificate who applies for a UM Certificate. ASME will require written verification from
both the ASME Team Leader who conducted the latest review for U accreditation and
the Certificate Holder's AIA, who participated in the review, that the Certificate Holder's
Quality Control Manual and QC System have been revised to include all additional
Code requirements required to fabricate components for the requested Certificate. Upon
receipt of a favorable recommendation from both the ASME Team Leader and the AIA
and the receipt of applicable fees, ASME will issue the requested Certificate and stamp.

Q: I recently underwent a joint review and received my U Certificate of


Authorization. Now I would like to apply for additional certificates (such as an S
and U2). Do I need another ASME review?
A: The addition of any Certificate of Authorization would require another joint review
with the exception of an S stamp holder applying for an A or PP, or a U or S stamp
holder applying for UM accreditation. The conditions for those applicants are described
elsewhere in other FAQ's. Requests for additional Certificates, without a full ASME
review, made within three months following the date a full ASME review was conducted
can be submitted to ASME for approval by the Committee on BPV Conformity
Assessment.
Q: I do not intend to renew my ASME Certificate of Authorization. However, I have
a job in the shop that I will not be able to complete prior to the expiration date on
my Certificates of Authorization. Can I request an extension from ASME to
complete the work?
A: A Certificate Holder can apply for a "Work-In-Progress" extension. The Certificate
Holder will need to send a letter to ASME at least 30 days prior to the expiration date on
the Certificate of Authorization requesting an extension of the appropriate Certificate to
complete an ongoing job. The request from the Certificate Holder should include the
following information and be accompanied by the applicable fee (shown in renewal
application package): Description of the work to be completed, including work/job
number, the number and type (S, PP, H, U, etc) of Code components involved and the
expected completion date for the work. ASME will contact the Certificate Holder's AIA or
ASME Designee, as appropriate, and request: 1. Written verification of the information
provided by the Certificate Holder; and 2. Verification that an audit of the Certificate
Holder's shop facility has recently been performed and the AIA/Designee is satisfied that
the Certificate Holder's Quality Control program is still in place and that they can
fabricate Code components in compliance with the applicable requirements in the
ASME Code. Upon receipt of a satisfactory report from the AIA/ASME Designee and
payment of the applicable fees ASME will issue a Work-In-Progress Extension for a
period of up to six months or until completion of the specified job, whichever occurs first.
No further extensions will be granted and no additional or new work can be started after
the original expiration date shown on the Certificate(s) of Authorization.
Q: I did not submit my application for renewal of my Certificate of Authorization to
ASME on time. The renewal review was held after the expiration date on my
Certificate of Authorization and I would like to keep my old Certificate number for
advertising purposes. What should I do?
A: It is ASME policy to assign new Certificate numbers under the following situations: on
the issuance of a Certificate of Authorization for the first time; and when a current
Certificate Holder's Certificate of Authorization has expired prior to the date the renewal
review was held and no extension was granted by ASME due to failure by the Certificate
Holder to submit the renewal application and fees to ASME at least 3 months prior to

the expiration date on the Certificate(s). However, the Certificate Holder may submit a
written request to ASME stating the reason they wish to have their expired Certificate
number reinstated, and the reason for the late submittal of their application for renewal
of their Certificate. ASME may grant the request provided: 1. The lapse in certification
from the expiration date on the old Certificate of Authorization to the date of issuance or
the new Certificate of Authorization has not exceeded three months; or 2. The review
was conducted within the three month period but ASME was unable to process the
Review Team recommendation within the three-month period.
Q: Which AIA's work outside of the United States and Canada?
A: There are Authorized Inspection Agencies that operate around the world. Please see
the AIA list on the ASME web site. Some have listed a website where you can find the
locations of their local offices. Otherwise a phone number, fax number and E-mail is
provided where you can ask the AIA directly.
Q: Do Authorized Inspection Agencies help write the manual or just review it?
A: You may contact the Authorized Inspection Agencies regarding the services that they
provide outside the duties required of them by the ASME Code. Many AIAs will assist
the applicant in developing a quality manual.
Q: During the Shop Review required to get an ASME stamp, is it necessary to
have a product in process of fabrication?
A: A demonstration or implementation of the quality control system during the Review
must include the administrative functions to support the QC system and the
manufacturing, fabrication and testing of product necessary to indicate knowledge and
ability to produce the items covered by the scope of the system. For evaluation of the
QC system, the Applicant must demonstrate sufficient administrative and fabrication
functions to show that they have the knowledge and ability to produce the Code items
for the type of certification applied for. Fabrication functions may be demonstrated using
current work, a mock-up to current Code rules, or a combination of the two.
Q: Does ASME provide consulting to help a company obtain a stamp?
A: ASME can provide support through the application process to obtain a stamp. We do
not provide consulting services to develop a quality system that will meet the
requirements of the ASME Code. Providing consulting services to a company to arrange
their quality system, which we would then approve, would pose a conflict of interest.
The Applicants contracted Authorized Inspection Agency should be able to provide
assistance in development of an acceptable QC Manual and provide guidance
regarding what will be covered in the ASME review. Additional information regarding
development of a QC Manual can be found in the ASME Applicants Checklist which can
be found on the ASME website