test organization program · a) the user shall establish a documented in‐house training program....
TRANSCRIPT
Test Organization ProgramCurrent Status, Future Opportunities
October 2016
Test Organization Program
Session overview
• Basic program details and NBIC basis• Current Implementation details• Future opportunities
Test Organization Program
• Formal implementation of “Test Only” process based on NBIC Part 2
• Developed to provide a certification program for organizations that only perform In‐Service testing of pressure relief valves
• Authorized in Feb. 2016 by Board of Trustees• Structure based on VR program
Program Background from NBIC Part 2
Inservice Inspection of Pressure Relief Valves• Device Data (2.5.2)
• Set pressure – compare to MAWP• Code stamps (VR stamps)• Record Nameplate data• Seal Identification
• Physical Inspection (2.5.3)• Seals intact• Valve physical condition, signs of leakage or
corrosion
Program Background
• Installation Inspection (2.5.4)• Inlet piping• Outlet piping, discharge location• Relief path arrangement
• Device Testing (2.5.7)• Acceptance Criteria: Original Code of Construction• Inspection of inlet and outlet connections for valves
that are removed for testing
Program Background
2.5.7 g)“If a 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 an organization accredited by the National Board to reset the valve to the correct opening pressure.”
T/O Program
• Provides formal process for defining and evaluating “an organization accredited by the National Board”
• Gives recognition for “fine tuning” inserviceadjustments, and method of documentation for adjustments that have been resealed• Traceablity through T/O nameplate and
test/inspection report via test number
Implementation
• NB‐528 program document published• T/O page on National Board web site published
(linked to pressure relief and stamps & marks page)
• Program documents prepared• NB‐535 Application Form• NB‐532 Control Sheet• NB‐564 Terms and Conditions• NB‐537 Checklist
Implementation
• June: Presentation to Valve Repair Council (part of Valve Manufacturer’s Association)
• June and September VR schools: T/O session added to curriculum
• Bulletin articles and “Ad” page published• Web page article published for first stamp
issuance• NB Representative training in August
Implementation
• Process for trademark registration of T/O symbol started• “Notification to Use”
Application Process
• Application submittal• Current VR stamp holder
• Update QC manual and submit for acceptance• Develop test procedure and test/ inspection report• Update “Test Only” nameplate – add test number
and T/O symbol
Application Process
• New Applicant• Prepare QC manual• Schedule audit• QC Manual reviewed by NB Representative• Testing process demonstrated• Demonstration valves submitted to accepted test
lab for verification
Note: NB‐528 indicates Jurisdiction may be involved in shop review
Next Steps
• NBIC Changes to acknowledge T/O program1. NBIC Scope updates prepared for 2017 edition (in
public review draft)2. Request updates to NBIC Part 2, 2.5.7
Possible NBIC Revision?
2.5.7 g)“If a 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 an organization accredited by the National Board a National Board VR or T/O certificate holder, or other organization acceptable to the Jurisdiction to reset the valve to the correct opening pressure.”
Jurisdictional Interaction
• Consider use of T/O program in place of NBIC Part 3, Supplement S7.10
NBIC Part 3, S7.10
S7.10 background
• Origin as guidance letter • Later incorporated into NBIC
NBIC Part 3, S7.10
GUIDE TO JURISDICTIONS FOR AUTHORIZATION OF OWNER OR USERS TO MAKE ADJUSTMENTS TO PRESSURE RELIEF VALVES
S7.10.1 GENERAL
The Jurisdiction may authorize properly trained and qualified employees of boiler and pressure vessel owners or users or their designees to confirm or restore nameplate set pressure and/or performance of pressure relief valves. All external adjustments shall be resealed with a seal identifying the responsible organization and a metal tag that identifies the organization and the date the adjustment shall be installed.
S7.10 cont.
S7.10.2 TRAININGa) The user shall establish a documented in‐house training
program. (training details follow)S7.10.3 DOCUMENTATION
Each user shall document the evaluation and acceptance of an employee’s or designee’s qualifications.S7.10.4 QUALITY SYSTEMa) A written quality system shall be established by either the user or the designee with a written descriptionavailable to the jurisdictional authority.b) The written description shall include at a minimum: (manual details follow)
S7.10 cont.
1) Calibration of Test Equipment: This shall describe a system for the calibration of measuring and test equipment. Documentation of these calibrations shall include the standard used and the results. Calibration standards shall be calibrated against the equipment having valid relationships to nationally recognized standards.2) Valve Testing, Setting, and Sealing: This system shall include provisions that each valve shall be tested, set, and all external adjustments sealed according to the requirements of the applicableASME Code Section and NBIC Part 3, S7.10.1.3) Valve Marking: An effective marking system shall be established to ensure proper marking of the metal tag required by NBIC Part 3, S7.10.1. The written quality system shall include a description ofdrawing of the metal tag.
S7.10 cont.
S7.10.5 EXTERNAL ADJUSTMENTSOnly external adjustments to restore the nameplate set pressure and/or performance of a pressure reliefvalve shall be made under the provisions of NBIC Part 3, S7.10.1 and NBIC Part 2, 2.5.7.S7.10.6 REPAIRSIf disassembly, change of set pressure, or additional repairs are necessary, the valve shall be repaired byan organization that meets the requirements of the NBIC.
NBIC Part 3, S7.10 Concerns
• No Recertification Included (no time period specified)
• No test report or traceability requirement included
• Includes reference to designee – how is third party involved?
• How widely used is this part of Supplement 7?
Possible NBIC Revision?
The Jurisdiction may authorize properly trained and qualified employees of boiler and pressure vessel owners or users or their designees to confirm or restore nameplate set pressure and/or performance of pressure relief valves. “Jurisdictions may require owners or users or their designees to obtain a National Board T/O Certificate for this purpose.”“The Jurisdiction may require periodic renewal of this authorization which may include a review or audit.”
Opportunities for Improvement
‐ NBIC test requirement listed as “RECOMMENDED INSPECTION AND TEST FREQUENCIES FOR PRESSURE RELIEF DEVICES”
“Recommendations” are hard to enforce.
‐ Table values are prescriptive, mostly based upon set time intervals
Opportunities for Improvement
Expand the concept of test intervals being based upon test history.2.5.8 a) Power Boilers1) Pressure less than 400 psig (2.76 MPa): Manual check every 6 months; pressure test annually to verify nameplate set pressure or as determined by operating experience as verified by testing history.2) Pressure greater than 400 psig (2.76 MPa): Pressure test to verify nameplate set pressure every three years or as determined by operating experience as verified by testing history.
Opportunities for Improvement
Expand application of Risk Based Inspection (RBI) to pressure relief device inspection.
(See NBIC Part 2, par. 4.5, and 4.5.7)
Opportunities for Improvement
4.5.7 JURISDICTIONAL RELATIONSHIPSJurisdictions mandate specific codes/standards with rules or laws that may differ between jurisdictions. Frequency and types of inspections are examples of requirements that may vary. Owners and users implementing RBI assessment plans should understand jurisdictional requirements, so deviations from the mandated types of inspection and frequency of inspection can be requested. Methods used to develop and implement RBI assessment methods and the RBI program developed from those methods shall be acceptable to the Jurisdiction and the Inspector as required.
Conclusion
Membership needs will drive these issues.
Feedback to the NBIC committee, through National Board members on committees, or via NB staff can all be avenues for NBIC development. Updates from this feedback then be incorporated by reference into Jurisdictional requirements.
Your opinions are needed, and of value to the standard development process!