1995 Interps

1995 NBIC Interpretations
INTERPRETATION 95-57
Subject: RB-3238(e) Above Ground Vessels
1995 Edition with the 1996 Addendum
Question 1: Does the interval of the lesser of five (5) years or 1/4 life refer only to an
initial external inspection?
Reply 1: No.
Question 2: Does the NBIC establish an inspection interval for periodic external
examinations?
Reply 2: Yes. The external inspection interval is defined in RB-3238 (e) & (f) with
remaining life calculated as per RB-3236.
Subject: RA-2231 (b)(1) Acceptance of Code Cases 1923 and 1945 when used in
Original Construction
Question: Under the provisions of paragraph RA-2231 (b)(1), is it permissible for a
“VR” stampholder to repair a restricted lift valve when ASME Code Case
1923-2 or 1945-3 was used in the original construction?
Reply: Yes, provided no change is made in valve lift.
Subject: RB-3550 Operational Inspection
Question: Under the provisions of paragraph RB-3550, may a repair organization
that meets the requirements of RA-2220 act as the designee of a pressure
vessel user to make adjustments to a steam service pressure relief valve
with air as the test media, provided that:
a. the jurisdiction has authorized such adjustments;

b. no “VR” Symbol is applied to the pressure relief valve?
Reply: Yes.
Subject: RC-2050 Pressure Testing
Question: In accordance with RC-1130, is it required that the inspector witness any
pressure test of a repair or alteration?
Reply: Yes, except as provided by RC-2031 (b).
Subject: RD-2031 Routine Repairs
Question 1: Is the addition of a nozzle penetrating through a head or shell considered a
routine repair?
Reply 1: No.
Question 2: Is a pipe nozzle that penetrates a head or shell considered a section of pipe
used in RC-2031?
Reply 2: No.
Subject: RD-2060 Patches, Figure 8
Question 1: Is there a maximum length-to-width ratio for the tube window patch
configuration?
Reply 1: No, the NBIC does not specify dimensions for the patch.
Question 2: Is there a maximum dimension allowed for the tube window patch?
Reply 2: No, the NBIC does not specify dimensions for the patch.
Subject: RC-1090
Question: May an “R” Certificate Holder use weld procedures and welders qualified
by a technically competent group or agency?
Reply: Yes, as permitted by RC-1092 or when allowed by the original code of
construction.
Subject: RC-2072 and RC-3052
Question: Does the term “attachment” as used in RC-2072 and RC-3052 refer to
Material Test Reports?
Reply: No, the term applies to R-3, R-4 and Manufacturer’s Partial Data Reports.
Subject: Appendix 6, B-17
Question: Does the example of a repair given in Appendix 6, paragraph B-17 apply
only to material changes within a single P number?
Reply: No.
Subject: RC-1020, RB-1050(a) & Appendix 6, B-6
Question 1: May retubing and testing a boiler whose original code of construction is
ASME Section IV be documented on an R-1 if the replacement tubes are
expanded as permitted in ASME Section IV, HG-360.2?
Reply 1: Yes, provided all applicable requirements of the NBIC are met.
Question 2: May repairs to saddles, frames or supports of pressure vessels be
documented on an R-1?
Reply 2: Yes, provided all applicable requirements of the NBIC are met.
Subject: RB-4020
Question: When replacing a nameplate, may the National Board number be stamped
on the replacement nameplate by the original manufacturer when the
manufacturer no longer holds an ASME Certificate of Authorization?
Reply: Yes, provided the requirements of RB-4000 are met.
Subject: Appendix 6, B-7
Question 1: May the example of a repair given in Appendix 6, paragraph B-7 apply to
a nozzle or an opening for which the axis is not perpendicular to the wall
or head of a pressure-retaining item?
Reply 1: Yes, provided calculations to determine availability of reinforcement
(compensation) for such construction is not a consideration of the original
code of construction.
Question 2: May the example of a repair given in Appendix 6, paragraph B-7 apply to
nozzles and openings larger than NPS 3?
Reply 2: Yes, provided calculations to determine availability of reinforcement
(compensation) for such construction is not a consideration of the original
code of construction.
Subject: Appendix 4
Definition of Repair
Question 1: Providing there is no work performed on pressure-retaining items, is the
removal of a coal grate, installation of new burners, brick wall
modifications, and concrete and refractory work outside the scope of the
NBIC?
Reply 1: Yes, provided the required safety or safety relief valve relieving capacity
is not increased.
Question 2: In a high temperature water boiler, is an increase in the maximum design
output in Btu/hr, which requires an increase in the safety relief valve
relieving capacity considered an alteration in accordance with the NBIC?
Reply 2: Yes.
Subject: Appendix 6, Item C-5
Examples of Alterations
Question: For a boiler stamped in accordance with the ASME Code, Section I, is it
the intent of Appendix 6, paragraph C.5 that an increase in heating surface
be considered an alteration only when the resulting change requires an
increase in the relieving capacity of the safety valves?
Reply: Yes.
Subject: Appendix 5, Definition of Repair
Question: May the welding of a new circumferential seam in a completed, code
stamped and certified ASME Code pressure vessel be classified as a
repair?
Reply: Yes.
Subject: RC-2070 Documentation
RC-3050 Documentation
Question: When work classified as an alteration is performed in conjunction with
work on the same pressure-retaining item classified as a repair, do both
Form R-1 and Form R-2 need to be prepared?
Reply: No, as long as the repair work is identified on Form R-2 along with the
alteration work.
Subject: RC-1110 Nondestructive Examination
Question 1: When performing in-service inspection, radiographic examination
uncovers indications in welds made by the original manufacturer that are
in excess of that allowed by the original code of construction. Is it a
requirement that these welds be repaired?
Reply 1: The decision as to whether or not to perform a repair of deficiencies
discovered during in-service inspection is outside the scope of the Code.
See RB-3280.
Question 2: When nondestructive examination of a repair weld reveals indications in
excess of that allowed by the original code of construction, must the
indication be removed or reduced to an acceptable size?
Reply 2: Yes.
Subject: Appendix 5, Form R-2 Report of Alteration
Question 1: Does the NBIC require that the Data Report Forms used to report repairs
and alterations be identical to the forms shown in Appendix 5?
Reply 1: Yes.
Question 2: May the Data Report Forms used for repairs and alterations be computer
generated?
Reply 2: Yes, provided they are identical to the forms shown in Appendix 5.
Question: Is the performance of a pressure test in accordance with RC-2050(a)
required after a routine repair?
Reply: Yes, except as permitted by RC-2050(g).
Subject: RB-3234 Pressure Testing
Question: Does RB-3234 allow for an in-service pressure test in excess of 1-1/2
times the MAWP adjusted for temperature?
Reply: No, where any provision of the NBIC presents a direct or implied conflict
with any regulation, the jurisdictional regulation shall govern. However, in
these circumstances, the activity cannot be documented as meeting the
requirements of the NBIC.
Withdrawn
Subject: RC-1020 Construction Standards
Question: When work is performed under the NBIC to a code other than the original
code of construction, is it required that the work be classified as an
alteration?
Reply: No, see RC-1020. The use of a different design basis code does not
necessarily require work to be classified as an alteration; however, the
concurrence of the Inspector and the jurisdiction is required for this
determination.
Subject: R-200 Definition of Terms
Question 1: Is the welding in of a plug to seal tubes in a boiler or pressure vessel
considered a repair?
Reply 1: Yes.
Question 2: Does the NBIC apply to plugging tubes by welding plugs to tubes and/or
their joints to tube sheets of tubes that have leaked, tubes that have
corroded to an unacceptable thin wall thickness, and tubes required to be
removed from service for operating reasons in boilers and pressure
vessels?
Reply 2: Yes.
Subject: Appendix 4, Definition of an Authorized Inspection Agency
1995 Edition
Question 1: In Appendix 4, the definition of an Authorized Inspection Agency refers to
the National Board Rules and Regulations. If an Inspector is assigned to a
shop that only holds an “R” Certificate of Authorization and performs
inspections of repairs and alterations to pressure-retaining items, is the
Authorized Inspector Supervisor required to audit the performance of the
Inspector as specified in 3.4.3.(d) of the National Board Rules and
Regulations?
Reply 1: No.
Question 2: In Appendix 4, the definition of an Authorized Inspection Agency refers to
the National Board Rules and Regulations. If an Inspector is assigned to a
shop that only holds an “R” Certificate of Authorization and performs
inspections of repairs and alterations to pressure-retaining items, is the
Inspector required to monitor the quality program?
Reply 2: No; however, the Inspector shall assure compliance with the requirements
of the NBIC. See RC-1130.
INTERPRETATION 95-33(a)
Subject: Appendix C-R, 4.0 (f)
Question: May an “R” Certificate of Authorization holder with field repair in the
scope of its “R” Certificate perform repairs and alterations in other shops
owned by the Certificate Holder?
Reply: No. Each shop must have its own certificate.
Subject: RC-2031(a)(2) Definition of “non-load bearing”
1995 Edition
Question: Does the NBIC specify a quantitative value below which an attachment is
considered non-load bearing?
Reply: No, “non-load bearing attachment” is a generally accepted design term
referring to items that transmit an inconsequential load onto the pressure
retaining boundary.
1995 Edition, 1995 Addendum
Question: In RC-2050(a), does the expression “shall be pressure tested at 80% of the
maximum allowable working pressure stamped on the pressure-retaining
item or operating pressure, whichever is greater” mean not less than the
greater of 80% of the maximum allowable working pressure or the
operating pressure?
Reply: Yes.
Subject: RC-2031 Routine Repairs
Question: Do the provisions in RC-2031(b) for waiving the inprocess involvement of
the
Inspector on routine repairs include waiving the requirement for the
Inspector to witness a pressure test as addressed in RC-1130?
Reply: Yes.
Subject: Data Report Forms
1995 Edition
Question 1: May repairs or alterations performed in accordance with the requirements
of API-510 be documented on NBIC forms R-1 or R-2?
Reply 1: No.
Question 2: May repairs or alterations performed in accordance with the requirements
of API-510 be accepted by the Inspector?
Reply 2: This is outside the scope of the NBIC.
Subject: RC-1070 Inspector
1995 Edition
Question: Is it the intent of the NBIC that a jurisdiction as defined in Appendix 4
which is not a member of the National Board, employ inspectors for
inspection of repairs and alterations as referenced in RC-1070(a)?
Reply: Yes, RC-1070(a) does not restrict the jurisdiction to only National Board
Members.
Subject: RC-2031 Routine Repairs
1995 Edition
Question: Do the provisions in RC-2031(a) for waiving the inprocess involvement of
the inspector on routine repairs include waiving the requirement for the
inspector to sign the Form R-1 as addressed in RC-2071(b)?
Reply: No. The requirements of RC-2071(b) are applicable for all repairs,
including routine repairs. See RC-2031(d).
Subject: RC-2031 Routing Repairs
RC-2050 Pressure Testing
RC-2060 Stamping
RC-2072 Distribution
1995 Edition
Question 1: May the repair of cracks or pinholes be considered a routine repair?
Reply 1: The scope of routine repairs are defined in RC-2031. The nature of the
defect is not a criteria for determining whether the repair is routine.
Question 2: Is the registration of R-1 forms an option?
Reply 2: Yes, see RC-2072. However, the jurisdiction may require registration
(RC-1150).
Question 3: May the “R” Symbol Stamp be applied to a repaired item whether or not
the R1 form is registered with the National Board?
Reply 3: Yes, provided all of the requirements of the NBIC are met. See RC-2060.
Question 4: Who is responsible for determining whether or not it is practical to
perform a pressure test of a repaired item?
Reply 4: The “R” Certificate Holder. See RC-2050(a).
Subject: RA-2262 Nameplate Contents,
Question: Is it the intent of RA-2262 (NB-65, paragraph 9.2(a)) that the capacity and
type model number be included on the valve repair nameplate only when
this information has been changed?
Reply: Yes.
Subject: Appendix 5, Form R-1,
1995 Edition
Question: Is it required that the inspector perform a physical inspection of routine
repairs to enable completion of the Certificate of Inspection block on
Form R-1?
Reply: No. When the Remarks section of Form R-1 includes the Statement
“Routine Repairs” in accordance with RC-2031(d), it is understood that
the inspection signed for by the inspector is a document review and that a
physical inspection may not have been performed.
Subject: Appendix 2,
1995 Edition
Question 1: Are nameplates required to have the same layout as the figures shown in
Appendix 2?
Reply 1: No. However, all information shown in the figures must be included on
the stamping or nameplate and the National Board Certificate number
must appear directly below the symbol stamp.
Question 2: Are the instructions (MAWP, ° F, etc.) shown in the figures in Appendix 2
required to be included on the stamping or nameplate?
Reply 2: Yes. However, the words “Certificate Holder” and “National Board “R”
Certificate Number” may be omitted.
Subject: RC-1010 Scope,
1995 Edition
Question: May repairs to cargo containers that are designed to ASME Section VIII,
Division 1 but are not stamped with the “U” Symbol be documented on
the form R-1, if the repair facility maintains the National Board “R”
Symbol?
Reply: Yes.
Subject: RC-3020 Design, RC-3021 Calculations,
1995 Edition
Question: May the rules of RC-3020 and RC-3021 be followed to reclassify a vessel
originally constructed to ASME, Section III, to ASME, Section VIII?
Reply: No. The NBIC does not provide rules for reclassification of pressure-
retaining items.
Subject: Appendix 4, Definition of Alteration,
1995 Edition
Question: May an ASME Section VIII, Division 1 pressure vessel that has postweld
heat treatment reported on an ASME Manufacturer’s Data Report, be
repaired by welding without subsequent postweld heat treatment or
postweld heat treatment alternatives?
Reply: No. This is an alteration.
Subject: Foreword
1995 Edition
Question: May the requirements of an earlier Edition and Addenda of the NBIC be
used when performing a repair or alteration?
Reply: Yes.
Subject: RC-1000 General Requirements
1995 Edition
Question: When the NBIC references “the original code of construction,” is it
required to use the edition and addenda of that code as used for
construction?
Reply: No. The term “original code of construction” refers to the document itself,
not the edition/addenda of the document. Repairs and alterations may be
performed to the edition/addenda used for the original construction or a
later edition/addenda most applicable to the work.
Subject: Appendix C-NR, NR-1000 Scope and Applicability
1992 Edition with the 1994 Addenda
Question 1: Is it a requirement of the NBIC that the rules of Appendix C-NR be
applied to any repair or modification performed on an ASME Section III
N-Stamped item, even though the installed item is not located in a Class 1,
2, or 3 system within the ASME Section XI Program boundaries
established by the Owner in accordance with regulatory safety system
classification so as to maintain its ASME Section III Code integrity?
Reply 1: No. The rules of Appendix C-NR are not required for repairs or
modifications to ASME Section III items installed outside of ASME
Section XI system boundaries.
Question 2: Is it a requirement of the NBIC that any work performed on an item prior
to its installation in a Class 1, 2, or 3 system within the ASME Section XI
Program be performed under the rules of Appendix C-NR?
Reply 2: Yes. Upon completion of the construction Code, any repairs or
modifications of an item intended for service in an ASME Section XI
system must be performed under the rules of Appendix C-NR to maintain
the Code integrity of the item.
Question 3: Is it permissible for the owner to reuse an ASME Section III N-Stamped
item that was installed in a location not within the ASME Section XI Class
1, 2, or 3 system, provided all work performed on the item was in
accordance with the rules of Appendix C-NR?
Reply 3: Yes. Under the described conditions, the Code integrity would be
maintained for possible reuse of the item in an ASME Section XI Class 1,
2, or 3 system application.
Question 4: Under the requirements of Appendix C-NR, is it permissible for the owner
to reuse an ASME Section III N-Stamped item that was installed in a
location not within the ASME Section XI Class 1, 2, or 3 system even
though work had been performed on the item outside the rules of
Appendix C-NR?
Reply 4: No. An item on which repair or modification activities have been
performed outside of the rules of Appendix C-NR may not be
subsequently used in an application which requires compliance with the
rules of Appendix C-NR.
Subject: R-404 Authorization of Organizations Making Repairs
Question 1: Is it the intent of the NBIC to permit documented repairs (Form R-1)
regardless of whether documented or undocumented repairs have been
performed in the past?
Reply 1: Yes, provided the original construction was to the ASME Code.
Question 2: When an “R” Certificate Holder performs a repair on a vessel, does the
Certificate Holder assume responsibility for the work performed by others
on the vessel?
Reply 2: No.
Subject: R-302.1 Welding Procedure Specifications
Question: Is it permissible for a repair organization to carry out repairs using
qualified weld procedure specifications supplied by an owner-user of the
boiler, pressure vessel or piping to be repaired?
Reply: No.
Subject: R-307 Replacement of Pressure Parts
Question: Is it permissible to use an assembly from an inservice pressure vessel as a
replacement part for the repair/alteration of a second vessel?
Reply: Yes, provided the intended repair/alteration has the concurrence of the
jurisdiction and the Authorized Inspection Agency.
Subject: R-202 Alteration
Question: May a welded repair to a pressure vessel be performed without postweld
heat treatment or acceptable alternative to postweld heat treatment, when
the pressure vessel as reported on the data report was postweld heat treated
during construction?
Reply: No.
Subject: U-106 Maximum Period Between Inspections
Question 1: Does Chapter V mandate the type of inspection to be performed?
Reply 1: No. The type of inspection (internal, external, NDE, etc.) is established by
the owner-user and the Inspector provided the inspection method provides
sufficient information to determine if the vessel can be safely operated.
Question 2: In accordance with paragraph U-106, may a “complete on-stream
evaluation of pressure vessels” be performed in lieu of an internal
inspection?
Reply 2: Yes.
Question 3: U-106(c) states that under specific circumstances and when the corrosion
rate is known to be zero a vessel need not be internally inspected. Does
this mean that an internal inspection is required when the corrosion rate is
not zero?
Reply 3: U-106(c) provides guidance for a specific situation. The requirements of
U-106(c) are not related to the requirements of U-106(b).
Subject: U-107 Inspection for Corrosion and Other Deterioration
Question 1: May the provisions of U-107 Inspection for Corrosion and Other
Deterioration of the 1992 Edition, 1994 Addenda of the NBIC be applied
to a vessel of any size?
Reply 1: Yes, provided the owner-user’s inspection program has been approved by
the jurisdiction.
Question 2: When applying U-107(b) in question 1, may any of the readings taken
along the length of the properly oriented line (circumferential or
longitudinal) be less than the required thickness for pressure?
Reply 2: Yes, as long as the average of the readings taken along the line is equal to
or greater than the required thickness for pressure.
Subject: R-503 Re-rating a Boiler or Pressure Vessel
Question: Do the rules of the NBIC permit the re-rating of a complete boiler or
pressure vessel to a higher MAWP by removing existing weld seams, re-
weld seams, performing radiography and recalculating using a higher joint
efficiency?
Reply: No.
Subject: R-301.2.2 Owner-User Acceptance Inspection of Repairs
Question 1: May an Owner-User obtain an “R” Certificate of Authorization?
Reply 1: Yes.
Question 2: May repairs performed by the Owner-User holding an”R” Certificate of
Authorization be inspected by Owner-User Commissioned Inspectors?
Reply 2: Yes.
Question 3: May acceptance inspections of alterations be performed by Owner-User
Commissioned Inspectors?
Reply 3: No. Acceptance inspections for alterations must be performed by an
Inspector employed by an Authorized Inspection Agency (insurance
company or jurisdiction).
Subject: Chapter III, Supplement 3 Welding Methods as an
Alternative to Postweld Heat Treatment
Question: Is it the intent of the 1994 Addendum to the NBIC to prohibit the use of
“controlled preheat” as an alternative method of postweld heat treatment
in the repair of pressure vessels?
Reply: Method 1 as shown in the 1992 Edition was inadvertently omitted from
the 1994 addendum. The omission should be considered an errata.
Subject: Appendix C-R, Guide for Completing Form R-1, Report of
Welded Repair or Alteration
Question: For instruction 13 of the guide for completing Form R-1, is a
manufacturer’s serial number acceptable for “stamped identification?”
Reply: Noting the manufacturer’s serial number is one acceptable method to
address “stamped identification.”
Subject: Appendix C-R, 3.0 Administrative Procedures
Question: May a renewed “R” Certificate of Authorization be issued based upon a
manual review of an “N” type Certificate of Authorization?
Reply: Yes.
Subject: R-401.2.2 Access Openings
Question: May a fillet welded patch plate be installed as a repair?
Reply: No.
Subject: Purpose and Scope of the NBIC
Question: At what point following the completion of a new power boiler, heating
boiler or pressure vessel may the NBIC be used?
Reply: When all requirements of the construction code have been met.
Subject: U-107 Inspection for Corrosion and Other Deterioration
Question: Is U-107(b) applicable to areas that have wall loss resulting from
grinding?
Reply: Yes.
Subject: R-200 Definition of Terms
R-404 Authorization of Organizations Making Repairs
R-505 Authorization of Organizations Making Alterations
Question 1: An inservice ASME stamped pressure vessel manufactured to the ASME
Boiler and Pressure Vessel Code, Section VIII, Division 1, has its shell
diameter turned down below original tolerances. The diameter is then built
back up by fusion welding using weld metal having a chemical
composition and tensile strength similar to that of the base metal, only to
be remachined back to its original tolerances. This is done to provide more
wear resistance and also to extend the useful life of the vessel. Is this
procedure considered a repair?
Reply 1: Yes.
Question 2: Is the procedure specified in Question (1) considered an alteration if the
weld metal has a chemical composition and tensile strength that are not
similar to that of the base metal?
Reply 2: Yes.
Question 3: In order to perform the procedures specified in Questions 1 and 2 above to
ASME Code vessels and maintain their integrity, in accordance with the
NBIC is it required that the organization performing the work hold an “R”
Certificate?
Reply 3: Yes.
Subject: R-307 Replacement Parts
Question: When a material change has been specified by the owner for a replacement
tube bundle, altered to upgrade the performance, which will be installed
into an existing heat exchanger shell by mechanical means (no welding), is
Form R1, Report of Welded Repair or Alteration, required by R-307.1(c)
necessary in addition to the manufacturer’s partial data report supplied by
the parts manufacturer?
Reply: Yes. The organization, in possession of a valid Certificate of
Authorization for the use of the “R” symbol stamp, that installs the part
and affixes the nameplate is responsible for completing the R-1 form.
Subject: Application of the NBIC All Editions
Question: In applying the rules of the NBIC, what edition of the NBIC governs the
inspection of a pressure vessel that was built prior to the latest edition of
the Code?
Reply: The laws/regulations of the jurisdiction in which the object is located
specify which edition of the Code applies to the object. If there is no
jurisdiction, the latest edition is applicable.

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a. the jurisdiction has authorized such adjustments;

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