Common Treatment of Repairs

This article by late staff member Chuck Walters was originally published in the fall 2004 National Board BULLETIN. Some code requirements may have changed because of advances in material technology and/or actual experience. The reader is cautioned to refer to the latest edition and addenda of the National Board Inspection Code for current requirements.

An individual’s role in the repair of pressure equipment can often influence how he or she views the National Board Inspection Code rules covering the repair. That is why it is important that interpretations of NBIC rules come from the NBIC Committee, not through personal perspective.

A common scenario involves an inspector (that is, a National Board commissioned inspector) who discovers through an inservice inspection that a pressure-retaining item needs to be repaired. The inspector informs the owner that a repair is necessary. The owner contracts with an “R” stamp holder repair organization to make the repair. After the repair is completed, the “R” stamp holder attempts to have the Authorized Inspection Agency (AIA) of record’s inspector sign Form R-1. Since this AIA’s inspector did not originally authorize the repair and has no knowledge of what was proposed or approved, he refuses to sign the form. The repair organization becomes frustrated with the program and in the future may comply with NBIC rules only if its AIA of record’s inspector is involved.

The NBIC repair program, developed many years ago, intended for the inspector to be informed prior to work being started. Many pressure equipment owners do not know the inspector must be advised of and be in agreement that the proposed repair meets the applicable code and/or jurisdictional rules. To reduce frustrations encountered by all parties, the first step is for the repair organization to determine which inspector will authorize and accept the repair (i.e., sign Form R-1).

Next, an agreement must be established with the appropriate inspector regarding the method, extent, and final testing of the repair. This agreement is the repair organization’s prior autho¬rization to perform the repair. The authorization may be the inspector’s review and concurrence with details for repairs, or a verbal acceptance via the telephone. The complexity of repair will be determined by its nature and by the amount of detail specified by the repair organization’s quality control system manual in satisfying code of construction requirements.

Repair of a pressure-retaining item may require:

• detailed repair procedures accepted by the repair organization’s AIA of record;
• applicable drawings or sketches;
• a list of material requirements (e.g., plate, formed heads, pipe, fittings); and
• applicable NDE and heat treatment requirements, welding procedures, and welders’ qualifications.

The authorization and acceptance requirements in the NBIC allow one inspector to authorize the repair and another inspector to accept the repair, as long as they both are employed by the same AIA. Under no circumstances can an inspector employed by one AIA authorize a repair and an inspector employed by a different AIA accept the repair.

The acceptance process has to be performed for every repair. All inspectors performing repair inspections, including routine repairs, must develop and maintain a diary to record activities related to the repair, including documentation of the repair authorization and acceptance. The diary must be bound (not loose-leaf), or alternatively the inspector may use an electronic diary controlled by the AIA or owner/user inspection agency. This is a specific requirement of NB-263, Rules for Commissioned Inspectors.

What are routine repairs and how do they differ from other repairs? Routine repairs are defined by the NBIC; NBIC paragraph RC-2031 describes the limitations permitted to fall under the term “Routine Repairs,” however the necessity of having inspector authorization and acceptance of the proposal is evident because the extent of each repair may be greater than the limits allow. For example, the NBIC permits replacing a tube of 2 inches to fall within the routine repair criteria, but if an entire bank of 2-inch tubes is being replaced, the inspector will consider this to be outside the definition of a routine repair and may want to overview the work.

In order to conduct routine repairs, the repair organization’s specific routine repair program must be accepted by the jurisdiction where the pressure-retaining item is located. If the jurisdiction does not accept the program, the repair organization and inspector must comply fully with the requirements in Part RC, including requirements for the inspector’s involvement during repair activities, nameplate requirements, and signing of Form R-1.

When working to the routine repair program, the repair organization must also:

• obtain acceptance by its AIA – that is, the jurisdictional authority, AIA, or owner/user – prior to implementing the program that will be used to control the routine repair;
• establish in its quality control system the scope or type of repairs that will be performed; 
  obtain prior authorization for each specific repair by the applicable inspector;
• complete Form R-1, with the note under Item 10 remarks “Routine Repairs”;
• have the inspector sign the form; and
• omit the requirements for a repair nameplate, if permitted by the jurisdiction.

Even with detailed requirements for this program provided in the repair organization’s quality control system, there are still issues with implementation of routine repair requirements. There are a number of reasons why compliance is not being obtained, but the most prevalent is coordination between the repair organization and the inspector. The method and extent of repair and final testing requirements must be submitted to the inspector to obtain prior authorization to proceed with the repair.

A common misconception is that prior authorization for routine repairs is not required because there is an accepted routine repair program, and consequently the information does not need to be submitted to the inspector. When the inspector is representing the repair organization’s AIA of record, compliance is achievable because the AIA of record has reviewed and accepted the repair organization’s quality control system. It is when the repair organization uses an inspector other than the AIA of record’s that the requirement for having prior authorization is often overlooked.

Implementation of an effective repair program, including routine repairs, must be managed by the repair organization, which must coordinate activities with the inspector, the AIA, and the owner of the equipment.