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2019 Interpretations


INTERPRETATION 19-16

Subject: Alternative Method in lieu of Pressure Testing or Examination (Part 3, 4.4.2 c)).

Edition: 2019

Question: When performing an alteration on a pressure retaining item and use of examination or test methods listed in Part 3, 4.4.2 are not possible, may finite element analysis (FEA) be used in accordance with the original code of construction?

Reply: No, this method is not addressed in Part 3 of the NBIC.

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INTERPRETATION 19-15

Subject: PV Cycles of operations change as an alteration (Part 3, 3.4.4).

Edition: 2019

Question: When the design of a  pressure retaining item (PRI) includes cyclic loading data, should an adjustment, modification or change in analysis of the original design data be considered an alteration?

Reply: Yes.

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INTERPRETATION 19-14

Subject: Alteration of ASME Section VIII Div.2 vessels (Part 3, 3.4.5.1 b)).

Edition: 2019

Question: In Part 3, 3.4.5.1 b) for an ASME Section VIII, Div 2 or Div 3 vessel, may an R-Certificate holder generate a replacement User Design Specification (UDS) in the event the original UDS was lost/destroyed?

Reply: No.

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INTERPRETATION 19-13

Subject: Nondestructive Examination (Part 3, 4.4.1 e)).

Edition: 2019

Question: May exclusive use of VT be performed in accordance with Part 3, 4.4.1 e) when pressure testing or alternative NDE methods other than visual examination, are not practicable?

Reply: No, except as permitted for Routine Repairs.

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INTERPRETATION 19-12

Subject: Weld build of wasted areas with different material (Part 3, 3.3.3 and 3.3.4.3).

Edition: 2019

Question: May the use of a corrosion resistant filler metal of different chemical composition but of equal strength as that of the base metal for a pressure retaining item be considered a repair? 

Reply: No.

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INTERPRETATION 19-11

Subject: Mechanical Installation of Replacement Parts in ASME Section VIII Division 3 Pressure Vessels (Part 3, 3.2.2, 3.3.3, and 5.12.4.1).

Edition: 2019

Question 1: An ASME Section VIII, Division 3 pressure vessel is made without welding from machined forgings.  The pressure retaining components consist of a cylinder, end closures and a frame that holds the end closures in place.  Is replacement of one of the pressure retaining components with a new ASME-stamped “Part” considered a repair?

Reply 1: Yes, see Part 3, 3.3.3.h.

Question 2: For the repair activity described in Question 1, does indication of “Mechanical Repair” in Line 10 Remarks of Form R-1 meet the requirements for identification of Repair Type in Line 7 of Form R-1?

Reply 2: Yes.

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INTERPRETATION 19-10

Subject: Continuity of Qualified Personnel (Part 3, 2.2.6 and S6.9.6).

Edition: 2019

Question: Under what conditions may an organization extend the qualification continuity of qualified
personnel as referenced in NBIC Part 3, paragraphs 2.2.6 and S6.9.6?

Reply: It is the opinion of the Committee that the qualification continuity of qualified personnel who
have experienced a business disruption due to the COVID-19 outbreak may be extended an additional
three months beyond that allowed by NBIC Part 3, paragraphs 2.2.6 and S6.9.6, under the following
conditions:

  1. The qualification was valid at the time of the business disruption, and
  2. The qualification was scheduled to expire during the business disruption.

The latest date the qualified personnel used the process within the extended period will be the new
date for continuity purposes. NBIC, Part 3, paragraphs 2.2.6 b. and S6.9.6 b. shall still apply for the
qualified personnel whose continuity was extended. The provisions of this Interpretation will expire
three months after the approval date**.


This Interpretation number shall be shown in the qualified personnel’s continuity record.

**This interpretation was approved by the NBIC Committee on May 23, 2020.

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INTERPRETATION 19-09

Subject: Acceptance of latest AWS SWPS for use in the 2019 NBIC (Part 3, Table 2.3)

Edition: 2019

Question: Is it the intent of the NBIC to accept the use of the following Standard Welding Procedure Specifications for repairs and/or alterations in accordance with the 2019 NBIC?

B2.1-1-016: 2018

B2.1-1-017: 2018

B2.1-1-019: 2018

B2.1-1-020: 2018

B2.1-1-021: 2018

B2.1-1-022: 2018

B2.1-8-023: 2018

B2.1-2-026: 2018

  B2.1-1-027: 2018

Reply: Yes.

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INTERPRETATION 19-08

Subject: Routine Repairs for ASME B31.3 Normal Fluid Service and Severe Cyclic piping (Part 3, 3.3.2)

Edition: 2019

Question 1: For process piping classified as Normal Fluid Service and under Severe Cyclic conditions in accordance with ASME B31.3 Process Piping, may routine weld repairs be performed in accordance with Part 3 of the NBIC? 

Reply 1: Yes, provided the requirements of Part 3, 3.3.2 are met and routine weld repairs have been accepted by the Inspector, and when required, by the Jurisdiction.

Question 2: Are “Routine Repairs” permitted for ASME B31.3 Category D Service piping?

Reply 2: Yes, provided the requirements of Part 3, 3.3.2 are met and routine weld repairs have been accepted by the Inspector, and when required, by the Jurisdiction. 

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INTERPRETATION 19-07

Subject: Form Registration Log (Part 3, 5.6)

Edition: 2019

Question: Does an “R” or “NR” Certificate Holder exclusively using National Board Electronic Data Transfer system (EDT) for registration of Form “R” Reports meet the Form Registration Log requirements of Part 3, 5.6 of the NBIC?

Reply: Yes, provided the Certificate Holder addresses the method of Form Registration Log documentation, access, and control in their Quality System.

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INTERPRETATION 19-06

Subject: National Certified Pipe Welding Bureau (NCPWB) welding procedure specifications (Part 3, 2.2 and 2.2.1)

Edition: 2019

Question 1: May an “R” certificate holder use a National Certified Pipe Welding Bureau (NCPWB) welding procedure for repairs and alterations of pressure retaining items consisting of pipe where ASME B31.1 is the construction Code?

Reply 1: Yes.

Question 2: May an “R” certificate holder use a National Certified Pipe Welding Bureau (NCPWB) welding procedure for repairs and alterations of pressure retaining items consisting of pipe (as the shell or nozzles) where ASME Section I or Section VIII Div. 1 is the construction Code?

Reply 2: No. 

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INTERPRETATION 19-05

Subject: Clarification of Part 3, 1.5.1 d) 1)

Edition: 2019

Question 1: If an R-Certificate holder makes repairs or alterations to a pressure retaining item installed in a location where there is no Jurisdiction or where the NBIC is not adopted, are the repairs/alterations required to be made in accordance with the NBIC?

Reply 1: No. 

Question 2: If a Form “R” Report  is completed and/or a Nameplate affixed/stamped for a repair or alteration to a pressure retaining item located where there is no Jurisdiction or where the NBIC is not adopted, is the R-Certificate holder  required to make the repairs/alterations in accordance with the NBIC?

Reply 2: Yes. 

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INTERPRETATION 19-04

Subject: Welding Method 6 on Grade 92 steel (Part 3, 2.5.3.6)

Edition: 2019

Question: May Welding Method 6 also be used on CSEF steel which has been manufactured to the requirements in Code Case 2179, and otherwise classified as P No 15E Group 1?

Reply: No. 

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INTERPRETATION 19-03

Subject: ISO/IEC 17025 edition reference in NBIC Part 3, 1.6.6.2 m), 1.6.7.2 m), and 1.6.8.2 m)

Edition: 2019

Question: The listed paragraphs show service to be provided in accordance with ISO/IEC 17025:2005. The 17025 Standard has been revised to the 2017 version, and all labs accredited as such have a 3-year transition window. Is it permissible to use either the 2005 or the 2017 edition of ISO/IEC 17025?

Reply: Yes. 

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INTERPRETATION 19-02

Subject: Wastage/Wasted areas

Edition: 2019

Question: If there are wasted areas on the fireside, does NBIC Part 3, 3.3.4.3-a govern repairs?

Reply: Yes. 

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INTERPRETATION 19-01

Subject: R Certificate Holder manufacturing parts and sub-assemblies

Edition: 2019

Question: May an R stamp Certificate Holder manufacture parts or sub-assemblies for their own use as part of the pressure boundary in their repair/alteration of a pressure retaining item?

Reply: Yes. Reference NBIC Part 3, 3.2.2. 

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