INTERPRETATION 19-26

Subject: Scope of Installation of Liquid Carbon Dioxide Storage Vessels (Part 1, S3.1)

Edition: 2019

Question: Do the requirements of Supplement 3 of NBIC Part 1 apply to a closed loop refrigeration system that utilizes carbon dioxide as a working fluid?

Reply: No.

INTERPRETATION 19-25

Subject: Examples of Repairs and Alterations (Part 3, 3.3.3 and 3.4.4)

Edition: 2019

Question: Are the examples of Repairs and Alterations listed in 3.3.3 and 3.4.4, respectively, intended to represent only some case examples? 

Reply: Yes.

INTERPRETATION 19-24

Subject: Stamping Requirements for Small Parts (Part 3, 5.7.5)

Edition: 2019

Question: Does NBIC Part 3 provide alternative marking requirements to those specified in paragraph 5.7.5?

Reply: No.

INTERPRETATION 19-23

Subject: Mechanical Replacement of Valves, Fittings, Tubes, and/or Pipes (Part 3, 3.3.2 e) 1))

Edition: 2019

Question: Are mechanical replacements of valves, fittings, tubes, or pipes considered routine repairs?

Reply: No.

INTERPRETATION 19-22

Subject: Repair of a Stiffening Ring (Part 3, 3.3.2 e))

Edition: 2019

Question: May the repair of a pressure vessel stiffening ring be considered a Routine Repair per Part 3, Sec. 3.3.2?

Reply: No.

INTERPRETATION 19-21

Subject: Accreditation Process/Certification of Scope (Part 3, 1.4.1)

Edition: 2019

Question: Is it required for an “R” Certificate of Authorization holder to also hold a Certificate of Authorization for the pressure retaining item’s original Code of Construction (e.g. ASME Section VIII Div. 1) for which a repair or alteration is to be completed?

Reply: No.

INTERPRETATION 19-20

Subject: Liquid Pressure Test Examination Methods Applicable to Alterations (Part 3, 4.4.1 & 4.4.2)

Edition: 2019

Question 1: When conducting a liquid pressure test of an alteration activity as described in 4.4.2(a)(1), shall the minimum required test pressure be as specified in the original code of construction?

Reply 1: Yes.

Question 2: When conducting a liquid pressure test of an alteration activity as described in 4.4.2(a)(1), may the minimum required test pressure be as adjusted based on the remaining corrosion allowance when the original test pressure included consideration of corrosion allowance?

Reply 2: Yes.

INTERPRETATION 19-19

Subject: Authorization of Repair/Alteration Activities (Part 3, 1.3.2)

Edition: 2019

Question 1: May Inspectors employed by two different AIA’s certify the Certificate of Design Change Review and Certificate of Inspection portions of the Form R-2?

Reply 1: Yes.

Question 2: Must the Inspector signing the Certificate of Inspection on the Form R-2 be the same Inspector, or employed by the same AIA as the Inspector, who authorized the construction work for the alteration?

Reply 2: Yes.

INTERPRETATION 19-18

Subject: Addition of Non-Load Bearing Attachments (Part 3, 3.3.2 e))

Edition: 2019

Question: May non-load bearing attachments welded directly to an ASME Section VIII, Div. 1 pressure vessel that has full postweld heat treatment reported on the ASME Manufacturer’s Data Report be considered a routine repair without subsequent postweld heat treatment or post weld heat treatment alternatives?

Reply: Yes, provided the attachment welds are exempted from post weld heat treatment by the original construction Code and any service related conditions.

INTERPRETATION 19-17

Subject: Scope of Repairs (Part 3, 3.3.3)

Edition: 2019

Question: May multiple repair activities referenced in 3.3.3 of NBIC Part 3 be listed on a single Form R-1 Report when performing a repair on a pressure retaining item?

Reply: Yes.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

INTERPRETATION 17-22

Subject: Repair of Section VIII Div. 2 and Div. 3 Pressure Vessels (Part 3, 3.3.2 and 3.3.5)

Edition: 2017

Question 1: Is a repair plan required for all repairs of ASME Section VIII Div. 2 or Div. 3 pressure vessels?

Reply 1: Yes. See Part 3, 3.3.5.2.

Question 2: May the repair plan for an ASME Section VIII Div. 2 or Div. 3 pressure vessel be accepted by the Inspector in lieu of the Authorized Inspection Agency or the Owner-User Inspection Organization?

Reply 2: No. See Part 3, 3.3.5.2 b).

Question 3: Must the Authorized Inspection Agency's or Owner-User Inspection Organization's Inspector make an acceptance inspection of the repair of an ASME Section VIII Div. 2 or Div. 3 pressure vessel?

Reply 3: Yes. See Part 3, 3.3.5.2 b).

Question 4: Are routine repairs defined in Part 3, Section 3, 3.3.2, applicable to pressure vessels constructed to ASME Section VIII Div. 2 or Div. 3?

Reply 4: No. Inspection of the repair by the Inspector is required.

INTERPRETATION 17-21

Subject: Determining the Pressure Used for Hydrostatic Test (Part 3, 3.2.2 e))

Edition: 2017

Question: NBIC Part 3, paragraph 3.2.2 e) states that the replacement part shall receive a pressure test as required by the original code of construction. Is it the intent of 3.2.2 e) that the reference to the original code of construction is for determining the pressure used for the hydrostatic test?

Reply: Yes.

INTERPRETATION 17-20

Subject: NDE methods in lieu of a hydrostatic test (Part 3, 4.4.2 c))

Edition: 2017

Question 1: An alteration to a Section VIII Div. 2 or Div. 3 vessel is performed by lowering the MAWP and increasing the design temperature. No physical work was performed on the vessel. Calculations confirm that the hydrostatic test pressure for the new MAWP and design temperature would be higher than that of the original hydrostatic test pressure. Is a new hydrostatic test required after the alteration is completed?

Reply 1: Yes, except as provided in Part 3, 4.4.2.c.

Question 2: The NBIC Part 3, 4.4.2.c provides rules for performing NDE in lieu of a hydrostatic test of an alteration. Is it required that concurrence of the owner, the Inspector, the Certifying Engineer if applicable, and when required, the Jurisdiction be obtained regarding the NDE methods, or combination of methods, to be used to verify the integrity of the alteration?

Reply 2: Yes, in accordance with Part 3, 3.4.5.

INTERPRETATION 17-19

Subject: Interpretations issued to earlier NBIC editions (All Parts, 8.1 b))

Edition: 2017

Question: May an interpretation issued to an earlier NBIC Edition be used for any other NBIC Edition when the requirements of the NBIC are the same?

Reply: Yes.

INTERPRETATION 17-18

Subject: NBIC Part 3, 3.2.6

Edition: 2017

Question 1: May a bolt hole in a SA350-LF2 flange be considered a repair using SA-105 material that is welded using a Welding Procedure Specification (WPS) that was qualified without postweld heat treatment (PWHT) and without impact testing?

Reply 1: No. This cannot be completed as a Repair.

Question 2: Does the Inspector have final authority for review and acceptance of a repair by a repair organization that has an “R” Certificate of Authorization under Part 3, 3.2.6 when a Jurisdiction does not exist?

Reply 2: Yes.

INTERPRETATION 17-17

Subject: Repair and alteration of Section VIII Division 2 items

Edition: 2017

Question: Is it permissible to perform a repair or alteration on an ASME Section VIII, Division 2 pressure vessel in accordance with the NBIC when the original User’s Design Specification (UDS) and/or the Manufacturer’s Design Report (MDR) is not available?

Reply: No. The Repair/Alteration Plan is required to be compatible with the UDS and MDR per the NBIC Part 3, Sections 3.3.5 and 3.4.5.

INTERPRETATION 17-16

Subject: Certifying engineer of UDS for re-rating of pressure vessel

Edition: 2017

Question 1: Provided that a single Edition/Addenda of ASME Section VIII, Division 2 is selected for the repair/alteration activity, may the 2007 or later Edition/Addenda of ASME Section VIII, Division 2 be used for rerating a vessel constructed to the 2004 or earlier Edition/Addenda of ASME Section VIII, Division 2?

Reply 1: Yes, per NBIC Part 3, 1.2 a).

Question 2: With regard to Question 1, may a registered engineer authorized outside the United States or Canada be recognized as an engineer in paragraph 2-A.2.2. (b) of the current ASME Section VIII Division 2?

Reply 2: This is outside the scope of the NBIC.

INTERPRETATION 17-15

Subject: Alternative Welding Methods

Edition: 2017

Question 1: Does NBIC Part 3, 2.5.3.2, 2.5.3.3, and 2.5.3.4 prohibit the use of Nickel-Chrome alloy (FNo.43) filler metal?

Reply 1: No.

Question 2: Does NBIC Part 3, 2.5.3.2(i), 2.5.3.3(g)(2), and 2.5.3.4(g)(2) prohibit “austenitic” filler metals that meet A-No.8 or A-No.9 requirements?

Reply 2: No.

INTERPRETATION 17-14

Subject: Plugging a Valve Casing Drain

Edition: 2017

Question: Is it acceptable to plug the Valve Casing Drain and provide the required drainage by another drain connection installed at the bottom of the inlet end of the discharge elbow, as long as it is below the level of the valve seat?

Reply: No.

INTERPRETATION 17-13

Subject: Alternative NDE methods acceptable to the Inspector and the Jurisdiction

Edition: 2017

Question: With respect to the RT requirement in 2.5.3 e); is it the intent of the reference to alternative methods acceptable to the original code of construction in paragraph 4.2 a) that UT examination may be used in place of RT examination when the original code of construction allows such examination?

Reply: Yes. These provisions have already been approved and clarified in the upcoming release of the NBIC 2019 Edition.

INTERPRETATION 17-12

Subject: Reducing a pressure vessel shell overall length

Edition: 2017

Question: Is changing a pressure vessel shell overall length considered an Alteration?

Reply: Yes

INTERPRETATION 17-11

Subject: NBIC Part 3, 2.5.3.6 e) Changing of Welding Consumables

Edition: 2017

Question: For Welding Method 6 in 2.5.3.6 (e), Part 3 of the NBIC 2017 Edition, may welding consumables E9015-B9, E9018-B9 and ER90S-B9 also be used for weld repair of Grade 91 material?

Reply: No

INTERPRETATION 17-10

Subject: ASME Section VIII, Division 2, Class 1 Vessels.

Edition: 2017

Question 1: May a vessel built to an ASME Section VIII Division 2 construction Code between 2007 and 2017 be altered to the 2017 ASME Section VIII Division 2 Code for Class 1 vessels?

Reply 1: No

Question 2: May a vessel built to an ASME Section VIII Division 2 construction Code, prior to 2007, that required a PE for design, be altered to the 2017 ASME Section VIII Division 2 Code for Class 1 vessels, provided the User’s Design Specification (UDS) and Manufacturer’s Design Report (MDR) are available and the ASME Section VIII, Division 2 vessel that was built prior to 2007 has no fatigue analysis or design-by-analysis to determine materials thicknesses?

Reply 2: Yes

INTERPRETATION 17-09

Subject: Post-Weld Heat Treatment for new full penetration groove pipe nozzle neck repair.

Edition: 2017

Question: In the original construction of a Section I Boiler, a full penetration groove weld, exempt from PostWeld Heat Treatment (PWHT) by the original Code of construction, was subjected to PWHT meeting the requirements of ASME BPV Section I, PW-39. May the repair of this weld be performed in accordance with the NBIC, Part 3 without PWHT or acceptable alternative to PWHT?

Reply: Yes, as long as the WPS is qualified without PWHT. Note: For Pressure Vessels, see Interpretation 95-14.

INTERPRETATION 17-08

Subject: Repair/Alteration Plans for ASME VIII, Division 2, Class 1 Pressure Vessels

Edition: 2017

Question: Does the NBIC require a Repair/Alteration Plan for an ASME Section VIII, Division 2, Class 1 vessel to be certified by an engineer when a Manufacturer's Design Report was not required to be certified under the original code of construction?

Reply: No.

INTERPRETATION 17-07

Subject: Omission of PWHT by an "R" Certificate holder

Edition: 2017

Question 1: A Section VIII, Div. 1 vessel was originally PWHT for service related reasons only and stamped per the original code of construction. An "R" Certificate Holder omits PWHT. Is the omission of PWHT of the vessel without the use of alternative weld methods in Part 3, 2.5.3 considered an alteration?

Reply: Yes.

Question 2: A Section VIII, Div. 1 vessel was originally PWHT for service related reasons only and stamped per the original code of construction. An "R" Certificate Holder omits PWHT. Is the omission of PWHT of the vessel with the use of alternative weld methods in Part 3, 2.5.3 considered a repair?

Reply: Yes.

INTERPRETATION 17-06

Subject: Part 3, Section 2.5.3.6, Welding Method 6

Edition: 2017

Question: When it is impracticable to perform post-weld heat treatment, may a tube-to-header attachment weld be made using Welding Method 6 in accordance with Part 3, Section 2, 2.5.3.6?

Reply: No. As explained in Part 3, Section 2, 2.5.3.6, use of Welding Method 6 is limited, among other things, to butt welds in tubing. The method has not been approved for use on tube-to-head welds.

INTERPRETATION 17-05

Subject: Repairs to a Pressure Retaining Part

Edition: 2017

Question: Is it permitted to perform a repair in accordance with the NBIC of a part that has not yet been installed in a pressure vessel or boiler that has not been completed in accordance with the code of construction?

Reply: No. The NBIC rules for repairs dor not apply to items not yet completed in accordance with the code of construction.

INTERPRETATION 17-04

Subject: Establishing maximum allowable operating conditions using API-510

Edition: 2017

Question: Does NBIC recognize API-510's procedure "Evaluation of Existing Equipment with Minimal Documentation" (Paragraph 7.7) for establishing maximum allowable operating conditions for equipment without nameplates, records, or stamping?

Reply: No.

INTERPRETATION 17-03

Subject: Adding Handhole Ring on Pressure Side of Pressure Retaining Item

Edition: 2017

Question: If acceptable to the jurisdiction and considered appropriate by the inspector, may adding a handhole ring as described in Part 3, Section 3, Figure 3.3.4.3-b and meeting the requirements of Part 3, Section 3, 3.3.2(e)(5) be considered a routine repair?

Reply: No.

INTERPRETATION 17-02

Subject: Continuity Records Retention

Edition: 2017

Question: In Table 1.5.1c), does the phrase “the continuity records are subject to review during each National Board triennial certificate review” mean that the continuity records developed since the last review are to be retained and made available for review during the next review?

Reply: Yes.

INTERPRETATION 17-01

Subject: Application of Term "Practicable

Edition: 2017

Question: May the desire to save time and/or expense be used solely in determining if a repair and/or alteration activity is practicable?

Reply: No. The determination of “practicable” shall be based on technical consideration of the nature and scope of repair and/or alteration activities.

INTERPRETATION 15-15

Subject: Installation Pressure Test

Edition: 2015

Question: If a pressure test has been performed and documented on the applicable Manufacturer’s Data Report for a boiler, pressure vessel or piping and the Jurisdiction does not require additional pressure tests, is an additional pressure test required prior to initial operation?

Reply: No.

INTERPRETATION 15-14

NOTE: This is actually an interpretation of the 2017 edition of the NBIC, not the 2015 edition. The information for this interpretation can now be found under Interpretation 17-02.

INTERPRETATION 15-13

Subject: Routine Repair Stamping Requirements

Edition: 2015

Question 1: Are nameplates and stamping required for routine repairs?

Reply 1: No, subject to acceptance of Jurisdiction and the concurrence of the inspector.

Question 2: Are nameplates or stamping required for repairs other than of a routine nature?

Reply 2: Yes.

INTERPRETATION 15-12

Subject: Surface Repair of Corrugating Rolls

Edition: 2015

Question: Is an “R” stamp required to be applied to a corrugating roll after a surface repair by welding, such as restoration of broken flutes, steam cut trunnion flanges, or a worn surface of a trunnion journal?

Reply: Yes, unless the repair meets the conditions for a routine repair in Part 3, paragraph 3.3.2.

INTERPRETATION 15-11

NOTE: This is actually an interpretation of the 2013 edition of the NBIC, not the 2015 edition. The information for this interpretation can now be found under Interpretation 13-11.

INTERPRETATION 15-10

NOTE: This is actually an interpretation of the 2017 edition of the NBIC, not the 2015 edition. The information for this interpretation can now be found under Interpretation 17-01.

INTERPRETATION 15-09

NOTE: This is actually an interpretation of the 2013 edition of the NBIC, not the 2015 edition. The information for this interpretation can now be found under Interpretation 13-10.

INTERPRETATION 15-08

Subject: Alteration to One Side of Shell/Tube Heat Exchanger

Edition: 2015

Question: If an alteration is performed only on one pressure chamber (e.g. shell side or tube side) of a heat exchanger, is it permitted to only stamp the MAWP for the altered side on the alteration nameplate?

Reply: No, the MAWP of both chambers shall be listed on the nameplate.

Rationale: NBIC Part 3, Sections 5.7.3, 5.7.5, Fig. 5.7.5-b; The alteration nameplate represents the current stamped ratings of the altered vessel. Having to decipher the current stamped ratings of the altered vessel from the alteration nameplate(s) and the original manufactured nameplate leads to confusion.

INTERPRETATION 15-07

Subject: Local Stress from Bracket Loading

Edition: 2015

Question: Is an increase in external loading on a bracket that increases local stress in a pressure retaining item (PRI) which does not require redesign of the PRI or bracket attachment considered an alteration?

Reply: No

INTERPRETATION 15-06

Subject: Change in Boiler Heat Input from HRSG

Edition: 2015

Question: When the total heat input into a boiler (for example a Heat Recovery Steam Generator (HRSG)) is changed (e.g. increased firing rate, adjustment, or modification to the primary or an auxiliary heat source), resulting in the steaming capacity exceeding the original Manufacturer’s Minimum Required Relieving Capacity (MRRC), does this departure from the original Manufacturer’s design represent an alteration?

Reply: Yes

INTERPRETATION 15-05

Subject: Verification of Installation of Repair Nameplate

Edition: 2015

Question: Is owner's method of verification of the installation of the Repair Nameplate acceptable per NBIC Part 3, 1.3.2 c) considering it as repair not routine repair as PWHT is involved in the repair?

Reply: Yes (with the authorization and knowledge of the Inspector)

INTERPRETATION 15-04

Subject: Explosive Weld Plugs Tube Repair

Edition: 2015

Question: Is explosion welding of plugs into leaking heat exchanger tubes considered a repair per the NBIC Part 3?

Reply: Yes.

INTERPRETATION 15-03

Subject: Fillet Welded Patches

Edition: 2015

Question: Are fillet welded patches permitted by the NBIC for repairs or alterations to pressure retaining items?

Reply: Fillet welded patches are not addressed by the NBIC.

INTERPRETATION 15-02

Subject: Valve Repair Nameplate Field Labels

Edition: 2015

Question: When a pressure relief valve is repaired, are field labels for type/model number, capacity, CDTP, and/or BP required on the repair nameplate if the values are not changed from the original manufacturer’s nameplate or stamping?

Reply: No.

INTERPRETATION 15-01

Subject: Boiler Clearance Less than Recommended

Edition: 2015

Question: Is it permissible to install boilers less than the minimum 36” clearance if recommended by the manufacturer and approved by the Jurisdiction?

Reply: Yes, in accordance with Part 1, Section 3.3.4 a).

INTERPRETATION 13-11

NOTE: This Interpretation was previously assigned as 15-10.

Subject: Repair/Replacement of Bolting Material

Edition: 2013

Question 1: Is a mechanical repair consisting of the replacement of bolting material, with like material (see Part 3, paragraph 3.3.3 s), as listed on the Manufacturer’s Data Report considered a repair that needs to be documented on an R-1 form?

Reply 1: No.

Question 2: Is the replacement of bolting material with a different allowable stress, nominal composition (see Part 3, paragraph 3.4.3 g) or configuration other than that listed on the Manufacturer’s Data Report considered an alteration?

Reply 2: Yes.

INTERPRETATION 13-10

NOTE: This Interpretation was previously assigned as 15-09.

Subject: Use of Backing Strips to Install Flush Patches

Edition: 2013

Question 1: May installation of a flush patch in a pressure retaining part be classified as a “Repair” if any of its attachment welds are made using a backing strip along with the welds receiving the same degree of volumetric examinations as original construction when the original vessel design and construction of the pressure retaining part did not use backing strips in its design and construction?

Reply 1: No. If backing strips were not considered and used in the original design and construction, and are used on the flush patch installation, the work must be classified as an Alteration.

Question 2: May installation of a flush patch in a pressure retaining part be classified as a “Repair” if any of its attachment welds are made using a backing strip along with the welds receiving a lesser or higher degree of volumetric examination such that the applicable flush patch butt weld design joint efficiency is lower or higher than original construction when the original vessel design and construction of the pressure retaining part did not use backing strips in its design and construction?

Answer 2: No. If backing strips were not considered and used in the original design and construction, and are used on the flush patch installation, and if the applicable joint efficiency of the weld made using a backing strip is lower or higher than that of the joint efficiency used on the original design, there would be a change in the joint efficiency applicable to design of the part which would mandate that the work be classified as an Alteration.

Question 3: If a flush patch plate in a pressure retaining item (PRI) is installed with attachment welds using backing strips and the attachment welds receive the same or higher degree of volumetric examination required by the original code of construction with no reduction in joint efficiency as original construction is this considered a repair?

Answer 3: Yes

INTERPRETATION 13-09

Subject: Penetrant Examination in Lieu of Hydrostatic Test

Edition: 2013

Question: When the Inspector and, when required, the Jurisdiction agree that penetrant examination will provide meaningful results to verify the integrity of a weld repair, may penetrant examination of the repair be performed in lieu of a hydrostatic test?

Reply: Yes.

INTERPRETATION 13-08

Subject: Quality Control System Responsibilities

Edition: 2013

Question 1: In an “R” Certificate Holder’s Quality Control system, is it permissible for one individual to have dual responsibilities for management functions, such as Quality control functions and non-quality control functions, such as production?

Reply 1: Yes, provided there is no conflict in enforcement of the quality control system and the functional responsibilities and duties are clearly described in the quality control manual.

Question 2: Is approval of revisions to the Quality Control Manual permitted to be made by someone other than the individual designated in the manual as responsible for approval of the revisions?

Reply 2: No.

INTERPRETATION 13-07

Subject: Weld Buildup of Wasted Areas

Edition: 2013

Question: When performing weld metal buildup of wasted areas of pressure retaining items, is the wall thickness required to be restored to the thickness listed on the Manufacturers Data Report?

Reply: No. The minimum thickness after build-up shall be the original thickness of the pressure retaining item minus the corrosion allowance.

INTERPRETATION 13-06

Subject: Postweld Heat Treatment Requirements

Edition: 2013

Question 1: An R-Certificate holder decides to perform post weld heat treatment (PWHT) of a vessel at the request of a client, where no PWHT was performed in the original construction. Is the performance of PWHT of the vessel considered an alteration and subject to documentation using a Form R2?

Reply: Yes.

Question 2: For the vessel described above, must the weld procedures used for construction of the vessel be qualified with PWHT?

Reply: Yes.

Question 3: Must the PWHT described above be performed by the R-Certificate holder?

Reply: No, the PWHT may be subcontracted; however the R-Certificate holder retains the responsibility for the performance of the PWHT.

INTERPRETATION 13-05

Subject: Operating Limit Control Location on Hot Water Supply Boilers

Edition: 2013

Question: Is it permissible to place the operating temparture control on a storage tank located in a hot water supply system?

Reply: Yes.

INTERPRETATION 13-04

Subject: Seal Welding of Inspection Opening Covers

Edition: 2013

Question: Is seal welding of inspection opening covers, such as handhole plates or plugs, considered a routine repair?

Reply: No.

INTERPRETATION 13-03

Subject: Standard Threaded Fitting Welded through ASME VIII, Div. 1 Vessel

Edition: 2011

Question: Is a standard threaded fitting welded through an ASME Section VIII, Div-1 vessel considered a nozzle?

Reply: Yes.

INTERPRETATION 13-02

Subject: Stamping Requirements for Alterations

Edition: 2011

Question: When temperature limits are not required to be placed on the original manufacturer’s nameplate in accordance with the original code of construction, may the temperature field for Figures 5. 7. 5 b) and 5.7.5 c) be indicated as N/A?

Reply: Yes

INTERPRETATION 13-01

Subject: Personnel Qualified IAW ANSI/ASME N45.2.23

Edition: 2013

Question: If audit personnel are qualified in accordance with the requirements of ANSI/ASME N45.2.23, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants, may they perform the audits specified in 1.8.5.1 q)?

Reply: No, the NBIC requires audit personnel to be qualified in accordance with NQA-1.

INTERPRETATION 11-06

Subject: Calculations / Start of Work

Edition: 2011

Question 1: Does the NBIC have rules that prevent physical work proceeding on a risk basis prior to the calculations being submitted and reviewed by the Inspector?

Reply 1: Yes

Question 2: Does the requirement in S3.2.5 that calculations be completed prior to the start of any physical work, apply to fabrication of replacement parts as defined in §3.2.2 that will be used in the alteration?

Reply 2: No

Question 3: Does the NBIC prohibit the "R" Certificate Holder that certifies the design portion of Form R-2 from subcontracting the design calculations provided the "R" Certificate Holder’s quality control system covers subcontracting of design calculations?

Reply 3: No

Question 4: If an alteration involves the installation of a replacement part (as defined in Paragraph 3.2.2 c) that has been designed, fabricated, inspected and stamped in accordance with the original code of construction and for which the part fabricator has documented on the partial data report that they have certified the design of the part for a specific set of design conditions (MAWP,MAWT, MDMT, corrosion allowance, etc.), must the "R" Certificate Holder responsible for executing the Design Certification on the R-2 Form obtain the calculations from the part fabricator and make available for review by the Inspector?

Reply 4: No; however, the "R" Certificate Holder responsible for executing the "Design Certification" portion of the R-2 Form must assure himself that the design complies with the NBIC and by signing; the Design Certification accepts responsibility for the design.

INTERPRETATION 11-05

Subject: Replacement of Stamped Data on Corrugator Rolls

Edition: 2011

Question: If a National Board Commissioned Inspector has verified the replacement of stamped data or nameplate by an “R” Certificate Holder on Corrugated rolls that are not stationary and subject to operation in multiple Jurisdictions, possibly by multiple owners, is the application of NB-136 “Replacement of Stamped Data Form” required for each of the multiple Jurisdictions?

Reply: No. If the vessel is not stationary, application should need only be made in the Jurisdiction where the nameplate is re-applied.

INTERPRETATION 11-04

Subject: Application of "VR" Stamp

Edition: 2011

Question: May the "VR" stamp be applied to pressure relief valves bearing the ASME Certification mark with the "V," "HV," "UV," or "NV" designator?

Reply: Yes

INTERPRETATION 11-03

Subject: Test Frequencies

Edition: 2011

Question 1: The table of suggested inspection and test frequencies in 2.5.8 f) does not include a column for “test frequency. Does the column heading "Inspection Frequency" include Inspection and Testing?

Reply 1: Yes

Question 2: May the guidelines for establishing inspection and test frequencies in 2.5.8 g) be used for establishing the frequencies of inspection and test for fluids in the table in 2.5.8 f)?

Reply 2: Yes.

Question 3: Once an acceptable pressure relief device service interval has been established per 2.5.8 h), is it acceptable to replace the pressure relief devices with a new device at the established service interval in lieu of servicing?

Reply 3: Yes

INTERPRETATION 11-02

Subject: Liquid Pressure Test Requirements

Edition: 2011

Question 1: In Part 3, 4.4.2 a) is a liquid pressure test not exceeding 150% of MAWP stamped on the pressure retaining item required for an alteration?

Reply 1: No. In accordance with Part 3, 4.4.2 a) 2), liquid pressure testing of connecting welds not exceeding 150% of MAWP may be tested or examined in accordance with rules for repairs.

Question 2: In Part 3, 4.4.2. a) 2) may a liquid pressure test of connecting welds for a pressure retaining item be performed below 150% of the MAWP for an alteration?

Reply 2: Yes, with acceptance of the Inspector and when required the Jurisdiction. See NBIC Part 3, 4.4.

INTERPRETATION 11-01

Subject: Routine Repair Considerations

Edition: 2011

Question: In Part 3, 3.3.2 d), is the replacement scope or the number of valves, fittings, tubes, or pipe NPS 5 in diameter and smaller, or sections thereof, a consideration when determining if the work is a routine repair?

Reply: No. The NBIC does not address the magnitude of work or scope in qualifying repairs as routine but rather addresses the exceptions representing routine repairs as noted within Part 3, 3.3.2 d) 1).