My boiler is down for repairs so I can just send this steam valve to another VR shop for testing, right?
This is a common question about a common problem. Like any problem, somewhere there lies a solution, but only sometimes it is as simple as one might like.
The solution to this one is not as easy as sending the steam valve to another VR shop for testing. To arrive at the solution, we need to examine a few paragraphs in the National Board Inspection Code (NBIC).
First, let’s review the minimum operations required under the VR program. These operations are found in paragraph 4.2.1(a)(1): Complete disassembly, cleaning, and inspection of parts; repair or replacement of parts found to be defective; reassembly; testing as required by 4.6; sealing; and application of a repair nameplate.
If the VR Certificate Holder does not complete any of those operations, they cannot apply the “VR.” A VR Certificate Holder needs to perform all these operations to apply the VR. Responsibility for certain required operations cannot be divided among different VR Certificate Holders for a VR repair. Under this paragraph, one VR Certificate Holder would not be permitted to perform some of the repair operations, send the valve to another VR Certificate Holder for testing, and then have the valve returned and apply the VR.
One solution is to forgo the work and have another VR shop perform the complete repair under its program. This may not be a favorable option when trying to provide a service to a customer.
However, another solution involves testing on another organization’s test equipment with the proper scope, a thorough Quality Manual that addresses testing at another facility, and good documentation of personnel and qualified test equipment used.
Starting With the Scope
If your boiler is down for repairs and you wish to test at a facility other than your shop, your scope should include the shop and field.
If testing is going to be conducted at another facility, the certificate holder applying the VR stamp may not operate the test equipment itself. Most likely, the test equipment will be operated by the owner of that equipment.
If this is the case, your scope should also include “Use of Personnel Not in the Certificate Holder’s Employ,” and the Quality Manual would need to address the requirements of NBIC Part 4, 4.10. This paragraph includes provisions to bring that personnel into the certificate holder’s program by documenting their qualifications for the work they are performing and requiring that the work they perform be under the direct supervision of the certificate holder.
The next piece of the puzzle is the qualification of test equipment. If utilizing another VR Certificate Holder’s qualified test equipment, you would still need to qualify that piece of test equipment as if it were your own and maintain those qualification records under your program. This documentation may also include any gages or other instrumentation utilized on that piece of test equipment.
While inconvenient, your boiler being down for repairs may only sometimes end all steam VR work. The organization applying the VR can test on another facility’s test equipment by describing this process in your Quality Manual, including that the test equipment is qualified under the quality program of the VR organization applying the VR, utilizing their personnel qualified under their own program or under the provisions of NBIC Part 4, 4.10, and maintaining good records of the personnel and test equipment used.