Calling all mechanical and chemical engineers!!!!!!

Is ASME Sec VIII Div 1 standard a Federal Standard? I say no!

Do all states adopt it for Pressure Vessel Construction? I thought there were a few states that do not necessarily mandate they be followed??

So here is my situation I am in need of fabricating 2 very simple bag filters here on site in the middle of nowhere(Vietnam). I can order some but will take too long to get but I am capable fabricating a set of emergency bag filters here in Vietnam buy cloning what I already use. The feeder pumps are able to pressurize the bag filter line up to 50 psi but doubt we would even see 15 psi of pressure.

So the safety guy squawks up and squeals that if it is over 15 psi it needs to be a ASME coded vessel. I say it didn't but I can have it fabricated to meet ASME standards but not require a stamps.

So the dance began. Safety guy tells a story of a friend getting his leg cut off because a bad design. I say waaaaa friend should've moved faster.

I am building two emergency bag bag filters out of seamless 8" sch'd 304SS pipe, with 2:1 eliptical head with a four eye bolt prefabbed quick opening manway. Hell if it was 6" pipe the bag filter would not qualify As a pressure vessel. I want to use 8" because I have the material because it is free. I own it.

So we argue the old age argument that built to ASME standards does not mean it ALLWAYS REQUIRES AN ASME STAMP AND YOU DONT HAVE TO HAVE A U STAMP SHOP TO BUILD SUCH VESSELS.

Any of you have guys have any other thoughts so I can beat that chuckle **** over the head tomorrow? Built to ASME standard, with calcs, with hydro text and Mtrs but I can't do it with a onsite welder. Wtf???

I can build these two filters and properly hydro test it to what is dictated by code but I am not required to have a U Stamp. Hell none of the vessels out there have a U Stamp. Chuckle duck says we just because we did it wrong to begin with doesn't mean we should repeat it.

I ought to downsize to 6" and say fu2.
But I want to beat him up over this so I am not backing off.

Are there any other standards that filter construction fall under? I know in ASME Code there is an exception for strainers. A bag filter is technically not a strainer right?
Because there is an exception to that as well.

All help is welcome. If I win I will supply free Huda beer for all the masses.

Vessel code is not my bag, but unless you can't physically keep it down to around 15 psi by PRV or such device, I would count on something bad happening and it building up to full pressure due to clog, malfunctioning controls, etc.

If you're talking about following the spirit of the code if not the letter, and can proof test your finished result, I don't see why that isn't acceptable outside the US.

My somewhat ignorant question is what do you do with SS pipe/welds not having a safe stress from cycle fatigue, and will there be acids or anything corrosive that could lead to stress corrosion cracking in the stainless?

An ASME stamp doesn't magically make a part inherently better than one without. IF you can have the part manufactured and tested to ASME specs, there's no reason you shouldn't be able to use it, especially temporarily, unless required by local law.

From a procedure standpoint, ask the HSE rep to show documentation that ASME stamped equipment must be used. If there's no documented requirement, he has no grounds to stand on. However, if he has documentation that states his case, he wins the argument. This doesn't necessarily have to be a drawing or spec sheet, but could be in a generic HSE procedure.

Bottom line, make him provide a documented requirement for the ASME stamp. If he can't and continues to stop work, go over his head.

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An ASME stamp doesn't magically make a part inherently better than one without. IF you can have the part manufactured and tested to ASME specs, there's no reason you shouldn't be able to use it, especially temporarily, unless required by local law.

From a procedure standpoint, ask the HSE rep to show documentation that ASME stamped equipment must be used. If there's no documented requirement, he has no grounds to stand on. However, if he has documentation that states his case, he wins the argument. This doesn't necessarily have to be a drawing or spec sheet, but could be in a generic HSE procedure.

Bottom line, make him provide a documented requirement for the ASME stamp. If he can't and continues to stop work, go over his head.

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Pretty much this.

With that said, doing things a certain way just to save money or circumvent the code (not saying this is what you are doing) typically isn't a good idea. If you are able to follow the code exactly (CHERRY-PICKING IS BAD MMKAY) and can perform a 1.5x hydrotest, you really shouldn't have a problem. It is important to keep fatigue in mind as well. If you can build a safety enclosure around the item as well, that would be even better.

To answer your earlier questions: no the BPVC is not a national requirement. It is up to each state to determine if they are a BPVC state or not.

You are correct in seeking out what codes are applicable here, but BPVC has been adopted by all fifty states and multiple countries. Per NRC adoption in the mid '90's, it is more or less a federal code in the United States.

Now, in Vietnam, I don't know.

Thank you for responding.

I looked on OSHA.gov and it states for implementation of vessel ASME standards under 3.1.4 ASME has no legal standing. But then it has two big paragraphs to why it is a good ideal to build to code. I do think it is. In my case I am building to meet ASME design standards but will not have stamp. Commonly done I know!

I called EATON and they said they build and sale bag filters to 150psig and DO NOT MEET ASME DESIGN STANDARDS. They it is a customer or local jurisdiction of authority who stipulates it.

All of my vessels up to date have been fabricated by local fab shops here in Vietnam. They were spec to meet ASME code but no stamp. All have been just fine until now.

The difference now is to him that I am self performing these bag filters with my welders and that doesn't meet code. He doesn't get the "design to" part of it. Really I would have only 6 pressure retaining welds. The body is 8" sch 10 304ss pipe it has a burst pressure rating of 700 psi. My pumps are only capable of 60psi.

All welds are full pen v groove welds. Easy. Pressure test to 150% mawp. If it all passes good to go.

Crazy. I know safety is important and they have a tough job but dang they can make it difficult when they pretend to be engineers.

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You are correct in seeking out what codes are applicable here, but BPVC has been adopted by all fifty states and multiple countries. Per NRC adoption in the mid '90's, it is more or less a federal code in the United States.

Now, in Vietnam, I don't know.

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Thanks. At one time there were 6 or 7 states that did not mandate it.

The engineer at EATON I got of the phone with said they sell 100psi filters that are not built to code.

These are simple bag filters. 8" sch 10 about 3.5 ft long.

See if you can get a hold of the EXACT testing procedures, if they are publically available, for what merits a BPVC stamp.

If by law you are required to conform to the code and if you can satisfactorily pass the exact test that a 3rd party would perform (which it sounds like that's what you're doing) you still don't get passed, it's time to elevate the issue to a higher authority.

So where did this illusion come from that all vessels must be code stamped.

Yeah I think it's important that you see what the testing procedure is like to obtain the ASME seal of approval. That being said, if you have some sort of design validation via mathematical analysis and proof that your manufacturing procedures are consistent with ASME procedures combined with a hydro test it should be okay.

In my line of business,traceability is a concern so make sure you have material certs on the pipe you're using and maybe a welding procedure that you're using when welding the pipe. NDE might be highly useful too in checking for integrity of the welds. But it seems like you have these type of procedures already in place.

Of course this is assuming that no entity that you encounter will require the ASME stamp.

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So where did this illusion come from that all vessels must be code stamped.

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So what was the outcome of the showdown?

Most serious thread EVER

Quick! Someone post tits!

I was going to be a wise ass in this thead but I have no clue what's going on. I'm going to back away slowly and make fart jokes in the zoo.

Something vessel something something pipe something stamp

Update

Working on my end to decompress the conflict. So I requested bid from local fab shop to fabricate. This shop initially no bid the work. I went back and said just tell me what you would do the work for. They have and there cost is still within my original budget. This safety guy seems think I can not self perform the work.

One question. Are bag filters considered strainers? Or is the definition of strainers explicit enough that bag filters can not construed to be strainers?

I am correct in that vessels " built to or to exceed ASTM Sec VIII Div 1" do not require a stamp. The need for a stamp is simply client driven or driven by the local authorities. It is not a federal law. I believe there are 5
5 or 6 states that don't really mention it. I have read reference that Texas is one one them. Texas does mention BPVC for boilers but no specific language to vessels. I read the mentions by Texas personally and the language is soft.....but I am unsure if this is true.

I have called two bag filter companies where they sell filters that are designed to working pressures of 150psi and do not come with a stamp. They also have economical versions that are not even design to code at those pressures that are commonly sold.

So this goes back to the original question. How do you correctly / factually tell someone
that believesASME Sec VIII Div I is mandated when indeed it is not?

I found reference in 3.1.4 of the implementation of vessel code by OSHA where the first sentence say straight up that "ASME Sec VIII Div I has no legal standing" but then is followed by a couple of paragraph that says but......it is good to be implemented. Is this the closest thing to actual language I can reference to because everything else is vaguely written that a lay person will read and think that ASME Sec VIII Div I is a federally mandated law.

I was curious to know what they do in Vietnam, as I have never worked there, nor know of anyone that does.

Our company pressure vessel spec says to follow local rules and regulations with regards to design. This is more to allow for all the different codes out there depending on what part of the world you are in.

As far as federal requirements for Section VIII, in the outer continental shelf, the US government does mandate the use of Section VIII on pressure vessels. But as you pointed out, that's not Vietnam.

An excerpt as follows:
http://www.ecfr.gov/cgi-bin/text-idx?SID=91070776b6ddbcdcc077c4f7b5e674b3&mc=true&node=se30.2.250_1803&rgn=div8

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250.803 Additional production system requirements.
(a) For all production platforms, you must comply with the following production safety system requirements, in addition to the requirements of 250.802 of this subpart and the requirements of API RP 14C (as incorporated by reference in 250.198).
(b) Design, installation, and operation of additional production systems(1) Pressure and fired vessels. Pressure and fired vessels must be designed, fabricated, and code stamped in accordance with the applicable provisions of Sections I, IV, and VIII of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (as incorporated by reference in 250.198). Pressure and fired vessels must have maintenance inspection, rating, repair, and alteration performed in accordance with the applicable provisions of API Pressure Vessel Inspections Code: In-Service Inspection, Rating, Repair, and Alteration, API 510 (except Sections 5.8 and 9.5) (as incorporated by reference in 250.198).

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I have read reference that Texas is one one them. Texas does mention BPVC for boilers but no specific language to vessels. I read the mentions by Texas personally and the language is soft.....but I am unsure if this is true.

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I had a weird situation earlier this week where I had apply a couple of non-coded vessels in Texas.

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I have read reference that Texas is one one them. Texas does mention BPVC for boilers but no specific language to vessels. I read the mentions by Texas personally and the language is soft.....but I am unsure if this is true.

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I had a weird situation earlier this week where I had apply a couple of non-coded vessels in Texas.

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It all becomes just one slippery tit doesn't it. Just can't quite get a total complete answer. Just when you think you have something definitive you find something that says not so much.

How and when can a vessel that contains a internal pressure greater that 15 psi that is not code stamped be used? Is there a case where that same vessel can still be use if it doesn't meet ASME Sec VIII Div 1 code but does pass the recommended hydro test of 150% MAWP?

I will keep looking for the smoking gun of how it is handled. It not federal law for sure! But just what are the real rules and limitations of using code/non-code vessels greater than 15 psig.

Bump

Div 1 is not a requirement it is a standard of design that has strict rules. These rules like any good engineering practice have significant safety factors.

I don't follow the "bag" comments. Are you building a steel vessel to hold this pressurized bag?

Depending on the diameter of the vessel just use pipe and build to B31.3.

People build non stamped pressure vessels all the time. They simply hydrotest them 1.3x mawp to validate the design. They also likely have a lower safety factor. Div 1 is 3.5 iirc and is achieved by derating the stress value of the material in the minimum wall thickness calculation. For example: 516-70 has a stress value of 70ksi, while only 20ksi is used in the calculation.

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People build non stamped pressure vessels all the time. They simply hydrotest them 1.3x mawp to validate the design. They also likely have a lower safety factor. Div 1 is 3.5 iirc and is achieved by derating the stress value of the material in the minimum wall thickness calculation. For example: 516-70 has a stress value of 70ksi, while only 20ksi is used in the calculation.

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Completely agree. Where is the magical phrase that dispels the myth that Sec VIII Div 1 is mandated to be followed at all times.

The closest I have come is 3.1.4 on OSHA guidelines to Vessel Code that says Sec VIII Div 1 does not have legal standing.

But is followed why is is still a good idea to implement it. Everywhere you read the narrative is written in a way that if you designed and built a vessel for 50 psi but did not followed code the ASME Coad police would come and shut you down and arrest you. I know that is not the case but I can't find where it says that for a common health and safety guy to understand.

I believe that if no code is mandated to be followed and the vessel passed the mawp of 150% it should not trigger any safety flag.

Again the context here is a inline 8" sch 10 bag filter that will never see above 50psi (pump limitation) and the water temperature is 110 deg F and will only be used in a temporary situation (14 hrs/day for 3mths) and will never will be used again.

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People build non stamped pressure vessels all the time. They simply hydrotest them 1.3x mawp to validate the design. They also likely have a lower safety factor. Div 1 is 3.5 iirc and is achieved by derating the stress value of the material in the minimum wall thickness calculation. For example: 516-70 has a stress value of 70ksi, while only 20ksi is used in the calculation.

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Completely agree. Where is the magical phrase that dispels the myth that Sec VIII Div 1 is mandated to be followed at all times.

The closest I have come is 3.1.4 on OSHA guidelines to Vessel Code that says Sec VIII Div 1 does not have legal standing.

But is followed why is is still a good idea to implement it. Everywhere you read the narrative is written in a way that if you designed and built a vessel for 50 psi but did not followed code the ASME Coad police would come and shut you down and arrest you. I know that is not the case but I can't find where it says that for a common health and safety guy to understand.

I believe that if no code is mandated to be followed and the vessel passed the mawp of 150% it should not trigger any safety flag.

Again the context here is a inline 8" sch 10 bag filter that will never see above 50psi (pump limitation) and the water temperature is 110 deg F and will only be used in a temporary situation (14 hrs/day for 3mths) and will never will be used again.

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div 1 is followed because the u-stamp serializes the vessel for registration with the national board. It also ensures that the design and fabrication has been reviewed by an authorized inspector, usually a representative of the insurance company like bureau veritas. As with anything more specification equals higher cost.

I think DOT requires div 1 but even then it isn't the letter of div 1 as the hydrotest pressure is 1.5x mawp and 8 hours instead of undetermined test duration.

Understand. It kicks off a huge paper trail that says it meet all of the checks and balances from material purchase, welding design, welder certs, heat treatment, NDT and such.....so when it blows up they (and insurance) will be protected to the max degree possible.

But where does it say that you can still do build and fab a low pressure filter without having to comply with all of what Code brings to the table.

The health and safety guys say "Hey that vessel could see 50 psi....therefore it should be designed and built to code and you aren't allowed to self direct that build"!!!!!! I say what to competly neutralize that assertion???
It has been awhile but my first 8 years out of school I did pressure vessel design (22years ago). Most of the older inspectors I new are dead or disappeared. I know the H&SE guy is wrong. (On this project we have always said vessels would be designed to Sect VIII Div 1but not require U stamp) I just can't point to something in writing to show him he has it wrong.

Nothing has to be built to div 1 unless a client specifically requires. Just like API, it is a guideline of rulesthat if followed significantly reduce the risk of failure. Pick materials that meet a certain mawp and hydrotest it to 1.3x for an hour. Make sure pressure holds and move on with life.

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But where does it say that you can still do build and fab a low pressure filter without having to comply with all of what Code brings to the table.

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The problem with this question is that it's a little bit like asking, "where does it say I can't wear socks with my sandals?" It may be a poor practice, but there (usually) isn't a rule prohibiting it. The burden of proof is on your HSE guy in the form of a local regulation, company policy, or customer requirement.

Are you asking where it says for just onshore Vietnam? Because I have pointed you to where the United States government specifically requires ASME section VIII be used for offshore oil and gas facilities.

Could your inspector's background be from there? That could explain why he is so insistent. A quick GIS of the matter pulls up a ton of companies that do ASME section viii inspections in Vietnam. So what do the Vietnamese government regulations say?

The HSE guy sounds like he is trying to use his "safety" authority to drive some mythical decision out of a lack of his own understanding.

The OP needs something that is only 8" and B31.3 can be used enlieu of div 1, just fabricate with SA-106B and B16.5 flanges.

Again, if a hydro test can be performed say at 150 psi for an hour that should be more than adequate to prove the design.