I feel your pain jerarca. What the "owner" apparently has yet to realize they are held to other standards and not just the code and spec.
While inspectors are typically focused on code and spec. Example CSA Z276-01. While API 620 covers most of it and is heavily referenced and in many parts required, the Canadian "law" is above and beyond API 620.
Another example is ASME Section III. Specific parts of it are exempted, modified, or not allowed by the U.S. NRC by law. Even down to what edition is valid. 10CFR part50.55a.
Example:
http://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-0055a.html"
(1) As used in this section, references to Section III of the ASME Boiler and Pressure Vessel Code refer to Section III, and include the 1963 Edition through 1973 Winter Addenda, and the 1974 Edition (Division 1) through the 2004 Edition (Division 1), subject to the following limitations and modifications:
(i) Section III Materials. When applying the 1992 Edition of Section III, applicants or licensees must apply the 1992 Edition with the 1992 Addenda of Section II of the ASME Boiler and Pressure Vessel Code.
(ii) Weld leg dimensions. When applying the 1989 Addenda through the latest edition, and addenda incorporated by reference in paragraph (b)(1) of this section, applicants or licensees may not apply paragraph NB–3683.4(c)(1), Footnote 11 to Figure NC–3673.2(b)–1, and Figure ND–3673.2(b)–1."
Not only is the specific code year edition specified, but they go so far as disqualifying specific paragraphs even though it is the "code".
The rules are different in your part of the world, the law of the land applies to them.
In that lies the conflict. The 'owner' has over ridden the previously accepted (by the government) FEED.
At any time an owner can over ride a code or spec which relieves the EPC/contractor of that particular responsibility. However; it does not relieve the owner of permit and governmental requirements. That particular relief can only come from the appropriate governmental authorities.
Example: If I use a sledge hammer to knock the tail lights out of my truck, I own it, I can do that if I wish. However, the State department of transportation and the US government have specific laws requiring those tail lights to be in working order before I can use that truck on the highways.
I hope all that helps. Even withstanding that, as mentioned by Shane and others, they are technically in violation of the code by ignoring the specs in the manner in which they have. That loops back to the governmental sign off's and the code both.
Owning something doesn't relieve a person, group, or company of responsible use.
pequeño jefe y la esposa decir hola.
Tomar cuidado mi amigo,
Gerald
I would like to know your opinion on below two cases and/or what is your suggestion for welds examination of a piping system which is normal service, the product is pressurized air or nitrogen, maximum operating pressure 190 psi.
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