"Gerald,
Do you have the paragraphs that require, and the paragraphs for acceptance criteria?
Not the AI stuff.
Also, B31.3 is not boiler code. And I am admittedly totally ignorant of Section XI."
For ASME III, it's an ANI, not AI. The duties of an ANI do not include visual inspection of a weld. Visual inspection typically falls under the perview of Quality Control.
As for paragraphs, what year code applies has to be established before that. That is found in 10CFR50.55A codes and standards.
Then there is the ASME stamp QA programmatic requirements, as accepted by the ASME survey for the specific application. NPT, etc.
Aside from that just using 2013 Section III as a reference (Which btw is yet to be accepted by the NRC). In fact, lets ignore the visual examination requirements documented in NX 2000 which vary.
Lets look at NX 4000, specifically starting at NB 4424 "Surfaces of Welds". I know of some orginizations that have found themselves on the wrong side of the code, NRC, and ANI's because they didn't understand this particular section, even more so when you get to NB 4424.2 preservice examination requirements. That latter part in particular invokes some requirements out of Section XI.
One particular organization found itself with multiple models locked down in their yard after the NRC shut them down for these kind of concerns and others. It was absolutely clear that the people who wrote their program were not the same as the ones attempting to implement the same.
All welds must be examined visually for piping under NB, NC, ND. with NB and NC often invoking preservice requirements as well. The only real difference is in who performs the exams. As a general rule of thumb, 'All' safety related items (nuclear safety), require visual inspection/examination by certified personnel, along with the other examinations as required out of NX 5000. An organization that does not understand that is set up for failure and taking a hit from both the regulators, and running the high risk of ASME pulling their stamp.
Now lets move out of the nuclear realm, and into ASME process piping B31.3 2012.
Specific paragraphs,
341.4.1 Examination - normal fluid service
(a) Visual examination. At least the following shall be examined in accordance with para. 344.2:
paraphrased;
At least 5% of fab, 100% for longitudinal welds, random examinations
341.4.3 Examination - severe Cyclic Conditions.
It becomes 100 percent of all fabrication.
For reference 344.2 Visual examination
344.2.1 Definition includes welds. 344.2.2 specifies BPV code Section V Article 9
B31.1 2012
136.4.2
"Visual examination shall be performed to verify that all completed welds in pipe and piping components comply with the acceptance standards specified in (A) below"
I believe that should be sufficient to make the point.
Quick hit an run for now but I
I'll be back to review more thoroughly. As I said my point was boiler code. So the B31 pressure piping codes are irrelevant.
Gerald,
To continue.
It must be kept in mind the context of my point. Again, I did NOT include pressure piping. Nor did I include API or the AWWA.
1) The NRC is irrelevant to the requirements of ASME. I did not make a point about the NRC.
2) 10CFR50.55A is irrelevant to the requirements of ASME. I did not make appoint about the Code of Fed Regs.
3) The requirement for safety related is also irrelevant to the requirements of ASME.
4) The ASME survey team will assess based upon code requirements. If there are none then they have no authority to impose. We usually kiss butt to pick our battles but if pushed I'd appeal. And even in NCA-4134.10, which speaks of "inspection", there is no explicit requirement for VT. In fact, ASME predominantly avoids the term "inspection" altogether except in reference to the AI/ANI, and reserves the term 'examination' for its usage. This of course runs counter to NQA-1 which explicitly uses the term inspection in a manner similar to ASME's use of examination. But I am not talking about NQA-1 either.
5) And while I will grant there are visual inspection requirements in NB-4424 those requirements are in relation to obtaining an acceptable NDE other than VT and are not stand alone. Quote: "The surface condition of the finished weld shall be suitable for the proper interpretation of radiographic and other required nondestructive examinations". The acceptance criteria is scant at best (no fusion, no slag, no cold lap, no porosity, no cracks, no craters, and the only criteria for ID is concavity) and related to the very quote provided. Compare this to the extensive VT requirements and acceptance criteria in Subsection NF.
6) As for NB,C,D-5000 when you look you will find RT, UT, PT, MT and eddy current. Something is conspicuously missing.
Now, having said all this I am not arguing that it is not a good idea, or even required by other governing bodies. In fact we do it, and it is. It is a very robust part of our program. But I think my argument stands.
Any QA program that doesn't take into account the federal regs is begging for trouble. As such, it does directly affect the ASME survey.
The edition of ASME III, and XI that is applied comes straight out of 50.55A. It is far from irrelevant.
Quoting NB 5000 is again taking it out of context. You have to view NX 2000 and NX 4000 to find the visual requirements as I mentioned.
The OP directly asked about ASME piping with no other qualifiers.
With all due respect, I have to question any program that claims visual is not required. Especially for those items required to be addressed by PSI.
I have extensive experience in the industry, QA, QC, Welding, and NDE nuclear. I have never seen it where visual was not required for safety related items.
It is apparent we will not agree on this given your most recent post. I will leave it at that and comment no more.
Gerald,
I don't mean to be sharp on this but you aren't even listening.
You ignore the fact that I made it clear we do perform VT robustly, so your nod to 'all do respect' has no context.
And my point was ASME, as was the point of the OP.
And you have yet to provide a single paragraph to clearly substantiate your point.
You claim its there as some ambiguous collective to be assumed, and that everybody should do it.
The challenge stands. Show me one paragraph wherein VT is a requirement (especially for welds) on its own and complete with acceptance criteria as is the case with Subsection NF.
I did specify the paragraph and how it feeds back to others. However, you have stated your not familar with Section XI. You have stated federal regulations (10CFR50.55a) do not apply. You fail to see the preservice tie back. In short, you fail to see.
Yes you did mean to be sharp as it most certainly read that way. It is also readily apparent no advice other than what you currently believe will be accepted.
One more piece of advice before I go. There is no such thing as 'one paragraph' that defines any given aspect of ASME code. They 'all' have loop backs always, sometimes, maybe, everytime. It is a fools errand to hang your hat on any 'one paragraph', and in fact "it is an ambiguous collective", especially when it comes to nuclear code. Without taking it as a whole, it is a given that a person will not be able to see the forest for the trees.
That will be the last I say on it.
Gerald,
I wasn't asking for advice. I was making a point.
You challenged my point and it proved to be very weak at best.
And you tried to disguise the weakness by insisting on points about CFR, pressure piping, and what a program should include, when I made it clear that was not my context.
Your best point was NX-4424, as I quoted in part. That was valid. And I stood corrected.
I also granted you programmatical points. Clearly.
Outside of that however, there is nothing. And you have demonstrated that. Nothing from Section I, nothing from Section VIII, and nothing from Section III other than 4424, ripples, valleys, and undercut. Very weak indeed.
Why is VT so conspicuously absent from NX-5000?
An absence you have not resolved, loop backs and/or phases of the moon notwithstanding.
Also, I never said Fed Regs don't apply, just that they essentially don't apply in a discussion of ASME requirements, no more than say 49CFR Part 192 is applicable to anything pertaining to API 1104 or ASME B31.8.
In other words. You have clearly developed a very effective forest. And I am sure your program is robust. But in order to do so you are having to uproot trees from another forest to fill in the blanks, while trying to convince us those trees were there all along.
Verry good discussions.
803056, please share your thoughts, what is your take on this argument of js55 & CWI555?
Thanks!
~Joey~
Just to muddy the waters abit, what is the requirement for visual inspectors for ASME?
ASME could not care less about the CWI certification. When ASME references NDE certification it always gets around to SNT.
Though this is in the process of being changed.
Let me add something I think is critical at this juncture. I am in complete agreement with Gerald on the idea that VT is absolutely necessary to an effective program. If you do not practice this method you will eventually encounter severe issues. While I am making these arguments my inspectors (and the welders as well) are looking at EVERY SINGLE WELD being produced by my company. You cannot rely upon Code minimums to determine or dictate your program. Code minimums are only the skeleton. You still have to flesh it out. If it has been assumed my intent was to argue that since it is not required then it is not necessary, this is mistaken.
It might be beneficial to our understanding to compare the Boiler Code approach to a pressure piping approach.
Take a look at the language and requirements of ASME Section III NB-4424 and then the language and requirements of ASME B31.1 127.4.2 (C).
Sound familiar?
And yet, in B31.1 we still have paragraph 136.4.2, in which, as stated, a notable similar paragraph is absent from Section III.
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