I'm struggling to compile this question so it may need to evolve as (or if) I get any feedback from the Forum. It's also long so please stick with me . . .

My place of work is in a large industrial complex with numerous large, steam heated buildings and each building has it's own local steam boiler. The typical boilers are rated at 150psig and produce steam at rates of ~4400 #/hr.  The working pressure is dropped down and is distributed throughout the pipe network at 9psig.  Based on this low working pressure, I assume all the boiler external piping for these buildings was originally designed and constructed under the ASME B31.9 Code for Building Services Piping.

Because of the age of the piping, the maintenance group is frequently called in for repairs which they often do by welding in patches when leaks spring or when a terminal unit needs replacement, usually on a crisis intervention basis.   The welds are never inspected. The welders are not, nor have they ever been qualified and they know nothing about procedures. As an inhabitant of these buildings, I worry that someone will eventually get hurt from their sloppy workmanship.   Feast your eyes on this beauty (attached) and you'll see what I mean and why I'm concerned.

Since common sense does not exist here and no one in their chain of command will accept the idea of training or qualifying the maintenance welders I am trying to find legal leverage to force my concerns as a code compliance issue and this is the beginning of my question:  What code would be applicable?   Is the NBIC Part 3 applicable to low pressure steam distribution piping?   Paragraph 1.2(a) of the 2007 edition re-invokes the original construction standard for repair & alteration of any "pressure-retaining item"  and paragraph 1.2(e) specifically addresses steam piping and also re-invokes the original code of construction for repairs or alterations.  As far as I can tell, the NBIC doesn't discriminate based on low system operating pressure so I conclude that if B31.9 was applicable when the system was built, it is applicable now when repairs are needed.

Does anyone agree or disagree with my logic so far?

If NBIC Part 3 is applicable to low pressure steam piping repairs then I can force the issue of requiring the maintenance welders to be trained, qualified, inspected, etc. and also mandate creation of qualified weld procedures.

If this sounds reasonable then I next have to find out how the NBIC becomes a legal standard.    The 29CFR and OSHA list ASME B31.1 is "consensus standard" that has been adopted by reference and therefore is tantamount to law BUT I cannot find any mention of the NBIC or B31.9 also being listed as "consensus standards".    Can anyone help me make this connection?

Incidentally, while seeking truth on this subject I have talked (informally) with a state official and also an NBIC committee member and both have expressed the opinion that low pressure heating systems such as I have described are not covered by any jurisdiction and therefore are not subject to inspections or normal weld qualifications.   Can this possibly be true ?!?!  


All opinions and advice are gratefully accepted.
Thanks.

You mentioned that the boilers are rated for 150 psi, however, the steam pressure is reduced to about 9 psi in the distribution system. ASME codes typical are usually mandated by the local municipality or state when the pressure exceeds 15 psi. So, the boiler is probably covered by the code, but not the distribution piping.

However, the owners are responsible for ensuring the safety of the workers or the tenants whatever the case is. Should a person get scalded or worse if a joint leaked or failed, the owner would be liable.

If the person injured happens to be a worker, the employer would be held liable, but that’s what worker’s compensation laws and insurance are for. They protect the employer against law suits by the employee. Still, OSHA requires the employer to provide a safe work environment. When there is a serious injury, OSHA may be involved and they could levy a fine against the employer.

If you want to stir the hornet’s nest to get some action, contact the insurance carrier and ask them to perform a walking inspection. They strive to reduce their exposure to a claim. If they see a situation that could result in a claim, i.e., a serious injury, they can demand corrective actions be taken or the owner could risk losing insurance coverage. Many insurance policies require the boiler and piping system comply with appropriate codes even if the code is not a legal requirement. It becomes a condition or a provision to get insurance coverage.

Good luck - Al