One of the significant deficiencies we find in our audits/investigations is the lack of meeting ASME B31.3/.5 to install process piping. I have written about this topic for decades, and I still get inquiries monthly about this standard and its critical role in real process safety management.
For those who attend my 5-day Advanced PS Course, this single topic gets more questions/discussion than any other. Only ASME Section VIII and Pressure Relief Devices (PRD) rank up there with the number of questions and challenges. My course is NOT intended to turn safety pros into process safety engineers; however, we need a basic understanding of what these “primary containment” RAGAGEPs require to help keep honest engineers honest to the best of our ability.
For decades, I was always taught that we must ” visually inspect,” called a VT, 10% of each welder’s welds. This is part of the Quality Assurance requirements from the ASME B31 series, which references ASME Sections V and IX. This 10% is “old school” and arose from the DOT Pipeline Standards, which, although a pipeline is a pipe, the requirements are a bit different in their construction, inspection, and testing.
However, ASME B31.3 has a very different take on the VT and NDT on chemical process piping, and in 2022, the standard changed regarding these requirements. I apologize for my delay in discussing this, but in 2022, I went to work full time for a client and got out of the PSM/RMP bubble, so I missed this significant update. But as they say, better late than never!
Let us get into the new requirements…
First, to be fair, here is 49 CFR § 195.234 – Welds: Nondestructive testing requirements
(emphasis by me)
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49 CFR § 195.234 – Welds: Nondestructive testing § 195.234 Welds: Nondestructive testing. (a) A weld may be nondestructively tested by any process that will clearly indicate any defects that may affect the integrity of the weld. (b) Any nondestructive testing of welds must be performed— (1) In accordance with a written set of procedures for nondestructive testing; and (2) With personnel that have been trained in the established procedures and in the use of the equipment employed in the testing. (c) Procedures for the proper interpretation of each weld inspection must be established to ensure the acceptability of the weld under § 195.228. (d) During construction, at least 10 percent of the girth welds made by each welder and welding operator during each welding day must be nondestructively tested over the entire circumference of the weld. (e) All girth welds installed each day in the following locations must be nondestructively tested over their entire circumference, except that when nondestructive testing is impracticable for a girth weld, it need not be tested if the number of girth welds for which testing is impracticable does not exceed 10 percent of the girth welds installed that day: (1) At any onshore location where a loss of hazardous liquid could reasonably be expected to pollute any stream, river, lake, reservoir, or other body of water, and any offshore area; (2) Within railroad or public road rights-of-way; (3) At overhead road crossings and within tunnels; (4) Within the limits of any incorporated subdivision of a State government; and (5) Within populated areas, including, but not limited to, residential subdivisions, shopping centers, schools, designated commercial areas, industrial facilities, public institutions, and places of public assembly. (f) When installing used pipe, 100 percent of the old girth welds must be nondestructively tested. (g) At pipeline tie-ins, including tie-ins of replacement sections, 100 percent of the girth welds must be nondestructively tested. |
Here is the comparison of the 2016 to 2022 ASME B31.3 requirements:
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341.4 Extent of Required Examination (16) 341.4.1 Examination — Normal Fluid Service. Piping in Normal Fluid Service shall be examined to the extent specified herein or to any greater extent specified in the engineering design. Acceptance criteria are as stated in para. 341.3.2 and in Table 341.3.2, for Normal Fluid Service unless otherwise specified. (a) Visual Examination. At least the following shall be examined in accordance with para. 344.2: (1) sufficient materials and components, selected at random, to satisfy the examiner that they conform to specifications and are free from defects. (2) at least 5% of fabrication. For welds, each welder’s and welding operator’s work shall be represented. (3) 100% of fabrication for longitudinal welds, except those in components made in accordance with a listed specification. See para 341.5.1(a) for examination of longitudinal welds required to have a joint factor, Ej, of 0.90. (4) random examination of the assembly of threaded, bolted, and other joints to satisfy the examiner that they conform to the applicable requirements of para. 335. When pneumatic testing is to be performed, all threaded, bolted, and other mechanical joints shall be examined. (5) random examination during erection of piping, including checking of alignment, supports, and cold spring. (6) examination of erected piping for evidence of defects that would require repair or replacement, and for other evident deviations from the intent of the design. |
341.4 Extent of Required Examination (22) For all fluid services, surfaces where attachment welds have been removed shall be visually examined in accordance Where temporary attachments were made on P-No. 4, P-No. SA, P-No. SB, and P-No. l SE materia ls, the surfaces shall also be examined by the magnetic particle or liquid penetrant methods in accordance with para. 344.3 or para. 344.4, respectively. 341.4.1 Examination – Normal Fluid Service. Piping (22) in Normal Fluid Service shall be examined to the extent specified herein or to any greater extent specified in the engineering design. Acceptance criteria are as stated in para. 341.3.2 and in Table 341.3.2 , for Normal Fluid Service unless otherwise specified. (a) Visual Examination. The following shall be examined in accordance with para. 344.2 : (1) sufficient materials and components selected at random to satisfy the examiner that they conform to specifications and are free from defects. (2) at least 5% of fabrication, as defined in para. 300.2, selected at random. (3) 100% of ALL COMPLETED WELDS, except those in components made in accordance with a listed standard. See para. 341.5.1(a) for examination of longitudinal welds required to have a joint factor, Ej, of 0.90. (4) a sufficient number of threaded, bolted, and other mechanical joints selected at random to satisfy the examiner that they conform to the applicable requirements of para. 335. When pneumatic testing is to be performed, all threaded, bolted, and other mechanical joints shall be examined. (5) alignment, supports, and cold spring selected at random during erection. (6) erected piping selected at random for evidence of defects that would require repair or replacement, and for other evident deviations from the intent of the design. |