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 ยง 195.234 – Welds: Nondestructive testing requirements
(emphasis by me)