The NDT Technician: A Quarterly Publication for the NDT Practitioner

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November 5, 2002

Hollis Humphries

TNT Editor

ASNT

P.O. Box 28518

Columbus, OH 43278

RE: Possible Errors in TNT-Volume 1, Edition 4 (October 2002) Pertaining to Non-Nuclear ASME Codes.

Dear Mr. Humphries:

After review of the above stated document, it is my opinion that the information presented in this article contained several errors and/or partial facts that should be clarified to your readers. In my opinion, these items are listed as follows:

•     Page 2 – “Code references to visual requirements are usually for the Third Party Code (sic) Inspector”

This statement ignores the fact that mandatory written quality control programs are required in all ASME construction codes, which stipulate that visual examinations be conducted by the Manufacturer. See UG-90 in ASME VIII. (Note the emphasis on “examination” versus “inspection” which is normally very confusing to many NDE practitioners).

•     Page 2 – “NDE requirements are determined in contract documents”.

This is partially true - however, the ASME Code mandates certain NDE requirements regardless of contractual rules, based on service or thickness (example: See UW-11 and UCS-57 of ASME VIII) or design conditions (example: See UW-12 of ASME VIII and PW-11 of ASME I).

•     Page 3 – “Sensitivity”

1)   Reference to Table “T-272” should be “T-276”.

2)   “This usually applies to shimmed hole type penetrameters (sic)” - This is incorrect. The –15%/+30% rule applies to all IQI’s, whether they are placed across the weld or on a shim. The +30% upper density restriction may be exceeded (up to 4.0 H&D density, maximum) if a hole-type IQI is shimmed.

3)   “NOTE: In the case of Section VIII of the Code, un-sharpness values are guidelines, but not to exceed 0.07 in (1.75mm).” - This is incorrect. There are no upper limits on unsharpness in ASME VIII; T-285 of ASME V is only a guide. The upper restriction of 0.07 in. is from ASME I, PW-51.

•     Page 3 – “Relevant Indications”:

“ASME Construction Codes define two types of indications - relevant and nonrelevant.”

This is partially true. The definition of what constitutes relevant and non-relevant indications is only provided for MT/PT and Appendix 4 in ASME VIII for rounded indications. For all other methods, “relevant” and “non-relevant” indications are not defined. The general term “imperfections” is used in UW-51/UW52 for RT, and also in Appendix 12 for UT.PW-51 and PW‑ 2 of ASME I also follow this language.

•     Page 4 – “Proper Application of non-destructive testing in accordance with codes such as the ASME Boiler and Pressure Vessel Code guarantees the safely and reliability of materials and fabrications during manufacture, maintenance, and performance”.

I Seriously believe that the authors of this article should rethink any statement that “guarantees” the safety of equipment built to the Code, even if the proper NDE is applied. The Manufacturer’s Data Report for each item does not “guarantee” safety – it simply states that the manufacturer and Authorized Inspector believe that the item was built to the Code.

•     Page 4 – Table 2 - “VT”:

The use of the acronym “VT” may lead some to believe that formal visual examination (per ASME V Article 9) with personnel qualifications and written procedures is required. This is untrue. Again, the term visual “examination” (conducted by the manufacturer) versus “inspection” (conducted by the Authorized Inspector) should be clarified here as to who is responsible to do what. It should also be clearly noted that ASME VIII and/or ASME I do not specify mandatory minimum training and certification requirements for Quality Control (visual) examination personnel.

In the same vein of thought, an article on page 1228 of Materials Evaluation in this same issue (October 2002) contains an advertisement for the API UT Examiner Program. This ad states – “API 510 and 570 make the use of qualified UT Examiners “mandatory” (their bold, not mine). This is untrue. The requirement for utilizing industry-qualified UT operators will become mandatory in December 2003 (see Para. 5.5 of API 510 and Para. 8.2.6 of API 570).

Additionally, your readers should be advised that API 510 and API 570 both allow alternative equivalent UT Examiner qualifications if approved by each owner/user. Therefore, the use of only "API – certified" UT personnel is not mandatory now, nor will it be in December 2003. If approved by the owner-user, ACCP, AWS, or other “equivalently qualified” UT personnel may be used.

Thank you for the opportunity to allow me to comment on this information. Please contact me at your convenience if you require any further information or have any questions.

Sincerely,

Tim Schindler

Managing Partner

Schindler & Associates

ASNT Level III

La Grange, Texas

November 13, 2002

Tim Schindler

Schindler & Associates

La Grange, TX 78945

Dear Mr. Schindler:

Thank you very much for your letter of November 5, 2002. The NDT Technician appreciates your concern regarding possible errors in Vol. 1, Issue No. 4 pertaining to non-nuclear ASME codes. Your comments regarding the article have been forwarded to reviewers of the material and we look forward to their response on this important matter. A copy of your letter has also been forwarded to the staff of Materials Evaluation for their action. On behalf of our readers, thank you again for your interest and concern.

Best regards,

Hollis Humphries

TNT Editor

Response to Letter From Tim Schindler on NDT Technician Article

Page 2 Schindler Comment on: “Code references to visual requirements are usually for the Third Party Code (sic) Inspector”

His comment: “This statement ignores the fact that mandatory written quality control programs are required in all ASME construction codes, which stipulate that visual examinations be conducted by the Manufacturer. See UG-90 in ASME VIII. (Note the emphasis on “examination” versus “inspection” which is normally very confusing to many NDE practitioners).”

What he says here is also partially true. The Code, however, has no specific requirements for visual examination that spell out, how a component is to be examined, what acceptance standards apply to it and who can do the examination. Each manufacturer must develop these as part of their program. There are no qualification requirements for whomever does visual examinations as there are for personnel performing radiographic and ultrasonic examinations in Section I and VIII. On the other hand these Codes have very specific inspection duties for the Inspector. When the Code refers to Inspector, it is referring to an Authorized Inspector as used in Sections I and VIII.

Page 2 Schindler Comment on: “NDE requirements are determined in contract documents”.

His comment: “This is partially true— however, the ASME Code mandates certain NDE requirements regardless of contractual rules, based on service or thickness (example: See UW‑11 and UCS-57 of ASME VIII) or design conditions (example: See UW-12 of ASME VIII and PW-ll of ASME I).”

I think he really means UW-11 instead of UW-12. His comment ignores the fact that every purchase of a pressure vessel or boiler begins with a contract. That contract will identify what edition of Codes are applicable, since jurisdictions may not all reference the latest published edition of the Code. Legislatures usually must approve laws that mandate particular requirements. However, each jurisdiction and owner may have additional requirements or the architect/engineer may have additional requirements. As an example, Section I does not require radiographic examination of boiler tubes as they meet exclusion requirements, but on most, if not all, power or recovery boilers, radiography is performed during fabrication and construction on these tube welds.

Page 3 Schindler Comment on: “Sensitivity”

His comments:

“1) Reference to Table “T-272” should be “T-276”.”

His comment is correct.

2) “This usually applies to shimmed hole type penetrameters (sic)”

“This is incorrect. The -15%/+30% rule applies to all IQI*s, whether they are placed across the weld or on a shim. The +30% upper density restriction may be exceeded (up to 4.0 H&D density, maximum) if a hole-type IQI is shimmed.”

His comment is basically correct. The requirement for the -15% or +30% apply for both types of IQI’s. However, shims are only used on hole IQI’s and the +30% density level can be ignored when shims are used as long as a 4.0 density is not exceeded.

3) “NOTE: In the case of Section VIII of the Code, un-sharpness values are guidelines, but not to exceed 0.07 in (1.75 mm).” This is incorrect. There are no upper limits on unsharpness in ASME VIII; T-285 of ASME V is only a guide. The upper restriction of 0.07 in. is from ASME I, PW-51.

His comment is correct. They are requirements for Section III work, however.

Page 3 Schindler Comment on: “Relevant Indications”

“ASME Construction Codes define two types of indications — relevant and non-relevant.”

His comments: This is partially true. The definition of what constitutes relevant and nonrelevant indications is only provided for MT/PT and Appendix 4 in ASME VIII for rounded indications. For all other methods, “relevant” and “non-relevant” indications are not defined. The general term “imperfections” is used in UW-51/UW52 for RT, and also in Appendix 12 for UT. PW-51 and PW-52 of ASME I also follow this language.

The determination of relevant and nonrelevant indications is basic in the NDT methods. Training outlines in SNT-TC-1A and training course materials define causes of indications and even add false indications to the list. The Section VIII Code may only mention these in MT, PT and RT rounded indications sections, but it is clear from the definitions, ASME Section V, Article 30 that an imperfection is a “departure of a quality characteristic from its intended condition”, a relevant indication. The Code does not intend that evaluation be applied to nonrelevant indications or nonimperfections that may be part of the material’s characteristics or the physical makeup of the component such as a drilled hole, weld root penetration, grain boundries or other feature that is part of the design or results from the fabrication materials or methods.

Page 4 Schindler Comment on: “Relevant Indications”

Page 4 — “Proper application of non-destructive testing in accordance with

codes such as the ASME Boiler and Pressure Vessel Code guarantees the safety and reliability of materials and fabrications during manufacture, maintenance, and performance”.

His comments: I seriously believe that the authors of this article should rethink any statement that “guarantees” the safety of equipment built to the Code, even if the proper NDE is applied. The Manufacturer’s Data Report for each item does not “guarantee” safety — it simply states that the manufacturer and Authorized Inspector believe that the item was built to the Code.

What was probably meant here is that following the rules for the Code provides a greater assurance of safety. However, the reliance on NDE alone to the exclusion of the other features of the Code guarantees nothing. The safety of Code vessels and systems has been demonstrated over the last few decades when all of the requirements of the Code have been met.

Page 4 Schindler Comment on: Page 4-Table 2- “VT”

His comments: The use of the acronym “VT” may lead some to believe that formal visual examination (per ASME V Article 9) with personnel qualifications and written procedures is required. This is untrue. Again, the term visual “examination” (conducted by the manufacturer) versus “inspection” (conducted by the Authorized Inspector) should be clarified here as to who is responsible to do what. It should also be clearly noted that ASME VIII and/or ASME I do not specify mandatory minimum training and certification requirements for Quality Control (visual) examination personnel.

The Code Section referenced in Table 2, UG-90, provides requirements for both visual examination and inspection. The application of the terms is consistent with the Code’s previously described use of the terms “examination” and “inspection”. As with any SNT-TC-1A program, the use of the term “VT” should be described in the manufacturer’s quality program and its NDE procedures. Neither ASME Section I or Section VIII require that the recommendations of SNT-TC-1A be followed for NDE personnel qualification for any method. The manufacturer can follow the recommendations as written in SNT-TC-1A or can have another program.

Frank Sattler

Sattler Consultants, Inc.

ASNT Level III

ASME Boiler and Pressure Vessel Code, Subcommittee V – Nondestructive Evaluation

Contributor Response to Reader Comments on TNT Article

I suggest a general statement of explanation that the article “Using the ASME Boiler and Pressure Vessel Code” is intended to provide a brief overview to create an awareness of the type of nondestructive requirements involved. The article is not intended as a comprehensive treatment of all the various Code sections.

Page 2 Reader Comment on: “Codes references to visual requirements are usually for the Third Party (sic) Code Inspector”.

I believe ASME Section III subsections NF and NG require Visual Examination in accordance with ASME Section V Article 9 and NF/NG provide acceptance criteria. Perhaps Richard McGuire can check this.

“This is correct. NF and NG of ASME Section III require visual examination by others than the third party inspector.”

Richard McGuire

Manager of Training, National Board of Boiler and Pressure Vessel Inspectors

ASME Boiler and Pressure Vessel Code, Subcommittee V ‑ Nondestructive Evaluation

Chair: Subgroup General Requirements, Personnel Qualifications, and Interpretations Subcommittee IX - Welding and Brazing Qualifications

Page 2 Reader Comment on: “NDE requirements are determined in contract documents”.

Concur with proposed response; however, the reader also seems to miss that the statement in the article is not in conflict with the code, but states that the contract or purchase order references the appropriate code. The reader seems to misinterpret the statement as somehow in contradiction with the Code.

Page 3 Reader Comment on: “Sensitivity”

Comment 1: is correct, this is a typo and should have been Table T-276.

Comment 2: The reader is correct about the provision of the code.

Page 3 Reader Comment on: “Relevant Indication”

Concur with proposed response. Additionally, ASTM E 1316 “Standard Terminology for Nondestructive Testing defines Relevant Indication as, “an NDT indication that is caused by a condition or type of discontinuity that requires evaluation.” Basic to the NDT industry is that relevant indications are those specified in the applicable acceptance/rejection criteria.

Page 4 Reader Comment on: “Code guarantees the safety….”

Concur with reader comments. I would have appreciated the opportunity to review the final draft, and would have flagged this too.

Page 4 Reader Comment on: Page 4-Table 2- “VT”

Concur with proposed response.

Thanks,

Bill Plumstead

PQT Services, Inc.

Greenville, South Carolina

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