Pressure Systems 10CFR851 - The Way to Go but,

Some Tough Issues

W. OrenManager of Engineering

and Technical Services Division

Pressure Systems 10CFR851 - The Way to Go but,

Some Tough Issues

W. OrenManager of Engineering

and Technical Services Division

Pressure Systems

“Contractors must ensure that all pressure vessels … and supporting piping systems conform to:

(1) The applicable ASME Boiler and Pressure Vessel Code(2) The applicable ASME B31 Code for Pressure Piping(3) The strictest applicable state and local codes”

“Contractors must ensure that all pressure vessels … and supporting piping systems conform to:

(1) The applicable ASME Boiler and Pressure Vessel Code(2) The applicable ASME B31 Code for Pressure Piping(3) The strictest applicable state and local codes”

“When national consensus codes are not applicable (because of pressure range, vessel geometry, use of special material, etc.), contractors must implement measures to provide equivalent protection…”

“When national consensus codes are not applicable (because of pressure range, vessel geometry, use of special material, etc.), contractors must implement measures to provide equivalent protection…”

DOE 10CFR851 Pressure Safety “Contractors must establish safety policies and procedures to ensure that pressure systems are designed, fabricated, tested, inspected, maintained, repaired, and operated by trained and qualified personnel in accordance with applicable and sound engineering principles.”

“Contractors must establish safety policies and procedures to ensure that pressure systems are designed, fabricated, tested, inspected, maintained, repaired, and operated by trained and qualified personnel in accordance with applicable and sound engineering principles.”

Key People – Roles and Responsibilities

Pressure Systems Committee:• Develop and maintain pressure system program and define what a pressure system is

• Maintain list of Design Authorities

• Act as final JLab authority for Non-Code Qualified Construction Elements

• Ensure conduct of Peer Reviews

Pressure System Definitions

• Define Pressure System

• Design Authority

• Non-Code Qualified Construction Element

• Peer Review

• Define Pressure System

• Design Authority

• Non-Code Qualified Construction Element

• Peer Review

The JLab Pressure System Definition:

• started with the 10CFR851 definition

• applied the exclusions specified in the ASME BPV and B31 Codes

• considered the types of systems at JLab, and

• added exclusions covered under other regulations or ES&H Chapters

Pressure System:

A system containing piping, its components and/or pressure vessel(s) used to either convey or contain a pressurized fluid including cryogenic, pneumatic, hydraulic and vacuum. Vacuum systems must be considered pressure systems unless adequate measures have been taken to prevent pressurization above 15 psi. Includes pressure sources, fittings, pressure relief devices and associated hardware such as gages and regulators.

ASME B31 exclusions include:• piping systems between 0 and 15 psi with

nonflammable nontoxic and not damaging fluids between -20 °F to

366 °F.• tubes, tube heaters, crossovers, and manifolds of

fired heaters.

ASME BPV Code exclusions include:• pressure vessels which are parts of rotating devices.• water vessels with design pressure < 300 psi and

design temperature < 210 °F.• hot water tanks with indirect heat source < 200,000

Btu/hr where temperature < 210 °F and capacity < 120

gallons.• vessels with internal or external operating pressure <

15 psi.• vessels with inside diameter, width, height or cross

section diagonal < 6 inches.Exclusion under one does not provide

exclusion under the other.

Additional Chapter 6151 exclusions include:• Department of Transportation regulated

cylinders and dewars.

• roof and floor drains, plumbing and sewers.

• piping for hydraulic or pneumatic hand tools.

• piping internal to instruments (not instrument piping).

• fire protection systems constructed in compliance with recognized fire protection standards and ES&H Chapter 6910.

For operational labs when are the requirements applied to our pressure systems?

• New pressure system design, fabrication, installation, …..

• When modifications are made to existing systems

• A modification consists of a change in service of a pressure system or the expansion of the capability of a pressure system, e.g. extending its capabilities by increasing the nominal operating pressure.

• Repairs to existing systems• Done under the direction of a Design

Authority using like materials if possible otherwise analyze and solve per the program.

Key People – Roles and Responsibilities

Design Authority• Ensure ASME Code compliance

according to JLab policy

• Where ASME Codes cannot be applied, ensure equivalent level of safety

• Follow JLab policy and procedures for welding and brazing

• Ensure proper pressure system documentation

Design Authority Qualifications• 4 yr. degree in engineering or physics, at

least 5 years experience in design of related pressure systems

or• PE and experience in design of related

pressure systems

or• Approval of JLab Engineering Manager

Design Authority Qualifications• 4 yr. degree in engineering or physics, at

least 5 years experience in design of related pressure systems

or• PE and experience in design of related

pressure systems

or• Approval of JLab Engineering Manager

• Define Pressure System

• Design Authority

• Non-Code Qualified Construction Element

• Peer Review

• Define Pressure System

• Design Authority

• Non-Code Qualified Construction Element

• Peer Review

If ASME Can’t be Applied

• Define Pressure System

• Design Authority

• Non-Code Qualified Construction Element

• Peer Review

• Define Pressure System

• Design Authority

• Non-Code Qualified Construction Element

• Peer Review

If ASME can’t be applied we call it a “Non-code qualified construction element”

• A non-code qualified construction element is a construction element where national consensus codes are not applicable because of pressure range, vessel geometry, use of special materials, etc.

If ASME Can’t be Applied

• Define Pressure System

• Design Authority

• Non-Code Qualified Construction Element

• Peer Review

• Define Pressure System

• Design Authority

• Non-Code Qualified Construction Element

• Peer Review

Peer Review is required• Peer Review: Documented

technical review of pressure system engineering design, to be conducted by at least one qualified independent (outside Jefferson Lab) design professional (i.e. professional engineer) or organizational peer group comprised of at least one technical representative meeting the qualifications for Design Authority who was not involved as a participant, supervisor, technical reviewer, or advisor in the work being reviewed.

Global Issues

Peer reviews and qualification of non-code qualified construction elements can be time consuming and expensive.

Issue #1• Are peer reviewed non-code qualified

construction elements (i.e. designs) acceptable between labs? Can they be used by other labs without further review?

• Should what constitutes a peer review be standardized across the labs?

• Can this also work for component qualification per ASME procedures?

Peer reviews and qualification of non-code qualified construction elements can be time consuming and expensive.

Issue #1• Are peer reviewed non-code qualified

construction elements (i.e. designs) acceptable between labs? Can they be used by other labs without further review?

• Should what constitutes a peer review be standardized across the labs?

• Can this also work for component qualification per ASME procedures?

Issue #1 Cont., Peer Reviewed Items

If we accept these elements across the labs what else should be considered?

– Is a database for new materials and their properties needed?

– Are material testing results accepted by all labs?

– Can DOE help by funding 3rd parting testing that would provide acceptable Office of Science-wide testing services (i.e. results acceptable to all labs)?

If we accept these elements across the labs what else should be considered?

– Is a database for new materials and their properties needed?

– Are material testing results accepted by all labs?

– Can DOE help by funding 3rd parting testing that would provide acceptable Office of Science-wide testing services (i.e. results acceptable to all labs)?

Issue #2, Movement Between Labs

Issue #2• Can designs using “non-code qualified

construction elements” or non-ASME stamped vessels be moved between DOE labs without further review? Points to consider are:

– Local codes may be different between sites

– Are the different lab programs uniform enough to provide a consistent product?

– Are internal peer reviews by the “home lab” equivalent to the “receiving lab”?

Issue #2• Can designs using “non-code qualified

construction elements” or non-ASME stamped vessels be moved between DOE labs without further review? Points to consider are:

– Local codes may be different between sites

– Are the different lab programs uniform enough to provide a consistent product?

– Are internal peer reviews by the “home lab” equivalent to the “receiving lab”?

Issue #3, Buying Items

Issue #3• How are labs dealing with procurement of

components where there are no “code shop” vendors that can do the job?

• Example: 12 GeV upgrade klystrons– 3 water cooling circuits at 150 psig,

110 degrees F, low hazard <100kJ

– Non-code qualified copper material

– Vendors not familiar with ASME codes

• JLab resolved with some “careful wording” in the RFP

• Can standard wording be developed to deal with these situations?

Issue #3• How are labs dealing with procurement of

components where there are no “code shop” vendors that can do the job?

• Example: 12 GeV upgrade klystrons– 3 water cooling circuits at 150 psig,

110 degrees F, low hazard <100kJ

– Non-code qualified copper material

– Vendors not familiar with ASME codes

• JLab resolved with some “careful wording” in the RFP

• Can standard wording be developed to deal with these situations?

Issue #4, Foreign Standards

Issue #4• Are US, European and Asian

standards equivalent?– Fermi study concludes that ASME and the

EU law – PED 97/23/EC produce equivalent products. (See PED 97/23 Pressure Safety Code Review Document, Fermi National Accelerator Laboratory, Dec 20, 2007, P. Hurh, et. al.)

Issue #4• Are US, European and Asian

standards equivalent?– Fermi study concludes that ASME and the

EU law – PED 97/23/EC produce equivalent products. (See PED 97/23 Pressure Safety Code Review Document, Fermi National Accelerator Laboratory, Dec 20, 2007, P. Hurh, et. al.)

What do we need?

I propose that Office of Science-wide guidance on these issues could be helpful in resolving them in a uniform fashion saving money, producing safe and acceptable products, allowing innovation and research to proceed and further enabling lab-to-lab collaboration.

I propose that Office of Science-wide guidance on these issues could be helpful in resolving them in a uniform fashion saving money, producing safe and acceptable products, allowing innovation and research to proceed and further enabling lab-to-lab collaboration.