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U1 Form vs U2

U1 Form vs U2

U1 Form vs U2

(OP)
All-
I have an in-service non-standard pressure vessel (no National Board Number)with no U1 and no manufacturing drawings.  Per State (jurisdiction ) rules, I cannot weld to the vessel shell.  What I have elected to do is install the new 3" nozzle and riser through a new 16" manway cover.  The manway cover will be bolted to the existing manway nozzle, thus satisfying state requirements.  The new piece is to be registered with the National Board.  The new piece is simply a 3" nozzle welded to and protruding through a 16" 150# manway cover/blind flange.

Question-Does the Section VIII code prevent me from registering this on a U1?  Some manufacturers have said it is a part and thus a U2 from is required.  I do not think the text exists in the code that specifically prohibits this from being registered with a U1.

Additionally, the code requires that a U2 for be attached to a U1 form, which I don't have.  This would make the U2 form out of code.

I am waiting to hear back from a couple of AI's about registering this with a U1.  That would be my preference.  Then I have all my ducks in a row for state requirements.

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