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Section I Thermal Oil Heater Quagmire!

Section I Thermal Oil Heater Quagmire!

Section I Thermal Oil Heater Quagmire!

(OP)
Per customer's desires, We built a Single Helix Helical Coil, Thermal Fluid heater.  Stamped "S" Under authority of Section I, Paragraph PG-2.4.

AI will not sign the P-2 because the PRV calc's were not done by us, the PRV's were not specified, ordered, received, inspected, and supplied by us.

If we built the SAME heater under Section VIII, Div. I, all
PRV related actions are NOT in our scope of supply and we stop at the heater's inlet and outlet flanges.  We only submit a U-1 Data Report and don't mention PRV's on it.
THE OWNER handles PRV's.

If we build and stamp under Section I (Power Boilers), we have to submit a P-2 Data Report, accompanied by a P-7 completed with PRV information.

On this job, we used Section I, Para. PG-16.1, Lines 7 thru 12 and lines 13 and 14, to justify ALL PRV related actions being done by the owner, except completing the P-7, just as we do on a Section VIII heater.  We obtained enough info on the PRV's from the owner to complete the P-7 Data Report.  Meeting the "appropriate use of other design codes" and "as safe as" requirements of PG-16.1, we felt was the most suitable path to take to build and register this heater (NOT A POWER BOILER) under Section I.

The fact that Thermal Fluid Heaters need PRV's with a Capacity in Liquid Units where Power Boilers have PRV's with Capacity in Vapor Units, further clouds the issue.  Section VIII Appx. 11 is the only place I know of where a method of conversion is defined.

Has anyone seen this situation arise before?  How was it handled?  

The AI's stance is that the PRV's that were sized and obtained by the owner, are incorrect.  The owner emailed us pictures of the PRV Dataplates.  The dataplates are stamped "SUP STM."

Our preference is that the AI allow the owner to be responsible for specifying, obtaining, and correctly installing the PRV's as per Section VIII, loosely permitted under Section I, PG 16.1.

What do you folks think?

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