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Interpretation of the Code, Section VIII, Division 2

Interpretation of the Code, Section VIII, Division 2

Interpretation of the Code, Section VIII, Division 2

(OP)
My company is in the process of procuring at new pressure vessel that with be classified under Section VIII, Division 2. We are developing our UDS and the engineer we are working with insists that a quick-actuating, quick-opening closure is a Code requirement and a mandatory feature in every new design. The vendor we are working with does not agree and sites this requirement as a significant factor in the final cost. My understanding is that the Code is applied when features such as a quick-actuating closure are part of the design concept as required by the customer for safety or other reasons. Is this the correct understanding of how the Code is to be applied?

RE: Interpretation of the Code, Section VIII, Division 2

I am a little confused. Are you asking whether a quick-acting closure is mandatory for each and every Div 2 vessel? The answer to that is no. If, on the other hand you choose to incorporate a quick-acting closure (in my career, less than 1% of vessels have this feature) then, yes, you need to follow the ASME Code rules for them.

Sounds like you need a better engineer assisting you with your UDS.

RE: Interpretation of the Code, Section VIII, Division 2

(OP)
Thanks for your response. That is exactly what this engineer is saying. Even after I quoted to them from the Code:

ASME BPVC Sect VIII, Division 2, Part 1, General Requirements:

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1.1.1 INTRODUCTION
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.
.
1.1.1.2 The Code does not address all aspects of these activities. Those aspects that are not specifically addressed should not be considered prohibited and shall be addressed by appropriate engineering judgment. Engineering judgment shall be consistent with the philosophy of this Division, and such judgments shall never be used to overrule mandatory requirements or specific prohibitions of this Division.
1.1.2 ORGANIZATION
.
.
.
1.1.2.2 Mandatory and non-mandatory requirements are provided as normative and informative annexes, respectively, to the specific Part under consideration. The Normative Annexes address specific subjects not covered elsewhere in this Division and their requirements are mandatory when the subject covered is included in construction under this Division. Informative Annexes provide information and suggested good practices.
1.1.2.3 The materials, design, fabrication, examination, inspection, testing, and certification of pressure vessels and their associated pressure relief devices shall satisfy all applicable Parts and Normative Annexes shown above in order to qualify the construction in accordance with this Division.
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There are two statements in this section that, to me, clearly show the intent of the Code. Paragraph 1.1.2.2 ("...their requirements are mandatory 'when the subject covered is included in construction' under this Division....") and 1.1.2.3 ("...shall satisfy all 'applicable' Parts and Normative Annexes...") are clear that the applicable Parts of the Code are applied when they are incorporated into the design and construction of the pressure vessel. Therefore they would only be requirements, if they were levied by the user (in the UDS) and/or incorporated by the manufacturer as part of the design/construction.

RE: Interpretation of the Code, Section VIII, Division 2

Simple advice: ditch this engineer. They absolutely don't know what they are talking about. You, on they other hand, are on the right track.

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