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NBIC decrease heating surface considered an alteration?

NBIC decrease heating surface considered an alteration?

NBIC decrease heating surface considered an alteration?

(OP)
Hello, So in the NBIC Part 3, Examples of Alterations 3.4.3 (d) states that a change in the dimensions or contour of a pressure retaining item constitutes an alteration. (e) states that In a Boiler, an increase in the heating surface or steaming capacity constitutes an alteration.
My question is; If in a fossil fuel boiler, one plugs a tube at a drum or header, and removes the now unused tubing from the boiler, is that considered an alteration? By the same logic, would shortening a loop or bend also be considered an alteration?

RE: NBIC decrease heating surface considered an alteration?

Yes

RE: NBIC decrease heating surface considered an alteration?

(OP)
NBIC interpretation 95-35 question 1 is: "Is the welding in of a plug to seal tubes of a boiler or pressure vessel considered a repair"
Answer: Yes
Why is this a repair and not also an alteration?

RE: NBIC decrease heating surface considered an alteration?

The method of tube plugging is a repair. Removing a plugged tube is not an alteration. It is outside the scope of the NBIC because it is a performance issue. De-rating, as in your case, is a Jurisdictional issue and is not addressed by the NBIC.

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