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I need help clarifying if this is a pressure vessel/fitting

I need help clarifying if this is a pressure vessel/fitting

I need help clarifying if this is a pressure vessel/fitting

(OP)
I'm in the US, and tasked with analyzing a heat exchanger for use in Canada, and new information has me questioning if this indeed qualifies as a PV or a fitting. The customer came to us needing us to analyze a heat exchanger to ASME codes because he was told it counts as a "Pressure Fitting" under Canadian codes. They've sold these in the US with no issues. I think I've found wording that would exempt it, but if anyone out there is familiar with Canada, specifically Ontario, I'd appreciate some thoughts.

Both fluids in the attached diagram are oils near or above their flash points. I've been told the 55psi figure is the max pump pressure. The thermostat sends fluid through the heat exchanger when the orange fluid temp gets too low.

https://www.ontario.ca/laws/regulation/010220

I think my biggest question is does pump pressure count as an actual pressure? On one hand it seems like pressure is pressure, so design for that pressure. On the other it feels to me than an important aspect of boilers and pressure vessels in general is that they're closed from atmospheric pressure. Fittings are used with pressure vessels, boilers and pipes, and those three things imply being closed off from atmosphere.

2.2.q & 2.2.r are also interesting. The capacity of this thing is only around .75 ft^3, but how do I judge/declare this to be "not a fitting". And would that mean that no analysis is required, or is there another code that would then apply to this?

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