Michigan U-stamp

[Duwe6]

Anybody done business in Michigan? We are being offered a new vessel fabricated in 'the manner of ASME VIII' but without the "U"-stamp or National Board listing. My reading of the posted MI laws regarding pressure vessels [vs. Boilers] is that MI does not regulate vessels. We are thinking of buying this unstamped vessel and installing it in MI, with proper PRV protection, etc. Will this 'fly' in the state of Michigan?

 

[metengr]

Ask the Chief Inspector, Mark Moore directly.

 

[Duwe6]

small correction - per MI website:

Boiler Division
William Vallance, Chief
Mark Moore, Assistant Chief
Steve Ayotte, Senior Inspector

 

[weldtek]

Duwe6,
You may already be aware, but you can access his contact info from the National Board webpage, under NB Members.

 

[Duwe6]

Interesting - per the NBIC website, Mark Moore is listed as "Chief Inspector".

 

[metengr]

Yes, because Bill Vallance joined the National Board last year and is our Secretary for NBIC Part 3 R&A.

 

[Duwe6]

OK - got an immediate response from MI Boiler Dept: State has no rules/regulations for pressure vessels. Only 'good engineering judgement' is necessary. The City of Detroit has some rules, but we don't need to go to Detroit.

NOTE: entire Boiler Dept was closeted in meeting when I called, so I left a message. About 1-hour later I got a response. It doesn't get any better than that!

 

[racookpe1978]

Provided you design it safely using YOUR specific and credible engineering knowledge agaisnt all of the unknown hazards that will be operating the PV over time.

Stay safe.

 

[JStephen]

You might check if any insurers involved or OSHA would require the stamp.

 

[Duwe6]

OSHA = PHA + RAGAGEP

PHA - Process Hazards Analysis [ includes PRV sizing ]
RAGAGEP - Regularly & Generally Accepted Good Engineering Practices.

For this item, it means use ASME rules to design and fabricate the vessel, and perform In-Service Inspx per API 510*. There aren't any other "Regularly & Generally Accepted" rules for design or In-Service [as-corroded] evaluations in the USA.

*I left out Nat'l Board because it has very few things to say about evaluating vessels [vs. boilers]. API-510 is the opposite; lots about vessels, not much on boilers.

 

[TGS4]

...use ASME rules to design and fabricate the vessel...

Can this be accomplished without a U-stamp? Don't the rules ASME BPVC require the application of the stamp at the completion?

 

[metengr]

TGS4;

Can this be accomplished without a U-stamp? Don't the rules ASME BPVC require the application of the stamp at the completion

Yes. Fabrication to Section VIII, Div 1 without a stamp and AI involvement is done. The rules do not require the application of the stamp unless it is stated in the contract for build.

 

[TGS4]

Fair enough. And if something goes wrong with this, resulting in an investigation from the CSB, or even worse, a lawsuit, would the "other side" be able to find an "expert" that would say that you didn't meet RAGAGEP because it wasn't U-stamped?

Just want to ensure that everything is covered here.

 

[Duwe6]

Of course the "other side" could find an 'expert' to say that. In case you havn't noticed, in US jurisprudence, both parties can always find an 'expert' to say that the other side made "terrible, unconsiable mistakes and grievous errors". For a large fee, there is testimony available - either way.

Bottom Line: if there is a problem that happenes inside your fince, and it causes injury, you will be held liable. Doesn't matter if you are blameless, if the act was done against your rules, if the act was done by a bonded contractor, or even a tresspasser -- you are liable.

 

[jte]

For a large fee, there is testimony available - either way.

Indeed! I hear some consulting firms have a - shall we say "different"? - rate sheet when legal issues are involved.

Not at all uncommon to see the "design and fabricate but do not stamp" clause. As already stated, ASME has no authority as to when, or if, the BPV is implemented. In some cases I advocate against a U stamp (generally when one is proposed for a vessel which is out of scope), but in general for vessels in scope I prefer to see a U stamp. Note the word "prefer" as I try to keep in mind that in my role I make recommendations to my company's facilities, I have no direct control authority to mandate anything.