NBIC repair or SECT 8

[DCMV]

We have a new exchanger bundle built to Sect8 Div1 by an out side supplier, there are two nozzles with pup piece welded on each. We the contractor will weld a new flange to one pup piece and a spool piece consisting of a 90 and flange to the other pup piece. My thought is that this would require a Part stamp and U2 form. The owner user is calling this a NBIC Repair. I'm I correct or is it a NBIC repair??

 

[metengr]

Was the heat exchanger bundle completed - hydrostatically tested, stamped and signed data report? If so, the added work would be under the NBIC, meaning an R-Certificate holder would do this work with ASME parts. If the bundle has not been completed, the work would be under ASME Section VIII, Div 1 scope with parts and data report.