U-Stamp or Repair? 1

[ehouston69]

We have a tube bundle built by another manufacture. We did the fabrication on the shell and channel. While installing the bundle 6 tubes were damaged. These tubes were replaced, by us, with new tubes like in kind.
The bundle will be installed in our shell and hydro tested as a full exchanger. Does the replacement of the new tubes have to go as a Repair and fill out an R-1 form? Ive spoken with our A.I. and he said he could sign off on an NCR and look at it the same as if it were an expansion joint etc. as long as we had the NCR and original Manufactures Data on the bundle (which we do). We could then Stamp the Unit as a complete exchanger. The client is under the impression that the work on the bundle has to be a Repair. What says you?

 

[metengr]

It would be handled as an NCR during construction. Once the heat exchanger is stamped and complete it falls under the NBIC or other code.