These Technical Questions and Responses have been collected by ABSA Design Survey and have value to
prospective submitters for clarification on processes, general policies, and some specific scenarios for design submissions. The following Technical
Questions and Responses are related to piping registration requirements.
1. Questions regarding piping systems less than 500 Litres and registration requirements
1.Q1. What piping does one have to consider when checking for the ≤ 500 L (≤ 0.5 m3) volume exemption from design registration that is provided for in section 14(6)(a) of the Pressure Equipment Safety Regulation?
1.R1. The piping volume to be considered is the internal volume of the piping carrying an expansible fluid at a design pressure > 103 kPa that is not exempted by section 4(2) of the Pressure Equipment Safety Regulation (PESR). Non-expansible fluid piping need not be considered.
1.Q2. Does the ≤ 500 L (≤ 0.5 m3) volume exemption from design registration that is provided for in section 14(6)(a) of the Pressure Equipment Safety Regulation include attached pressure vessels or heat transfer apparatus such as air-cooled heat exchangers?
1.R2. No, only the piping volume needs to be considered.
1.Q3. A flange pair is to be inserted into an existing registered plant piping line to facilitate maintenance. Does this change to the piping require a design registration submission?
1.R3. No design registration would be required because this piping change would involve less than 500 L of piping volume. See PESR section 14(6)(a). Section 14(6)(a) applies to modifications and additions to existing registered or non registered pressure piping systems as well as to new pressure piping systems.
1.Q4. A small amount of new piping (< 500 L internal volume) is to be added to an existing registered pressure plant. Does the exemption from design registration in 14(6)(a) of the Pressure Equipment Safety Regulation apply to the new piping or to the entire system?
1.R4. The exemption applies to the piping being added.
1.Q5. New piping of < 500 L internal volume is being added to an existing unregistered pressure piping system (exempt because of its small internal volume) and the resulting aggregate internal volume will exceed 500 L. Does this pressure piping system now require design registration?
1.R5. No. Section 14(6)(a) of the PESR applies to an addition to an existing non registered pressure piping system. It is not applied retroactively to the existing non-registered piping.
1.Q6. An engineering company has been engaged to design an addition to a small previously unregistered pressure plant facility. Because of its size (< 500 L contained volume in the piping) design registration was not a requirement for the original plant. The addition is of a size that is required to have its design registered. Must the original plant design be registered along with the new addition? No AB-83 Pressure Piping Construction and Test Data Reports are available for the existing plant.
1.R6. Unless the engineering company is prepared to assess fully the current condition of the pre-existing piping, to ascertain what specifications the piping materials are, to prove compliance with the code of construction, and is prepared to apply a professional engineer’s stamp to the reverse-engineered design of the old piping, registering the old piping would not be feasible. It would be desirable to include with the design registration package for the addition any design data that may be available for the old piping for information only.
5. Questions regarding non-expansible fluids in piping
5.Q1. Must the piping system containing water for fire suppression purposes in a pressure plant be registered as part of the plant piping?
5.R1. A pressure piping system is defined as “… pipes … for the conveyance of an expansible fluid under pressure …” in the PESR, section 1(1)(aa). Since fire water is a non-expansible fluid [see PESR section 1(1)(l) for the definition of expansible fluid], the fire water piping system design need not be registered.
5.Q2. Must the piping system in question 1 be built to ASME B31.3, Process Piping?
5.R2. Since piping in non-expansible fluid service is not subject to the PESR, ABSA has no mandate to establish what code to build such piping to. Certainly B31.3 would not exclude ambient temperature water service from its scope, but there may be other standards that might also be applicable.
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7. Questions regarding pneumatic or other alternate test of pressure piping
7.Q1. Is it required to register all pneumatic test procedures through ABSA’s Design Survey Department?
7.R1. Not all pneumatic test procedures must be registered through Design Survey. Per section 30(1) of the PESR, “(a)ll pressure piping leak tests must be conducted using the hydrostatic method.” Section 30(2) goes on to say that “(d)espite subsection (1), the Administrator may accept, for a specific pressure piping system, alternative test methods that are allowed in a code or standard that is declared in force.” The Administrator has designated the power to accept an alternative test method (read "pneumatic test") to some safety codes officers subject to certain conditions. If the safety codes officer in the field has been delegated the power to accept a pneumatic test procedure, he or she may be able to authorize a pneumatic test for a specific pressure piping system without involving Design Survey. Otherwise, he or she will require the testing organization or the owner of the piping to be tested, as appropriate, to submit the pneumatic test procedure to Design Survey for registration. Other alternative test procedures must be registered by Design Survey for the specific pressure piping system.
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9. Questions regarding piping undertolerance
9.Q1. May the 12½% mill undertolerance be used as corrosion allowance on pressure vessel parts made of pipe? The pressure vessel is designed in accordance with ASME Section VIII, Division 1.
9.R1. No, the mill undertolerance must be taken into account except for nozzle wall reinforcement area requirements in accordance with UG-37 and UG-40 where the pipe nominal wall thickness (in the fully corroded condition) may be used in the calculation of A2, the area available in the nozzle wall. Note that, if the vessel shell is made of pipe, the undertolerance must be taken into account in the calculation of A1, the area available in the shell, at the location where a nozzle opening exists. Ref. ASME Section VIII, Division 1, paragraph UG-16(d).
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10. Questions regarding fired heater coils
10.Q1. May the coils in a fired heater be designed and built to the ASME B31.3, Process Piping code?
10.R1. No. Figure 300.1.1, Diagram Illustrating Application of B31.3 Piping at Equipment, in ASME B31.3 specifically excludes “tubes, tube headers, crossovers and manifolds of fired heaters, internal to the heater enclosure” from the scope of ASME B31.3. ABSA interprets this to apply to any such tubular components inside the refractory of the heater. Components outside the refractory may be designed and built to B31.3.
11. Questions regarding gas lines for the purpose of fuel
11.Q1. Is it the responsibility of ABSA to determine the fuel gas line registration requirements?
11.R1. . In accordance with STANDATA G-03-11-ABSA, under "Pressure piping system at plant site" first paragraph, 'ABSA will be responsible for the design review and registration... when the design and installation procedures have been submitted for registration with ABSA'. Although the wording here may not be as explicit as the IB10-006 for steam pipelines, the meaning is the same, i.e. (from IB10-006) "it is the responsibility of the owner and the designer to determine which pipelines require design registration and compliance with this Directive". Likewise, for fuel gas line, it is the responsibility of the owner and the designer (not ABSA) to determine which fuel gas lines require design registration.
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Updated Jan 31, 2012