ASME Question?

Dave_4

<I>invalid for the reasons that follow. The BFP and the check valve designed for two disparate purposes and made to accomplish two distinct functions. The check valve required by Section IV, HG-705(a)(b), is intended for the sole purpose of preventing the water in the boiler from being forced out under pressure in the event of a piping break or loss of supply pressure. The backflow preventer is intended for the sole purpose of preventing normally contaminated (undrinkable) water found in the boiler from back-flowing into the potable water system as is required by the plumbing codes.</I>

What genius determined that these are two disparate functions? The description given for operation of the check valve seems the <I>exact</I> function of a backflow preventer with such backflow preventer "required by the plumbing codes" because check valves were determined inferior to backflow preventers.

Then the simple check valve is deemed superior because it has no rubber to melt. Come on... If the check valve is the ultimate protection (as this proposes) then why have the backflow preventer other than for needless complexity and required annual inspection? Here in MO a few years ago a law was attempted that required backflow preventers (and of course annual inspection) on ALL water services. It was nicknamed the "plumber's enrichment act"...

Robert O'Connor_12

ASME Question?

Does anyone have a copy of Section 4 of this ASME Code?
If so, I'm specifically interested in paragraph 705. Apparently there is a FTO (formal technical opinion) dated Jan.,1st 2006 related to this code section that is being interpreted differently than one would "reasonably assume".
The question/regulation/code has to do with the requirement of a back-flow preventer on a boiler. An inspector from the Hartford Insurance Co. wrote:


"Even though this is an ASME approved equivalent for the back-flow preventer, the State of New Jersey code(s) do not accept a back-flow preventer as an acceptable check valve equivalent."


After speaking with this field inspector from Hartford (who was extremely helpful and nice), he is going to fax it over to me but I will not be able to receive it till Tuesday.


Has anyone ever heard of this on a water boiler in a garden apartment type application ( not residential and not really commercial )


Its Friday after 5pm and I'm about 60+ miles away from my office and a good friend is in need before Monday.


Robert O'Connor/NJ

gerry gill

HUH!!

a backflow preventer is a check valve..actually two...least it was the last time i recertified..sounds like that guys wacked..

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Weezbo

open to a thought ?

at one time BFP were known as Anti back flow suppression valves. maybe dude is wigging . if the boiler was on a private well where draw down and vaccum might be a problem in stall a sweat check house side...that will maintain a water pressure on the up stream side of the BFP. or put a ball valve ahead of it and tell the inspector it is part of the maint.and is an isolated system, which is allowed.

Unknown

or u can

Or you can have him pay you for the education for doing his job

Perry_2

ASME Code Cases

You need to be carefull with ASME code case results. Be very carfull to understand the situation behind the code case. Just reading the words without that understanding can get you into trouble (although ASME works to minimize misunderstandings - it usually takes a bit to figure out how to reword a code case and get it into the next version of the code.

Another key here is that the state does not recognize it. Thus, you can't do it legally. There are states that will not recognize the changes in the 2001 code - and want to stay fixed in the 1998 code due to the changes in allowable stresses in materials (reduced in 2001).

Of course, we are now on 2004 code year and the 2007 code will be out in about 5 months.

Perry

Robert O'Connor_12

ASME

Thanks for the responses, and yes, I believe a backflow IS the correct device. The gentleman from Hartford was really cool and too agreed with me, however, he is enforcing an interpreted "opinion" based on the Setion 4, paragraph 705 of these regulations that he is apparently being forced to enforce based on a state higher up (I know his name but not his title YET).

Perry, you stated in another thread that you have these regs., handy??? Any help here would really be appreciated.


Robert O'Connor/NJ

Perry_2

I'll look

I don't recognize what Section IV is off the top of my head.

The plant does not have a full set of ASME code books (all sections); we buy several sets of the sections of interest and have them in different parts of the plant - or plant offices.

We have an Authorized Inspector onsite full time (contracted from one of the major insurance companies, and I believe Hartford). I sit near his office - and the office of another engineer who works on plant related code issues (and between them they have one of the "partial" sets of code books). Design engineering in another building has another "partial" set.

I sent an email to my work, and I'll see if we have a copy of Section IV. If we do, I can look it up for you.

I'll let you know; probably Monday night.

Perry

Robert O'Connor_12

Thank You Perry

See too if there was a Jan 1st interpretation.

Section 4 has to do with boilers & pressure vessels. I'm sure the check valve requirement is there (or is it?)

Thanks again.


Robert O'Connor/NJ

Plumdog_2

Could it be a misprint

that escaped the proofreaders? Maybe the intended wording was: "a check valve shall not be considered equivalent to a backflow preventer".

Robert O'Connor_12

Plumdog

No mis-print, apparently the chief inspector is interpreting something that, well, lets just say shouldn't be.


Robert O'Connor/NJ

Perry_2

Rob:

Sorry for the delay on this. It's been one of those weeks at work, 12 hour days and not even doing what I'm susposed to be doing... Which means I get to catch up next week. Labor day does mean labor dosn't it?

It appears that we do not have a copy of Section IV at the plant.

Sorry

Perry

Rodney Summers

Update

I finally received a fax from the third party "commissioned" inspection agency. The fax includes a section out of the A.S.M.E Boiler Pressure Vessel Code book. The section reads as follows:


Section (roman numeral) 4 Article 7, paragraph HG-705 a & b

HG-705 FEEDWATER AND MAKEUP WATER CONNECTIONS


(a) Steam boilers. Feedwater or water treatment shall be introduced into a boiler through the return piping system. Alternatively, feedwater or water treatment may be introduced through an independent connection. The water flow from the indepentent connection shall not discharge directly against parts of the boiler exposed to direct radiant heat from the fire. Feedwater or water treatment shall not be introduced through openings or connections provided for inspection or cleaning, safety valve, water colum, water gage glass, or pressure gage. The feedwater pipe shall be provided with a check valve near the boiler and a stop valve or cock between the check valve and the boiler or between the check valve and the return pipe system.

(b) Hot Water Boilers. Makeup water may be indtoduced into a boiler through the piping system or through an independent connection. The water flow from the independent connection shall not discharge directly against parts of the boiler exposed to direct radiant heat from the fire. Makeup water shall not be introduced through openings or connections provided exclusively for inspection or cleaning, safety relief valve , pressure gage, or temperature gage. The makeup water pipe shall be provided with a check valve near the boiler and a stop valve or cock between the check valve and the boiler or between the check valve and the piping system.


Now, on to the "Official" INTERPRETATIONS Volume 36 of the ASME Boiler and Pressure Vessel Code SECTION (roman numeral) 4


INTERPRETATION: (RN) 4-95-02


Subject: Section (RN) 4, HG-705(b) and HG-715(c)

File: BC94-353


Question: May a backflow preventer containing a check valve be used to satisfy the requirements for a check valve per paragraph HG-705(b)?


Reply: Yes


Any questions?


POC for the New Jersey State Boiler and Pressure Vessel Compliance is Milt Washington (609) 292-2345



Robert O'Connor/NJ

Mike T., Swampeast MO

Glad you received the appropriate answer!

I found it amazing that an inspector would try to require a simple check valve in addition to the double blackflow preventer. Egads--they have to be certified annually but the never-known-for-long-term-effectiveness check valves sit there for deacades...

Rodney Summers

Mike

Its not what think. They (meaning the States head of the Dept) isn't allowing it. This is why I've been posting this smack. They have whats called "commissioned" inspectors who work for insurance companies and they are bound by what the state says (meaning the ASME regs and this guy). Long story short is that the insurance carrier IS requiring it. I have talked to this gentleman from the insurance company at lenght and he really is a nice guy BUT he says we gotta install the check valve. He told me we can leave the the existing (code compliant BFP) valve were it is. I just have to scratch my head in wonder whats up with the state guy though.

Anyone who knows me can tell you this is just the begining.



Robert O'Connor/NJ

Robert O'Connor_12

ADVISORY?????

specified in this Advisory
BOILER REGULATION ADVISORY

Subject: Use of a backflow Preventer in Boiler Applications


In accordance with the regulatory authority granted by the Boiler, Pressure Vessel and Refrigeration Laws, this advisory is being issued to ensure safety of the general citizenry in the installation, repair and operation of boiler plants which includes the appurtenances, devices, controls or any items that directly or indirectly impacts upon the regulated equipment that could potentially pose a hazard to the public. Specifically this advisory addresses the use of a Backflow Preventer (BFP) in all boiler related applications.


This advisory responds to numerous inquires that have been submitted concerning the position of the Bureau of Boiler and Pressure Vessel Compliance (BB&PVC) on the acceptance of ASME interpretation IV-95-02, future ASME Code addenda regarding BFP, and other written requests for an official determination on the acceptable use of a BFP in boiler applications that fall under the BB&PVC's jurisdiction.


The BB&PVC does not concur with ASME Code interpretation, IV-95-02 and officially declares any future ASME Code addenda allowing such installations as invalid for the reasons that follow. The BFP and the check valve designed for two disparate purposes and made to accomplish two distinct functions. The check valve required by Section IV, HG-705(a)(b), is intended for the sole purpose of preventing the water in the boiler from being forced out under pressure in the event of a piping break or loss of supply pressure. The backflow preventer is intended for the sole purpose of preventing normally contaminated (undrinkable) water found in the boiler from back-flowing into the potable water system as is required by the plumbing codes.


The BB&PVC staff has thoroughly reviewed product information from the manufacturer of a commonly used BFP. According to this manufacturer's documentation and information obtained from their corporate technical staff, their BFP has rubber-to-metal valve internals that would not be able to tolerate an incidental temperature excursion of 250 degrees F without failing. These types of excursions might be experienced by low-pressure boilers during abnormal or malfunctioning conditions and as a result would melt the rubber internal components, which according to the design of the BFP would open the port to the atmospheric vent so as to prevent the undrinkable boiler water from contaminating the potable water supply. When this vent opens it creates an unacceptable event for boiler operation, because the melting internal component in the BFP puts the boiler at risk for dry-firing condition which could result in a catastrophic failure or a boiler explosion.


For obvious reasons, the melting of protective components is not acceptable for safety and contradicts the logical reasoning for the installation of a standard boiler check valve. Acceptable engineering practices requires that the valves, devices, controls and other similar appurtenances or appliances attached to the boiler or that are an integral part of the boiler, be engineered to prevent a catastrophic failure. Clearly, the BFP installed by itself in the potable water supply line to a boiler defeats the practical safety applications meant for the various devices and components used in boiler systems.


The BB&PVC as the jurisdictional authority has determined that the installation of the BFP the way it is presently (#1) engineered, must not be used by itself in the potable water supply line to the boiler as a replacement for the simple design and standard issue metal seated check valve. In addition, when the installation of the BFP is required by the plumbing codes in the potable water supply or makeup line to the boiler, it shall include the standard check valve as the required by the (#2) boiler safety codes and standards. Thus, the required metal seated and standard check valve must be installed downstream of the BFP, and include a shut-off valve next to the boiler and be located downstream of the standard check valve for system isolation and maintenance purposes.


Therefore, in accordance with N.J.A.C. 12:90-4.2(e), where it states that "only standards relating to public safety are adopted by any incorporation by reference as prescribed ect". The BB&PVC has conclusively determined that the ASME Code Interpretation IV-95-02 and any subsequent Code addenda or revisions regarding this Advisory topic is not in the best interest of public safety for boiler operation thus is ruled invalid. Therefore, in accordance with this advisory any standard check valve and shut-off valve found to be installed in any other manner described herein shall be deemed to be in violation of the BB&PVC regulations and the owner will be subject to the monetary per diem penalty assessment until abatement of the violation occurs.


All questions regarding this advisory should be directed to the BB&PVC by calling (609) 292 2921; by email to the Bureau Chief: MiltonWashington@dol.state.nj.us by Fax at (609) 984 1577, or by written request to the address below.



Department of Labor and Workforce Development
Labor Standards and Safety Enforcement
Division of Public Safety and Occupational Safety & Health
Bureau of Boiler and Pressure Vessel Compliance
P.O. Box 392 Trenton, NJ 08625-0392



Signed: Milton Washington
Chief, BB&PVC



(#1) The BB&PVC recognizes that technological advances occur that could address the safety concerns of this Advisory and that improvement in the BFP is possible. However, until advances are made in the design of the BFP to address the concerns expressed, this Advisory shall be enforced and in effect until deemed otherwise necessary.

(#2) See 2004 ASME Code or any earlier code edition of Section IV, "Rules for Construction of Heating Boilers" at paragraph HG-705 for the installation detailed in this Advisory. Until proven otherwise, this Advisory renders paragraph HG-705 of the 2006 ASME Code Addenda and future revisions invalid when the design of the BFP is of the type as specified in this Advisory.


Personally I think the BB&PVC is wrong, and fundamentally cannot do this legally. There has been NO official Code adoption, Nothing has been included in the Registar nor have they responded with any data suporting their position other than alot of mumbo-jumbo as I've written above.


Robert O'Connor/NJ