API Electronic Balloting Template/Version April 2003 s1

API Ballot Comments and Resolution Ballot: 653-232 Rev0- Add Suitability for Proposal: Allow suitability for service or rerate as an option for Ballot ID: Date: June 1, 2018 Service to Acceptance of Existing Welds existing welds that are not acceptable to the as-built standard. 1661

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Voter Name Clause No./ Type of Comment (justification for change) by the Voting Member Proposed change by the Voting Comment Resolution (Vote) Subclause Comment Member No./Annex (e.g. 3.1)

Steven Adolphsen 4.3.8 Technical Negative comments: I suggest: change “… deterioration of the existing CBI Services 1. Was the last sentence of the current 4.3.8 welds… “ to read “ .. deleted or just unintentionally omitted? (NonVoter) deterioration of the surfaces of 2. I agree with the concept of the proposal, but existing welds, such as corrosion it creates another issue. I think the original intent was or pitting, must be …”. to require a visual inspection of all shell welds and any surface defects detected be repaired. The proposal, as written, can be interpreted by a regulator to mean that the entire weld, not just the surface, be checked. This could mean 100% UT or X-Ray of all shell seams to meet this wording. Douglas Miller 4.3.8 Editorial While the suggested addition of API 579 offers added “”” …. Using CRITERIA from flexibility, in the end meeting 653 or 579 should be either this standard or API 579 Chicago Bridge & required. The word “guidance” makes it seem like and ….” Iron there is no required conformance to anything. Company(CB&I) (Affirmative) Douglas Miller 12.2.2 Editorial Recommend slight rewording so that it reads clearly If the existing welds do not that a satisfactory result from a suitability for service satisfy the as-built standard, a Chicago Bridge & evaluation is required. Not enough to just DO the fitness for service evaluation may Iron evaluation. This is obvious of course, but it’s better if be performed per API 579. If the Company(CB&I) the words are clear. welds are not acceptable by any (Affirmative) of these methods, they shall be repaired. W. Clay White general Technical no comment (approve) ConocoPhillips (NonVoter) John Ludman 12.2.2.2 Technical The wording for assessing known defects in welds should be "must" not "may". There is direct DuPont contradiction between the wording found in 4.3.8 and Engineering 12.2.2.2. The flip/flop between must and may is (Negative) glaring between the two sections Donald Comire 4.3.8 Technical Some typical shell butt-weld flaws and recommended procedures for repairs are given in 9.6. (Is this page 1 of 6 API electronic balloting template/version April 2003 API Ballot Comments and Resolution Ballot: 653-232 Rev0- Add Suitability for Proposal: Allow suitability for service or rerate as an option for Ballot ID: Date: June 1, 2018 Service to Acceptance of Existing Welds existing welds that are not acceptable to the as-built standard. 1661

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Eastman statement remaining in 4.3.8 or being eliminated by the Chemical agenda item? I think it should remain.) Company (Negative) Donald Comire 12.2.2.2 Technical 12.2.2 Acceptance Criteria for Existing Shell Plate to Shell Plate Welds. (First, the Agenda Item appears to Eastman have one too many "2's" in the paragraph number. Chemical Second, I think this paragraph ought to point to the Company sources of information to either repair such as 9.6, or (Negative) to service evaluate such as RP-579. As it reads currently, it seems vague and open to much un- educated interpretation) Joel Andreani Technical API 579 reference is now API 579-1/ASME FFS-1 Equity Engineering Group, Inc. (Affirmative) Tearle Taylor Ballot item Technical Current 4.3.8 is a visual inspection and discussed Add Weld defects in 4.3.8 deterioration and pitting not a weld defect that is found Flint Hills by RT, UT or MT. When NDE is used there are specific Resources guidelines for acceptable and rejectable. Need to make some statement in (Negative) regards to paragraph 9.6 or change it, otherwise the code Should "flaws" be weld defects or should weld defects loses credibility when it comes to be mentioned in 4.3.8 to clarify your position. NDE.

In API 579 FFS, typically “indications”, lack of fusion, Define the suitability for service IP, slag and other planar type defects are treated as evaluation for weld defects prior cracks in API 579. This is usually a conventional to changing the code stating to hypothesis because the stress intensity is higher at the perform the suitability for service crack tip due to the sharp edge. These will fail in the evaluation. CTOD test.

of 6 API electronic balloting template/version April 2003 API Ballot Comments and Resolution Ballot: 653-232 Rev0- Add Suitability for Proposal: Allow suitability for service or rerate as an option for Ballot ID: Date: June 1, 2018 Service to Acceptance of Existing Welds existing welds that are not acceptable to the as-built standard. 1661

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There is nothing definitive in API 653 to suggest how to perform a suitability for service evaluation on weld defects that are found.

Depending on the type of defects found a 0.7 joint efficiency could be very liberal. There is no calculation to obtain a proper joint efficiency if a weld has defects or the type of defect, length, number etc.

The current 12.2.2.2 if the weld is not per current code you can evaluate to the old code and if it doesn’t pass then repairs are required.

Nelson Acosta Para. 4.3.8 Technical While I understand the intent of the item, I believe the 4.3.8 ...." and, if necessary, use of the term "rerated" can be misleading in this appropriate repair procedures HMT Inspection context as we are dealing with ASTs and not pressure established, or the tank safe fill (Negative) vessels. height should be re-assessed. Nelson Acosta Para. Editorial The term "as built" as used in this text addition should 12.2.2.2 ..." welds may be 12.2.2.2 be hyphenated. evaluated according to the as- HMT Inspection built standard." (Negative) John Grocki Other I am not technically competent to comment on this item. Industeel (Abstain) Eric Ellis 12.2.2.2 Technical If the existing welds are also Acceptance unacceptable to the as-built LyondellBasell Criteria for standard, the welds shall be Industries Existing For 653-232 12.2.2.2 we would like to see the second repaired or a suitability for (Affirmative) Shell Pl MAY should be changed to SHALL. Normally its seen service evaluation performed. as fitness for service rather than suitability but either one is acceptable. page 3 of 6 API electronic balloting template/version April 2003 API Ballot Comments and Resolution Ballot: 653-232 Rev0- Add Suitability for Proposal: Allow suitability for service or rerate as an option for Ballot ID: Date: June 1, 2018 Service to Acceptance of Existing Welds existing welds that are not acceptable to the as-built standard. 1661

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Takayasu Tahara API579 Technical API579 was revised on 2007 Please change to API579- 1/ASME FFS-1, 2007 Petroleum Association of Japan (NonVoter) Roy Schubert Technical Comments forwarded to David Wang and his vote will represent Shell Canada Energy Shell Canada Energy, Ltd. (Abstain) Bhana Mistry Technical Accpted as presented. TIW Steel Platework, Inc. (NonVoter) David Martinez Technical Approved as written. Western Refining Yorktown, Inc (NonVoter) page 4 of 6 API electronic balloting template/version April 2003 API Ballot Comments and Resolution Ballot: 653-232 Rev0- Add Suitability for Proposal: Allow suitability for service or rerate as an option for Ballot ID: Date: June 1, 2018 Service to Acceptance of Existing Welds existing welds that are not acceptable to the as-built standard. 1661

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John Mooney 12.2.2.2 Technical Should be 12.2.2 (too many twos) (Affirmative) John Reynolds 4.3.8 Technical "must" is not an appropriate API standardization term. Change "must" to "shall". (Affirmative) John Reynolds 12.2.2.2 Editorial Simply new requirement to one sentence. "If the radiograph of an intersection between a new and (Affirmative) old weld detects unacceptable welds by the current applicable standard, the existing welds may be repaired or evaluated according to the as built standard or appropriate fitness-for-service analysis." Alan Watson 12.2.2 Editorial 12.2.2.2 Should be 12.2.2 A.R. Watson, USA (Affirmative) Mark Baker 4.3.8 Technical 1) Editorial – I believe the use of defect is appropriate The condition of the tank shell instead of flaw or nonconformance. welds shall be evaluated for Baker Consulting suitability for service. Any Group, Inc. 2) Technical - As written, the tank must be evaluated defect or deterioration of the to API 653 or API 579. There are many other (Negative) existing welds shall be evaluated recognized industry procedures for fitness for service using an appropriate suitability evaluations and I feel that this standard should not for service procedure and, if exclude those procedures. necessary, appropriate repair procedures established or the tank rerated. Mark Baker 12.2.2.2 Editorial The word “may” in the last sentence should be If the radiograph of an replaced with shall. As written, doing nothing is an intersection between a new and Baker Consulting option. old weld detects unacceptable Group, Inc. welds by the current applicable (Negative) standard, the existing welds may be evaluated according to the as built standard. If the existing welds are also unacceptable to page 5 of 6 API electronic balloting template/version April 2003 API Ballot Comments and Resolution Ballot: 653-232 Rev0- Add Suitability for Proposal: Allow suitability for service or rerate as an option for Ballot ID: Date: June 1, 2018 Service to Acceptance of Existing Welds existing welds that are not acceptable to the as-built standard. 1661

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the as-built standard, the welds SHALL be repaired or a suitability for service evaluation performed.

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