New Process for Managing Non-Code Pressure Vessels Creates NASA Standard
NASA-STD-8719.26A, NASA Requirements for Ground Based Non-Code Metallic Pressure Vessels went into effect May 11, 2021. This standard is intended to manage risk to personnel, facilities, missions and the environment posed by the use of existing ground-based, non-code metallic Pressure Vessels (PVs) that either 1) do not comply with applicable American Society of Mechanical Engineers (ASME) code requirements specified in Occupational Safety and Health Administration (OSHA) 29 CFR pt. 1910 regulations or 2) were modified and no longer comply with the code.
“This document gives us a process for continued use of non-code pressure vessels in NASA operations and it ensures the safety of our employees,” said Clifton T. Arnold, Office of Safety and Mission Assurance (OMSA) program executive for Pressure Systems. “We presented this standard to OSHA earlier this year and they came back with glowing remarks stating our methodology was solid, and OSHA fully supports the development and implementation of NASA STD 8719.26. Every technical detail and procedural process met or exceeded OSHA’s expectations and fulfills the guidance provided by OSHA Letters of Interpretation.”
When possible, all NASA centers and facilities work diligently to comply with ASME code requirements mandated by OSHA. However, many of NASA’s ground-based PVs were designed and fabricated years prior to the development of the OSHA regulations.
“Unfortunately, OSHA does not grandfather pressure vessels,” said Arnold. “So, there are a number of pressure vessels in our NASA inventory that do not meet the OSHA requirements for ASME code construction and design.”
This NASA technical standard provides uniform engineering and technical requirements for processes, procedures, practices and methods that OSHA endorsed as standard. It also includes requirements for the selection, application and design criteria of ground-based PVs that do not, or cannot, comply with all applicable OSHA 29 CFR 1910 regulations.
NASA-STD-8719.26 applies to two classifications of PVs:
- Non-code metallic PVs: PVs that do not comply with the original applicable ASME construction code, including PVs that were fabricated from non-code materials by non-code processes or organizations.
- Ground-based Layered PVs (LPVs): Metallic PVs that have a shell and/or heads made up of two or more separate layers.
“This standard requires that centers and facilities verify the structural integrity and fitness-for-service of agency non-code pressure vessels following the well-established methodologies of ASME Boiler and Pressure Vessel Code; API 510, Pressure Vessel Inspection Code: In-Service Inspection, Rating, Repair, and Alteration; and API 579-1/ASME FFS-1, Fitness-for-Service,” said Calogero DiRienzo, OSMA Pressure Systems delegated discipline lead.
NASA has performed extensive investigations, analyses, materials data development and Non-Destructive Examination (NDE) research, along with methods development and qualification for non-code metallic PVs not currently addressed by API 510 or API 579-1/ASME FFS-1, such as NASA’s fleet of ground-based LPVs.
“The Agency LPV Risk Mitigation Team is also working to produce technical memorandums and a Pressure Systems Manager Handbook that will be released the second quarter Fiscal Year 2022,” said Brian Stoltz, OSMA LPV risk mitigation project manager. “These documents will focus on specific discipline areas and provide detailed material properties, structural analysis and NDE methods required to qualify LPVs fit for operation.”
For more information about this standard, contact Clifton Arnold.