Letters

Thanks for your comments ["Storm Warning," September, p. 6] and attempt to bring some type of forum to discuss the matter of overseas outsourcing of technical and, in many cases, patent and security sensitive work. What do you think can really be done?

Many engineers and IT people cannot bring themselves to think of "organizing" or "unionizing" for the collective good. But they have never faced the wholesale onslaught of job losses. Literally, whole generations of technical staffs could be wiped out in the U.S.

Would a "services" tariff similar to a "goods" tariff be the answer for outsourced foreign services that are brought back into the U.S.? There are a lot of issues to deal with when people talk of tariffs. If I recall, 60 Minutes had a story on someone who was downsized after training the very people who replaced him. He's now running for Congress in Florida.

I am aware that some of the major E&C contractors who set up the job shops have been marketing engineering consulting, design and drafting services for $25/hr. Of course, it is obvious that the work is going offshore.

But do keep up the dialogue. It will be critical to see how the professional societies and technical trade groups try to address these matters, since, sooner or later, they stand to lose lots of dues-paying members.

The editorial ["Plant Security: the Calm Before the Storm," September, p. 9] referred a number of times to Sal DePasquale, and identified him as "chief architect of the CCPS methodology." As the Director of the Center for Chemical Process Safety (CCPS) and organizer of the project to develop the CCPS Security Vulnerability Analysis methodology, I am compelled to clarify Sal DePasquale's role and offer some important contextual information.

A number of very well-qualified individuals made significant contributions to the CCPS methodology. More than two dozen additional individuals contributed critical review, personal experience, comments, and reality-checks. I believe the number of people involved in this process demonstrates the strength of the CCPS methodology, and it is appropriate to recognize all of the contributors. By furthering our collaborative work across industry lines, CCPS continues to address the critical importance of chemical plant security to our sponsors and the communities in which they exist.You and your readers may request a copy of the CCPS SVA at http://www.aiche.org/ccps/sva

A number of statements in ["Crack the Code," September, p. 46] I believe to be inaccurate, misleading, and/or unsafe. On page 47 of the article, for example, it is said that ASME governs the "R" stamp. In fact, the "R" stamp mentioned by the authors is governed by the National Board of Boiler and Pressure Vessel Inspectors.

On page 47 of the article, the authors say that "modifying a Code vessel is generally not recommended, since cutting into a dust collector vessel's shell places that vessel under the same testing and documentation requirements as a brand new Code vessel." In fact, repairs have successfully been made on all types of equipment originally constructed to the ASME Code using procedures outlined in post-construction standards such as the National Board Inspection Code and American Petroleum Institute's publication, API-510. Additionally, NBIC outlines the testing and documentation requirements; some of which are far less stringent that that which was required by the ASME Code at the time of original construction.

On page 47, the authors state that, in order to receive a "U" stamp, the vessel must be filled with water and pressurized to 1.5 times its design pressure. The Code states in UG-99(b) that the multiplier on MAWP is 11/3 x MAWP x the ratio of stress at test temperature to stress at design temperature. To use a multiplier of 1.5 on MAWP could potentially result in the vessel exceeding yield stress of the material, damaging it. Also, while it is recognized that water is the choice for most applications, the Code does not require water to be used.

On page 48 of the article, the article suggests that, "while under pressure, construction materials, welds, accessories and other hardware associated with the vessel must be rigorously checked before approval." This could lead an individual to perform the very unsafe act of closely inspecting a vessel that is under full hydrostatic pressure.

I also take issue with the statement on page 48 that "Many Code vessel manufacturers also produce non-Code dust collector vessels, yet use ASME Code calculations for unusual configurations and/or performance requirements," The Code specifically states that vessels with an external pressure of over 15 psig are included in its scope.

On page 48 of the article, the statement is made, "In certain situations, a properly designed and built Code vessel rated for operation at 14.9 psig positive pressure might be able to handle 25 psig operation in complete safety." The Code requires in UG-21 that vessels shall be designed for at least the most severe condition of coincident pressure and temperature expected in normal operation. A user who operates a vessel at a pressure greater than what it has been certified for could risk the safety of any operator in close proximity to the vessel.

The article was not intended as a detailed compendium on ASME code, but, rather as a primer and resource for engineers lacking Mr. Roberts' detailed knowledge of the Code, to help them interact more effectively with vessel designers, and to consult the code itself faster and more efficiently. It would be irresponsible for any engineer to use such an article as a basis for detailed design work or maintenance.

However, in the process of condensing code material, we regret that some detail was sacrificed, and one error overlooked. As Mr. Roberts notes, the "R" stamp is not governed by ASME but rather by the NBIC.

His comments concerning Code vessel repairs, and use of procedures outlined by NBIC standards and the American Petroleum Institute are also correct; due to space constraints, we did not add this information to the article. We wished to emphasize the idea that design work should be done as carefully as possible, upfront, to minimize the need for repairs and rework, to stress the fact that repairs and rework cannot simply be done in the end user's plant, and to highlight the point that any vessel repairs or redesigns will trigger detailed testing and documentation requirements.

As Mr. Roberts notes, the multiplier on MAWP was changed in the 1999 addenda of the ASME code. We used the correct multiplier for our sample calculation, but failed to correct the number in the actual manuscript, and thank him for pointing this out.

However, we believe that our material stands on its own, and that the balance of Mr. Roberts' comments reflect differences in semantics and interpretation. For many years, Flex-Kleen has designed and built many ASME Code vessels which have performed to specifications without failure. We are impressed with Mr. Roberts' knowledge of the ASME code, and regret that he or any of your other readers may have been either inconvenienced or misled by any material in our article.

We welcome your comments, suggestions, criticism and praise. E-mail us at [email protected]. If you prefer, write to us at: CHEMICAL PROCESSING, 555 W. Pierce Rd., Itasca, IL 60143. Call us at 630/467-1300, or send a fax to 630/467-1124. We reserve the right to edit your comments for clarity and because of space considerations.