I totally agree with you that it is legal problem more than engineering. Even, there is no design problem at all.
I will till what we finally decided and please till is this OK or Not.
first of all the vessel is not installed in neither USA or Canda and there is not local jurisdiction which role the installation and repair of pressure vessels.
We convinced the client (Aramco by the way) that we will consider this job as two separate jobs. One for Repair and another for de-rating.
Repair job was 100% as per NBIC code and R stamp is applied.
De-rating job is as per API 510 and there is no involvement of NBIC.
Summary;
The vessel stamp is still valid since we are operating the vessel not beyond the limit of the vessel rating. After repair the vessel still can work at the original pressure temperature rating. However, the User decided to operate it at lower values. Original ASME Nameplate still shows the original rating. another nameplate (not stamped) will be attached near to ASME nameplate.





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