The boiler plant at my company requires a minimum of a 1st Class C license, which I hold.  I am the manager of my department and supervise several mechanics who hold Chief C licenses.  Can I place myself in the role of chief engineer and delegate my staff as operating engineers as defined by MN Rule 5225.0050 and Rule 5225.1110?  In other words does their licenses supercede mine insofar as who serves as the chief engineer?  Thanks.

Jim,

Thanks for the question.  I realize you are a manager, but I will answer this as though you are not management for the benefit of the majority of chiefs out there who are not management.  I will provide more detail than you asked for, since these issues and related issues are commonly misunderstood.

If your plant is 500 horsepower or less, you can be the "chief" or the "take charge" person for your plant.  The other operators, or shift engineers must have at least a 2nd class.  If they have a chief license it just means they meet the requirements for their positions. 

The employer is free to choose the chief engineer, as long as the person they choose has a license that is high enough, which it is in your case (1st class) if your plant is 500 horsepower or less.

There is no provision in the law that requires the person with the highest license to be the take-charge person. 

As long as you are considered the chief engineer, you have responsibility for and must have management authority over the safety of your plant.  This means you have authority over other operators in terms of operational procedures, maintenance scheduling, etc.  You should also have a seat at the table when management is discussing these same issues or if they are contemplating a change to the plant.

Management owns the boiler and they can do what they want with it with some limitations.  If they want it painted pink, you will have to do that, since it is not a safety or other issue requiring your expertise.  Management can also decide who will sweep which floor, who will change oil on an air compressor in the boiler room, etc.  They can also delegate this type of supervision to the chief engineer, which they usually do.

As the chief, your management authority generally means you can veto management's plans for a change in the boiler room for safety reasons and you can require that certain tasks must be performed, such as sending safety valves out for testing each year.  Management cannot just choose not to do this because of the expense.

Be careful using your authority with your employer, since they can choose to find another chief engineer if they think you are unreasonable.   I would only push my authority hard if I believe other chief engineers would take the same stance on an issue.  You will also need to be right about the issue if you want the State Inspectors to back you up.

If you need more info, please post again.

Thanks,

Reed

Jim,

First of all, I wouldn't be worried about losing a license.  The infraction has to be pretty serious for that to happen. 

I believe the fuel train is considered pressure piping (and should be inspected), but I am going to check just to be sure.  I have an inspector looking into it right now.  I'll post again when he gets back to me.  Fuel train components are covered under ASME CSD-1, so that should put it under the inspector's domain.

The operator should continue to check the boiler in the meantime because not checking it is more dangerous than checking it.

Tell the operator to do the following things whether it needs to be inspected or not:

1.  Check to see if he smells gas while the boiler is running and while it is not running.

2.  Perform a scanner test (you should do this monthly anyway)

3.  Perform a pilot turndown test (should be done anually and whenever changes are made to the pilot or flame scanner mount).

4.  Perform a visual check of the fuel train (should do this monthly).

5.  Perform a leakage test on pilot and main fuel valves (should do anually).

6.  Test high and low-pressure gas interlocks (should be done monthly).

7.  Test purge air switch (should be done anually).

8.  Test low fire start interlock (should be done anually).

Although I listed frequencies with this, I would like to see him do all of these right now since they might not have been done by the installer.  It would be nice to think the installer would have done all these things, but you should do it yourself, just to be sure.

In the future, you should do all of the above in the suggested frequencies to all of your boilers.  This is all CSD-1 stuff, so it isn't just my opinion.  We teach a class on this. 

The above items are all required to maintain a safe fuel train system.  If the system passes all these tests, you should be pretty safe.

I would like to make it clear that I am not saying you should run the boiler before it is inspected (at least until the inspector gets back to me).  I am saying the above maintenance items are normally performed to make sure your boiler is safe.  I'm also saying you should check the boiler if you are going to run it.

If the installer knew what he was doing, he should have called inspectors as necessary during or after the installation, so you should probably contact him to make sure he did.

If you have any questions about how to perform any of these tests, let me know.

Reed

I re-read your post to make sure I covered everything and I don't think I did.

To answer more directly:  In my opinion, your operator did not do the right thing.  If he chose not to check the boiler then he knowingly allowed a boiler to operate that he felt was in an unsafe condition.  He had a couple of choices:

1.  Check the boiler

2.  Shut the boiler down and call you or the inspector (hopefully you)

By allowing the boiler to run when he felt it was unsafe, he violated the law.  You are supposed to call the state if you feel a boiler is being operated unsafely (or shut it down until it can have the problem corrected).

Think of it this way: Why are you licensed?  Answer: To protect yourself, your employees and the public.  Does refusing to check the boiler meet this goal?

This all assumes the boiler is unsafe, which I'm not sure it is.  I'll post again with the answer from the state.