Confusion over PED & sec IX requirement

[smart143]

I have to build a LTCS spool piece which is designed per ASME B31.3 & needs PED 97/23/EC compliance as well.
As per B31.3 WPS/PQR qualification is required per ASME sec IX whereas PED asks the qualfication per EN 15614-1.

So which welding code supercedes here 15614-1 or sec IX or I need to comply to both the welding codes, if that is the case then I will need to qualify multiple procedures to cover the thickness range for base metal.
I already had a previous weld cupon welded on 8 mm thickness & tested as per sec IX as well as 15614-1 with impact testing. but now job thickness is 6.35 mm & 15mm. so over thickness limit is not an issue but sec IX allows min thickness as 8 mm whereas 15614-1 allows min thickness as 4 mm. so shall I need to weld additional test cupon only for impact to qualify lower thickness limit to meet sec IX?

Too many questions asked but a small guidance will help me to come out with solution.

 

[DekDee]

smart143,
Strongly suggest you get a Welding Engineer involved because it is a lot more complicated than you realise.
Example: The thickness requirements for impact tested applications for B31.3 (which overrules ASME IX) are totally different to ASME IX.(Your 8 mm coupon only qualifies you to 14 mm as per B31.3 not 2 x T as per ASME IX)

As far as I am aware you can weld using ASME IX welding procedures and be in compliance with PED - never seen any requirement for ISO/EN15614-1,
Cheers,
DD

 

[DekDee]

Smart143,
Further to my post above.
I worked on a US$4 billion Nickel Refinery in a French territory and it was all PED and our third party inspectorate was Lloyds of London.
All our welding procedures were in accordance with ASME IX but the two points listed below may be different to your situation.
We had no low temp welding on site (so no impact testing) and all WPS/PQRs were witnessed by a third party.

Note 3:
The current version of ASME Boiler &Pressure Vessel code Section IX is
another example of where properties are not sufficiently dealt with for
some applications in order to comply by itself with the PED (e.g.
impact property in the HAZ). Furthermore, it does not require that the
tests and examinations shall be performed under the responsibility of a
third party (see also guidelines 6/1 and 6/4).

Have a look at B31.3 Table 323.3.1 A-5 Your 8 mm coupon is valid for 4mm to 14 mm (as per B31.3) and if it is EN 15614-1 compliant then impacts should have been tested in the HAZ. If you also had a third party witness then your WPS/PQR is PED compliant.
Unfortunately you will have to qualify another PQR to cover the 15 mm

Hope that helps,
Cheers,
DD

 

[XL83NL]

Use of ASME IX under PED is possible, done extensively and successfully (if implemented by personnel knowledgeable about the differences in both documents), and I dont recall of any requirement on using EN ISO 15614 for 'welding under PED'.
The key sentence in the PED for welding is found in the ESR's of annex I, chapter;

3.1.2. Permanent joining
Permanent joints and adjacent zones must be free of any surface or internal defects detrimental to the safety of the equipment.
The properties of permanent joints must meet the minimum properties specified for the materials to be joined unless other relevant property values are specifically taken into account in the design calculations.
For pressure equipment, permanent joining of components which contribute to the pressure resistance of equipment and components which are directly attached to them must be carried out by suitably qualified personnel according to suitable operating procedures.
For pressure equipment in categories II, III and IV, operating procedures and personnel must be approved by a competent third party which, at the manufacturer's discretion, may be:
— a notified body,
— a third-party organization recognized by a Member State as provided for in Article 13.
To carry out these approvals the third party must perform examinations and tests as set out in the appropriate harmonized standards or equivalent examinations and tests or must have them performed.

Furthermore, as DekDee pointed out, some requirements of the PED are not covered in ASME IX.
I suggest reviewing NPR/CEN-TR 14549, " Guide to the use of ISO 15649 and ANSI-ASME B31.3 for piping in compliance with the Pressure Equipment Directive ".
Some of the PED guidelines are useful on this subject too, like guideline #6/12 DekDee already referred to.

 

[smart143]

I believe 15614-1 is the harmonised standard for PED requirement, do you say that equivalent examinations means we can use ASME sec IX with additional checks in HAZ ???
will this comply to annex I
I do need to qualify new procedure for 15 mm thickness & fortunatley my 8 mm thick plate procedure tested under third party with impact in HAZ area as well.

 

[XL83NL]

Yes, EN ISO 15614-1:2004 is a harmonised standard. Applying it assumes conformity under the PED. It is however not a PED requirement (i.e. using ASME IX is allowed but may be more difficult).

Know the ESR's (Essential Safety Requirements) of the PED, found in the annexes, and make sure your welding procedures line up with that.

In any case of doubt, contact your notified body; he will be involved in the end assessment when making up the EC Declaration of Conformity, and help you getting your weld qualifications up with PED requirements.

 

[wegm]

To my opinion ASME B31.3 could be used as design code without being mandatory the wps and welder to be qualified in accordance with ASME IX but as required by PED 97/23/EC. Please have a look at this link (for wps/welder qualifications):

http://www.weldinguide.com/gdanastasiadis/viewtopic.php?f=5&t=392

In addition please note that in no case ASME IX could cover the PED requirements (Note 3 of the attached file)

 

[smart143]

Thanks wegm,

I gone through note 3, though sec IX does not require impact in HAZ & neither it requires testing to be witness by TPI. But suppose if we perform test cupon per sex IX under TPI with additional impact check in weld & HAZ ,will that be sufficient to comply to PED??

 

[DekDee]

smart143,
All the information is in the postings above.
As XL83NL has stated " appropriate harmonized standards or equivalent examinations and tests or must have them performed."
ASME IX has all the equivalent tests except for impacts in the HAZ so you conduct those and your examination and testing is equivalent.
If you have had your PQRs witnessed by a TPI then you have complied with the requirements of PED.
On the project I noted above we had a very experienced engineer whose role was PED Co-ordinator - he spent 3 years on the project ensuring all welding, bonding and materials complied with the PED - ASME IX and B31.3 for all piping.

wegm,
I would be interested to know how you can design to B31.3 and yet qualify your procedures to something other than ASME IX ?
Cheers,
DD

 

[wegm]

DekDee,
The PED is not a construction code, it is simply a law! So, if the ASME B31.3 covers the PED requirements, then you can use it for the design, although the weldings shall be performed as required by PED and thus the procedure and welder qualifications shall be in accordance with harmonized standards
regards
wegm

 

[DekDee]

wegm,
Please advise how your piping system can possibly comply with B31.3 if the welding procedures and welders are not qualified in accordance with ASME IX.


328.2 Welding Qualifications
328.2.1 Qualification Requirements
(a) Qualification of the welding procedures to be used
and of the performance of welders and welding operators
shall conform to the requirements of the BPV Code,
Section IX except as modified herein.

At the risk of repeating myself - again, read 3.1.2 posted by XL83NL above - To carry out these approvals the third party must perform examinations and tests as set out in the appropriate harmonized standards or equivalent examinations and tests or must have them performed.
You do not have to work to a harmonised standard to be compliant with the PED,
Regards,
DD

 

[XL83NL]

Dekdee hit it by the nail I think. Thats how I work around using PED and B31.3 for European work too. Thats the escape, so to say.
Furthermore, but thats off topic, the EN piping code, 13480, is a harmonized standard which should conform to PED by itself. Im not that familiar, yet, with that code, but I prefer B31.3 a million to times EN 13480. What an unpleasant code, to put it delicately.

 

[smart143]

DekDee,
Thanks for your resposne, I will take up this matter with our N.B. to remove the additional qualification as per Harmonsed standard (EN15614-1) & just perform equivalent testing as per PED.