PED Compliance 1

[DK44]

1. When a Heat Exchanger / Pressure Vessel is designed to : 1) ASME Sec VIII Div 1 + TEMA + ASME U stamp or 2) ASME Sec VIII Div 2 + TEMA + ASME U2 stamp, with ASME Materials in both cases, what additional requirements if any are to be complied with, to conform to PED when such Vessels are supplied to European Countries.

2. If such vessels are designed to EN 13445 + CE marking,with EN materials, does it directly comply with PED.
2.1 Can ASME Materials be substituted in this case with EN Materials.

 

[KVdA]

Question 1: No, U stamp or not you need to comply with PED essential safety requirements.

Q2: yes
Q2.1: yes when in conformity with 13445 or PED

 

[XL83NL]

As to Q1; you might want to check out ASME PTB-10;

https://www.asme.org/products/codes-standards/ptb10-2015-guide-section-viii-division-1-stamp

There certainly are requirements not covered in the ASME codes.

Just out of curiosity; why would you want an ASME stamped vessel for the EU market, where only PED is a requirement? Or is this a hypothetical case?

 

[Vikko]

1) the requirements depends on the PED Category, from I to IV, and in the best case when there is no category or article 4, paragraph 3 you should do just nothing. TO evaluate the category you should see in Annex II of the PED, and apply the correct table 1 to 4, depending on the type of fluid liquid / gas, group 1 (methane, hydrogen, any flammable fluid) or group 2 (water, nitrogen, and other not dangerous fluid). If it is a category I there is not a lot a to do, it is just a self evaluation, so everything is smooth and simple. Starting from category II it gets more paper to do and you should choose a notifying authority to follow you up for the certification process, you cannot do it all by yourself. You choose a module (see the table at the beginning of annex II), the modules are then in annex III, and tells you what you have to do. Usually for cat. III or IV you can choose module B+F for a production in series, or module G for a single piece.

2) The PED does not specify a calculation code, you can use anyone you like, EN 13445, AD2000, PD 5500, ASME VIII, etc. Also CE marking is not necessary if it is not at least a category I: article 4 paragraph 3 does not require CE marking. You can use ASME material with PED of course, but starting from category III you need EN 10204 material certificate type 3.1, which usually the supplier ask some money for them and you also need to fill a datasheet called PMA if the material is not harmonized (EN). If the vessel is designed with EN 13445 it does nod make it suitable for PED: PED has nothing to do with the calculation code, it is a process which involves third party inspectors and the submittal of a lot of paper and certificates to it. Starting from category III you also have to own WPS/WPQR/WPQ according to EN 15609 / EN 15614 / ISO 9606, which shall have been already approved also by a notifying authority (like TUV, SGS, etc) following their certification processes.

This is the PED:

https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32014L0068&from=EN

 

[DSB123]

KVdA,
What are you answering No to in Q1? The OP is asking what additional requirements are needed to conform to the PED. "No" as an answer tells him nothing. Also not only does he need to meet the essential safety requirements but the materials need to be either in accordance with a harmonised standard, be a EAM or get approval via a PMA.

Your answer to Q2.1 is also ambiguous. You cannot substitute an ASME material for a European Material!! ASME materials can be used provided they are a EAM or have been approved via a PMA.

Also your answer to Q2 is not correct. "Yes" is not the answer. Remember the "design" must meet the Essential Safety Requirements.

 

[DK44]

From the foregoing, if I am not wrong, understand that method (1) can be followed with compliance of ESR and PMA and such Pressure Vessels / Heat Exchangers can be exported to EU from Non EU counties. Is this in order.

 

[KVdA]

DSB123,
You are correct I misread the first part. Note that material requirements is also under annex 1 being the ESR's.
Answer to Q2.1 is not ambiguous. EN13445 will state that you require a PMA or... If you follow EN13445 from start to finish you are in compliance with the PED even when you chose to use ASME material.
Answer to Q2 is correct, yes if the material is in conformity to the PED than you can use it.

Vikko,
All pressure equipment placed on the European market (with some exceptions) shall be in conformity with the PED requirements. Simply stating that you don't need to de anything is in my opinion thus incorrect.
Although I agree the category is a very important thing to know

Darakakrishna,
My answers where perhaps a bit to short although it is actually impossible to answer Q1 without any further details.

 

[XL83NL]

Come on DSB, dont take it that hard. KvdA is just trying to help, as are you. Remember that we're all here to provide advice and help to one another. Most people have the best intentions, but may be less native in English, or less experienced in a certain field, and as such may not provide an answer which (in your eyes) holds the whole truth.

Allthough your remarks have some ground, KvdA's answer to Q2 is correct; EN 13445 + CE Marking = PED compliant. Remember, a CE mark may only be applied if the design is PED compliant. Furthermore, EN 13445 is a harmonized standard, meaning that a design acc that standard presumes conformity with the PED.

Indeed, KvdA's answer to Q2.1 is somewhat ambiguous; the short answer indeed is "when in conformity with 13445 or PED". It's rather tricky, but essentially, if ASTM materials are used, that is OK as long as they meet the requirements of the PED, and the design code requirements. If the latter is e.g. EN 13445, then it becomes quite difficult; the design basis for stress allowables, mechanical testing, chemical, NDE, etc is whole different. Just making a PMA is not all it takes. If a material, e.g. A106-B or A312 TP316 is dual certified to both the EN & ASME standard, then youre lucky. For a lot of common grade materials, thats the case right now with a lot of EU mills. The common grade materials e.g. are A106-B, A312 T304 and A312 TP316.

The answer to Q1 indeed is not a simple no, but the listing of all ESR's (Essential Safety Requirements) is too much for this topic. References for further reading have been supplied.

 

[Vikko]

@KVdA
Of course all PV need to be compliant to PED in EU, because PED is a law and its requirements are mandatory; but in case of such heat exchangers or pressure vessels, which falls in article 4 paragraph 3 of the PED (for the tables in annex II), there is not really anything to do in practice. I posted the link to the PED law, and for those who cares or wants to read article 4 paragraph 3 it states: "Pressure equipment and assemblies below or equal to the limits set out in points (a), (b) and (c) of paragraph 1 and in paragraph 2 respectively shall be designed and manufactured in accordance with the sound engineering practice of a Member State in order to ensure safe use. Pressure equipment and assemblies shall be accompanied by adequate instructions for use. Without prejudice to other applicable Union harmonisation legislation providing for its affixing, such equipment or assemblies shall not bear the CE marking referred to in Article 18.". So in that case you do not even need to CE stamp on there.

And I add that even in category I, there is not a lot to do, because it is all a self declaration and makeing the rating plate with CE mark and PS/TS/PT mark: thats all.

From category II and on, you neet a notifying authority, which means you have to deal with an inspector (you choose who wants to work with TUV and the like).

For category III and IV you have to deal with a lot of more requirements:
- WPS/WPQR/WPQ according to EN 15609 / EN 15614 / EN ISO 9606 : you should already have all this certificates or start an application for them, because the process is not smooth and simple.
- EN 10204 3.1 material certificates, the suppliers will charge you more for them, because usually there are tensile tests printed on it.

The calculation code is not prescribed by PED, you can use EN 13445 if you like or any other (ASME VIII div 1, PD5500, AD2000, etc). The compliance to EN 13445 does not have anything to do with the PED and does not guarantee anything in regards to PED.