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The PED, CE stamp and nuclear applications

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Varjaks_coffee

Mechanical
Nov 21, 2022
2
Hello all,

Looking for any opinions here on the following situation:

The Pressure Equipment Directive (PED) Chapter 1, Article 1, para. (h) explicitly states that nuclear equipment (specifically, "the failure of which would result in an emission of radioactivity") is excluded from the directive.

I have received instruction to design a vessel that is compliant with ASME VIII Div. 2, and PED, and some additional French pressure equipment regulations (ESPN). Without going into unnecessary detail, this vessel is a piece of nuclear processing equipment (contains a radioactive gas) and is to be installed in a nuclear facility. So, obviously would fall under the 'exclusion' statement above. Now, aside from the additional time and effort it would take to design and fabricate such a vessel, another question arises. The entire purpose of engaging a Notified Body and performing Conformance Assessments is to eventually receive a CE stamp. Based on the exclusion above, it would appear to me that seeking a CE stamp isn't even appropriate in this case, and even if you did engage a Notified Body they likely wouldn't be willing to apply a stamp as this is so clearly outside the scope of PED.

Has anyone else here run into situations like this? It appears to me that the eventual owner of the equipment (within the EU) just wants a CE stamped vessel because that is what is 'normally required', without the consideration of its nuclear application.

Any commentary would be appreciated,

Thank you,

-V_C
 
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No similar situations or experience, but applying CE to something outside the scope of the PED (or any Directive for that matter) is prohibited. A customer or client can ask you to do a full 'PED-assessment' (i.e. apply module G or H or whatever), to find some sort of compliance in essential safety requirements; thats OK. However, youre not still not allowed to apply CE and declare an EU DoC. It's similar to art 4 section 3, which also excludes a physical CE-mark.

Huub
- You never get what you expect, you only get what you inspect.
 
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