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ASME section 1 and Pressure Equipment Directive

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If a boiler is designed, manufactured and tested in accordance with ASME section 1, will it also comply with PED?

athomas236

No

To comply with the pressure equipment directive you must fulfill the Essential Safety Requirements of Annex 1.

It isn't necessarily true that the boiler won't comply but it isn't guaranteed that it will comply.

You need to look at the directive and the code you've sued to design the boiler.

If the code differs from the directive then you have to demonstrate an equivalent level of safety to that required by the directive.

It is also almost certain that the minimum hydrostatic test pressure will not conform to the requirement of 7.4 of Annex 1 of the PED,
in this case you'll have to perform an analysis (fea or calculations) to show that the boiler can survive a test at the minimum required
by the ped and then retest the boiler.

You can design by experimentation for the ped but this requires a lot of careful analysis and documentation.

Materials may be your biggest headache but, as there aren't any approved materials for the PED yet everyone is having to develop
PMAs for every material they use anyway.

I would get in touch with a notified body and discuss the specific design with them.

Fawkes, what you have written corresponds to a large degree to what our notified body has told me a few days ago with respect to
ASME Div 8 (pressure vessels). For pressure vessels in essence it would be easy. The pressure test needs to be adjusted as you have
explained. For pressure vessels, apparently for the materials the PMA is not such a headache.

Based on the recent replacement of the material related DINs by new ENs, I thought that that was reflecting the PED approved
materials. It therefore suprises me a little bit that you say there are no PED approved materials yet.

Now, if it is that easy for an ASME vessel to be approved for use in Europe, is it similiarly easy for a PED vessel to be approved for use
in the USA?

I think what is also important is as our notified body expressed it: "ASME is one of the codes which are recognised by the PED". Is
there a list of codes which are recognised and another of codes which are not recognised?

asme sect I does not recognize fatigue damage, yet the PED EN 12952-3 mandates that the boiler mfr define the operating
limitations for cycling service based on the PED fatigue calculation procedure. So ,there is a major piece of the puzzle missing if only
sect I was followed.

The real reason that using ASME will not meet the PED is that ASME is a consensus standards system established to protect the
public. The PED was developed by bureaucrats as a barrier to trade.

====================
Still trying to help you stop corrosion.
formerly Trent Tube, now Plymouth Tube
eblessman@plymouth.com
or edstainless@earthlink.net

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EdStainless, really......try living in Europe and complying to ASME, all codes are barriers to trade outside their economic environment.

Davefitz, the designation PED EN 12952-3 doesn't make sense, PED is a directive, directive 97/23/EC, EN 12952-3 is a standard, they
are separate documents.

It is true however that you must manufacture equipment safely and consider all the design criteria, if it is good engineering practice
to consider fatigue with certian types of vessels or boilers then this must be considered even if the code you using does not state it is
a requirement.

I would check the guidelines though, the essential safety requirements of the PED require impact testing but, under guideline 8.8
impact testing is not required if brittle fracture is not an issue, for instance if cryogenic materials are being used.

With regard to the materials.

The EN specifications replace the BS materials, DIN materials and all the other standards across the European Union. They have to be
approved for use with pressure vessels. There are three levels of material specification:

Harmonised Standards, these specifications are harmonised across Europe and are suitable for use in pressure vessels.

There are currently non of these.

European Approved Materials, these are materials suggested by Notified Bodies to CEN for acceptance for use in pressure vessels,
currently all applications have been refused.

The final option is Particular Material Appraisals (PMA) where you aproove a material for a specific service and this is agreed by the
notified body.

This is your only option.

I would suggest that you make the PMA as generic as possible for each material specification and grade then you can use it more
than once. It is worth noting that the PMA can be for any material specification as long as it is a recognised standard, we primarily
use ASTM/ASME materials so we can produce to ASME and PD5500.

We have also produced many vessels to the PED with a U-Stamp it is worth noting however that both PED and ASME are strict on
how vessels are marked so you need two nameplates.

As a side note, I have a link in the faqs of the CEN forum to the official website

http://www.eng-tips.com/faqs.cfm?fid=280

Wrong link

http://www.eng-tips.com/faq.cfm?pid=748

Fawkes,

You are right, the European commission recognizes that the EN 12952 meets the PED ESR's , but the PED did not directly generate
it. The european commission has published a list of "harmonized standards " which meets the PED's ESR's ( essential safety
regulations), and the en-12952 is there, but ASME section I is not. In addition, such a harmonized standard is to be listed formally in
the PED annex Z ( which I haven't found yet), so if the 12952 is in annex Z, is could be stated that is is recognized by the PED.

So, it might be technically more correct to say " the PED annex Z's recognized harmonized standard en 12952" than simply "ped en
12952".

As I mentioned, one of the ESR's is fatigue damage, which is not currently recognized by section I , but is proposed to be recognized
for HRSG's. If a vendor chose to use asme section I , he would need to demonstrate compliance by demonsgtrating all ESR's are met,
and have the desing approved by the EU compliance authority.

Fawkes, you seem to be immersed in all this PED-EN stuff. There are some concepts mentioned in your post of which I cannot make
head or tail. I apologise for asking you here and not going through all the material presented in your link. I would get lost in there.

What is a "harmonised" standard? I thought the purpose of the EN standards is to provide a uniform standard which is then adopted
by each of the member states and conformed to through local standards. Yet, as you state, there are no harmonised materials
standards. Are the EN standards therefore not "harmonised"? What is the point in having EN standards then? (Our NB said they

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accept the EN materials because they "suspect" - he used the German legal term - conformance of these materials to the PED safety
requirements. Which brings to me the question of whether the powers to be are lawyers or engineers.)

The following is also not clear to me:

As you state: There have been applications by notified bodies to CEN for use of materials in pressure vessels. All applications have
been refused. Yet, the public/state/government/whoever entrusts the approval of materials for pressure vessels to said notified bodies
of which the applications have been refused. Somehow the ethics of this arrangement does not make sense to me. (Perhaps I read
too much into the words).

If you could put my mind at ease with only a few words, I would greatly appreciate it.

Davefitz

The annex Z should be in EN 12952 not the PED, for instance annex z of PD5500 privides a table highlighting the codes compliance
and non-compliance with the ped.

GL431

Within Europe there aren't standard standards there are harmonised standards, they are essentially the same but they differ slightly
for language and cultural reasons.

You can view the three material qualification types here:

http://ec.europa.eu/enterprise/pressure_equipment/ped/materials/index_en.html

Now, the notified bodies, which are independant of any nationality, submit materials they belive are acceptable for use in pressure
vessels, all the ones that have been submitted are under consideration or have been refused.

The notified bodies are private institutions and that is why they have to submit the application, I think CEN have limited it to notified
bodies to streamline the process and ensure that reasonable applications are presented.

The truth is that the directive was put through without enough attention paid to materials, maybe because a new design code, EN
13445, was introduced and this deals with material selection, maybe because they didn't realise how difficult it was, anyway 5 years
on the position is no better, the only materials available are the ones you produce a PMA for, I would stick to the materials you are
most happy with and ensure that they meet the requirements of the annex 1 of the ped.

If you go to the link you can see how a guideline on creating a PMA, it is really easy and if you're wise you'll add it as a quality
measure for material selection, I've used them as a checklist for designers to impose limits on certain materials, temperature ranges,
etc.

I would also advise you to go to http://ec.europa.eu/enterprise/pressure_equipment/ped/index_en.html where you can

view the entire directive for free (woohoo) and view guidelines.

You're materials have to come from a supplier that has a quality assurance system that meets the following:

Quote:

The equipment manufacturer must take appropriate measures to ensure that the material used conforms with the required
specification.
In particular, documentation prepared by the material manufacturer affirming compliance with a specification must be
obtained for all materials.
For the main pressure-bearing parts of equipment in categories II, III and IV, this must take the form of a certificate of
specific product control.
Where a material manufacturer has an appropriate quality-assurance system, certified by a competent body established
within the Community and having undergone a specific assessment for materials, certificates issued by the manufacturer are
presumed to certify conformity with the relevant requirements of this section.

This means their ISO quality system is approved by an organisation that is authorised to do so and has a presence in the EU
(essentially so they can be brought to court if needs be) not, and at least one notified body has tried this con, not that the quality
system is approved by a notified body

I would strongly advise anyone to read the text AND the guidelines, conformance is easy(ish), not necessarily cheap but the
procedure does provide a good skeleton for successful and structured design.

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Fawkes,
I am confused as you stated that there are not harmonized European standards. Is EN10216-2 a harmonized European standard, as it
appears in EN12952-2 para. 4.1.1?

The issue is that there aren't any harmonised standards acceptable for the PED not that there isn't any harmonised standards (sorry
for the confusion)

Fawkes,
I am also confused about your posting concerning non existing harmonised standards. There are a lot of existing harmonized
standards for construction (e.g. EN 12952 - Water tube boilers, EN 12953 for shell boilers, EN 13445 for unfired pressure vessels, EN
13480 for piping). There are also a lot of harmonized material standards, e.g. EN 10028 for flat products, EN 10216 for seamless
tubes, EN 10217 for welded tubes, EN 10222 for forgings, ...
http://ec.europa.eu/enterprise/newapproach/standardization/harmstds/reflist/equippre.html
Harmonized means that these standards give presumption of conformity to the essential safety requirements (ESR) of PED and are
published in the official journal of the European Community (OJEC). All these harmonized standards have an Annex Z where the
relationship between the standard and the ESR of PED are given.
EAM (european approved materials) are existing for some high alloyed materials. All other demands, mainly for old national
standards or ASME-materials were declined. Actually, the opinion of the Working Group Pressure within the European Community is,
that EAMs should only be issued for materials that are not comparable to existing materials in harmonized EN-standards. ASME-
materials comparable to existing EN-materials (e.g. ASME-SA516) were therefore declined.
athomas236,
I think, the only way if you use ASME I with ASME material under PED is the PMA,
see http://ec.europa.eu/enterprise/pressure_equipment/ped/guidelines/guideline9-5_en.html.
EdStainless,
Maybe you are right concerning trade barriers, but the question is if the whole world should abandon their national Codes, their
national experiences and to use only ASME.
Under PED you can use ASME Construction Codes and ASME materials and a lot of people do so. All EN-Construction Codes like EN
13445 permit ASME-material in conjunction with a PMA (which is often not quite difficult to establish). On the other side, is a PV
constructed according EN-standards acceptable on the territory of US? Can I use all EN-materials within ASME?

Gentlemen,

Apologies for not responding earlier to all the good advice given above.

Last week I had a meeting with one of the biggest HRSG suppliers in Europe to discuss this matter. This supplier has previously
supplied HRSGs for five projects that complied with PED and ASME I and were stamped with the ASME stamp.

Very briefly, this supplier said said:

1. ASME materials can be used under PED, they just need the approval of the NoBo.

2. The ASME cade is acceptable for design, manufacture and testing.

3. Hydro test pressures can be selected that fall within the max and min values required by PED and ASME.

For record purposes, I will be formalising with the supplier how it will meet both PED and ASME. Any other advice or comments would
be welcomed.

Regards,

athomas236

So much misinformation in one thread! Ulysses's post explains well how to use materials in PED vessels.

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