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