Is it right to determine pressure test value acc. to AD 2000 Merkblatt last edition (to satisfy PED requirements) for heat exchangers type of AET or AES (and the others) taking into consideration not only shell and heads but also main flanges and their bolts as pressure parts? This situation causes that PT is limited by bolts. Please see Ad 2000 HP30 para. 4.17 third indent. Also please see PED guidelines numbers 7/6 and 7/8 (main bearing pressure parts). Jack
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