PED question regarding equipment installed prior to PED
PED question regarding equipment installed prior to PED
(OP)
I've searched through the PED regulation (2014/68/EU) and I don't see any reference or discussion about equipment that was in service prior to PED. Are PED regulations retroactive?
It seems inconceivable to me that the answer would be yes. After all, most of today’s vessels and relief installations pre-date PED. Retroactive application would have a pretty high cost without producing any safety benefit, unless the existing PRD was improperly designed and/or installed. I expected that this would be a widely discussed topic, but after searching the internet and the PED text I came up empty.
Take, for example, an ASME Sec VIII vessel (installed in the 90's) that has two in-service PSVs (one set at the MAWP and the other set at 1.05MAWP) and the valves were sized for an accumulation of 16%, as permitted by ASME Sec VIII. PED allows the existing set pressures, but it doesn’t allow the 16% accumulation. For multiple relief devices, the PED allowed accumulation is still 10% for a non-fire case. Does PED require a field modification or is this installation grandfathered?
It seems inconceivable to me that the answer would be yes. After all, most of today’s vessels and relief installations pre-date PED. Retroactive application would have a pretty high cost without producing any safety benefit, unless the existing PRD was improperly designed and/or installed. I expected that this would be a widely discussed topic, but after searching the internet and the PED text I came up empty.
Take, for example, an ASME Sec VIII vessel (installed in the 90's) that has two in-service PSVs (one set at the MAWP and the other set at 1.05MAWP) and the valves were sized for an accumulation of 16%, as permitted by ASME Sec VIII. PED allows the existing set pressures, but it doesn’t allow the 16% accumulation. For multiple relief devices, the PED allowed accumulation is still 10% for a non-fire case. Does PED require a field modification or is this installation grandfathered?





RE: PED question regarding equipment installed prior to PED
RE: PED question regarding equipment installed prior to PED
RE: PED question regarding equipment installed prior to PED
Not sure if that helps much though.
RE: PED question regarding equipment installed prior to PED
Regardless, per ISO, only the term Safety Valve is used for all overpressure eventualities.
RE: PED question regarding equipment installed prior to PED
..."The Pressure Equipment Directive (97/23/EC) was adopted by the European Parliament and the European Council in May 1997. It has initially come into force on 29 November 1999. From that date until 29 May 2002 manufacturers had a choice between applying the pressure equipment directive or continuing with the application of the existing national legislation. From 30 May 2002 the pressure equipment directive is obligatory throughout the EU."
Dejan IVANOVIC
Process Engineer, MSChE