Directive 2014/68/EU - Sound Engineering Practice?

[J penner]

We manufacture coolers. We design them in accordance with ASME BVPC section VIII and the design is registered in Canada. We would like to export them to the EU. From our reading of EU Directive 2014/68/EU, the design falls under SEP. what do we need to do to confirm that our design meets the SEP requirements?

 

[XL83NL]

For SEP, it basically means there are no requirements specified. Design per ASME VIII-1 would normally considered sufficient. You might want to review the PED guidelines to exactly understand what SEP means. Find it here;

https://ec.europa.eu/docsroom/documents/33402/attachments/1/translations/en/renditions/native

Just search the pdf for SEP or Sound engineering practice.
The only real requirement you’ll find in the guidelines is the need to provide a manual for safe installation, operation and maintenance, and a nameplate. The default ASME nameplate may not suffice. I’ll share details tomorrow (when I’m back at the office) which additional details need to included on the nameplate.

Just to be sure, can you share the details which led you to the conclusion the cooler is considered SEP? What are the volumes of both chambers, both fluids, both pressures and both temperatures?

 

[J penner]

Thanks for the reply,

First, the directive say SEP of a member state. Canada is not a member state and as far as I could find out, ASME BVPC has not been adopted by any EU member state. So while we feel the design is designed in accordance with sound engineering practice, we are concerned it may technically not be with respect to the EU (ie format of calculations, presentation of results, welding standards, materials specs, etc.). What I need to find out is whether I have to purchase a standard from a member state and redo the calculations and other documentation to meet the format requirements of the European standard. While this would ensure conformance with SEP, it also represents a significant cost and effort. I would therefore prefer to rely on the ASME work, but need to confirm is acceptable with respect to the SEP in the EU directive.

Second, the cooler is used for a group 2 liquid (oil with flash point of 271°C) , rated for a pressure 250 psi (17.2 bar) at 232°F (110°C), volume is 21 litres, PV = 569 bar*L. Per article 3, part 1(a)(ii) indent 2, a Group 2 fluid with a 10 bar < PS < 1000 bar & a PV < 10000 does not need to satisfy the ESR and is governed by SEP. The cooler is fan cooled in atmosphere.

 

[XL83NL]

While this would ensure conformance with SEP, it also represents a significant cost and effort. I would therefore prefer to rely on the ASME work, but need to confirm is acceptable with respect to the SEP in the EU directive

ASME VIII-1 is sufficient, trust me, as long as you include an IOM and a nameplate which includes the PED required details (see my 1st post). No NoBo will need to have a look at this. From my experience with the PED, and with NoBo's, no one has ever ran into a situation where a member state has specific definitions for what that member state calls 'sound engineering practice'.

We have done dozens of ASME vessels under PED (up to cat. IV), which required little extra work to make sure PED was met (usually limited to simple paperwork)

The only thing I can think of, is that certain countries may pose additional requirements (outside the scope of the PED), such as Germany with emission restrictions (their 'TA Luft'-stuff), etc. However for your application there will be little change youll run into such situations.

 

[XL83NL]

The only exception I could find is in guideline B-04. I dont think that guideline applies to your case, since your cooler is probably not used "in refrigeration systems, in air conditioning systems or in heat pumps". Furthermore I dont know the size and shape of your application, hence dont know if the piping aspect is predominant.