Technical Note

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Note N: 2006-03 Rev.: 1

Reference / Basis / Source: GL 7/17 Rev.: 27/1/2003

From: Michel Margat

To: All PED Staff / pressure equipment Manufacturers
Copy to: Andreas Splinter / James Grice
Date: May 5th 2010
Subject: PED impact testing exemption policy for Pressure Vessels per ASME Section VIII Div 1

The following can be applied with immediate effect:

This interpretation cannot supersede more restrictive rules of the Code

Option 1

Use our current rules (Quick approach)

This method is based on the common practice of Notified Bodies and is based on
National Standards that existed prior to the PED.

a. Use of ASME Section VIII Div 1 UCS66 exemption curves with the following
restrictions
1) Minimum temperature permitted without impact testing = 32F (0C)
2) Use curve UCS 66 to estimate the impact properties
3) Adjustment of temperature per API579 to estimate 27J at MDMT, example
below
4) Chemical analysis per ASME/ASTM Specifications
5) Recertified material per UG-10 not permitted
6) For bolting see annex "A"
b. The worst case hydrostatic test pressure per the PED/ASME shall be used

c. The operating instructions must reference that the user must not pressurize the
vessel at temperatures below MDMT.

Wording expected from the customer on the PMA to cover that option:
Yes, sufficiently ductile at Minimum Allowable Temperature per UCS 66 code
exemption
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API 579 EXAMPLE - ASME Section VIII Div 1 quick approach. ( See annex "B")

Material data:
SA106 Gr B, 18in sch 80 (thk 0.937in)

- Per curve B Fig.-UCS-66,15ft.lbs (20J) can be expected at 270F (-2.80C)

- Applying the API 579 appendix F conversion factor of -12.4F (- 6.9C),
27J [per PED Annex I Section 7.5] can be expected at 39.4F (4.10C).
- Pipe SA106 Gr B, 0.937 in. can be used down to 39.4F (4.10C) without impact
testing when using the quick exemption approach:

Option 2

Use of current rules (Material exemption)

a. Material exemption on the basis that the materials chosen for the service conditions
do not exhibit brittle fracture tendencies at low temperatures
- For example Aluminium, Stainless Steel, Titanium

Wording expected from the customer on the PMA to cover that option:
Yes, Ductile Material
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Option 3

Product exemption method 1 Section VIII Div 1 UG20 f)

This method utilises the exemptions allowed in the Code that can be determined as
product oriented. It utilises the experience of the Code coupled with requirements
from the Directive and harmonised standards.

Use Section VIII Div 1 UG20 f) product exemption the vessel operates
under conditions using materials at thicknesses where brittle fracture
will not occur.

i. All the requirements of Section VIII Div 1 UG20 f) must be met plus:
1) The chemical analysis of vessel materials ie. all pressure parts and materials
welded to pressure parts, with the exception of bolting, shall be limited to
the following maximums:
a) C = 0.23% for ladle analysis
C = 0.25% for product analysis
P = 0.035%
S = 0.025%
Others = ASME/ASTM specified limits

b) Recertified material per UG-10 not permitted

These limits shall be identified in the PMA and once approved, in the
procurement documentation that goes to the material supplier.

The chemical analysis must be verified on the MTR

b. The worst case hydrostatic test pressure per the PED/ASME shall be used

c. The manufacturer must provide technical justification during hazard analysis that
there is no risk of brittle fracture due to the service conditions of the vessel and the
material selected. The manufacturer should state that their reasoning is based on
experience based on service history, the technical justification background to the
product exemption in UG20 f) of Section VIII Div 1 and any other supporting
factors that are pertinent.
Note this is not a material exemption, it is a product exemption.
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d. The operating instructions must reference:

i. That the user must not operate the below minimum temperature
ii. That the vessel cannot be subject to thermal or mechanical shock
iii. That cyclic loading is not controlling design and therefore the static loading
or maximum number of cycles shall be defined. In this instance the method
of counting cycles shall be defined.

e. For bolting see annex "A"

Wording expected from the customer on the PMA to cover that option:
Yes, product exemption per UG 20(f) plus chemical restriction

Option 4

Product exemption method 2 Section VIII Div 1 UCS66

This method utilises the exemptions allowed in the Code that can be determined as
product oriented. It utilises the experience of the Code coupled with requirements
from the Directive and harmonised standards.

Use Section VIII Div 1 UCS66 product exemption the vessel operates
under conditions using materials at thicknesses where brittle fracture
will not occur

a. The requirements of Section VIII Div 1 UCS66 and the curves must be met
plus:
1) The chemical analysis of vessel materials ie. all pressure parts and materials
welded to pressure parts, with the exception of bolting, shall be limited to
the following maximums:
a) C = 0.23% for ladle analysis
C = 0.25% for product analysis
P = 0.035%
S = 0.025%
Others = ASME/ASTM specified limits

b) Recertified material per UG-10 not permitted

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These limits shall be identified in the PMA and once approved, in the
procurement documentation that goes to the material supplier

The chemical analysis must be verified on the MTR

2) Refer to the curves in Fig.-UCS 66 to estimate the impact properties. The

curves establish the temperature at which an impact value of 15 ft.-lbs.
(20 J) may be assumed.

3) Adjust the temperature found in Fig.-UCS-66 per API579 Table F7

(appended) to estimate 27J required by PED for the MDMT.

4) The use of UCS66 (b) coincident ratio and UCS-68 (c), 30F (17C) reduction
for non-required PWHT of P-No. 1 materials, are not permitted

5) The worst case hydrostatic test pressure per the PED/ASME shall be used,
the MDMT shall be considered to ensure that the test temperature is not
below impact test exemption temperature.

b. The manufacturer must provide technical justification during hazard analysis

that there is no risk of brittle fracture due to the service conditions of the vessel
and the material selected. The manufacturer should state that their reasoning is
based on experience based on service history, the technical justification
background to the product exemption in UCS66 of Section VIII Div 1 and any
other supporting factors that are pertinent.

c. The operating instructions must reflect that the user must not operate the
vessel (pressure equipment) below minimum temperature.

d. For bolting see annex "A"

Wording expected from the customer on the PMA to cover that option:
Yes, sufficiently ductile at Minimum allowable temperature per UCS 66 code
exemption plus chemical restriction
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Annex "A"

Bolting (low alloy steel bolts)

Option 1 (material without guaranteed impact properties)

Use of ASME Section VIII Div 1 UCS66 exemption table with the following restrictions

1. Minimum temperature permitted without impact testing = 32F (00C)

2. Chemical analysis per ASME/ASTM Specifications

Wording expected from the customer on the PMA to cover that option:
Yes, sufficiently ductile at Minimum allowable temperature

Option 2 (specific material selection)

Use ASME/ASTM SA/A 193 B7, B7M/194 2H

Up to and including 2 in. (64 mm) diameter impact test exemption down to - 55F
(- 480C)

Over 2 in. (64 mm) diameter impact test required for a MDMT below 32F (0C)

Wording expected from the customer on the PMA to cover that option:
Yes, per code exemption

Option 3 (material with specified impact properties)

Example : ASME/ASTM SA/A 320 L7

Can be used down to impact properties guaranteed by the specification providing impact
test values required by the PED are met.

Wording expected from the customer on the PMA to cover that option:
Yes, impact tested to satisfy 27 J
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Annex "B"

Table F7 Extract from API 579 appendix "F"