Assume, we are a contractor for the modernization of steam turbines. Modernizations often cover the range of about 10-30% of the turbine set. Should we give the CE marking to the entire tub? Can the CE marking be given by the owner or power plant?
A modernized machine in the light of the CE marking should be treated as new if the scope of the modernization significantly influences the change in the conditions of safety of use. Therefore, if it is a modernization of mechanical assemblies that improves the machine's efficiency, life or reliability, it does not require CE marking (it should be remembered here about Directive 2009/104 / EC).
However, if the scope of modernization are control and protection elements, they have a significant impact on safety and the machine-turbine set should be marked with the CE mark.
The CE marking should be made by the machine manufacturer, but who is the manufacturer can be a contractual issue. In today's industry, often the last company to place a production plate is a producer even though it does not always take part in production. The producer may be a modernization contractor or owner of a turbine set and may give CE marking on his own behalf.
We are dealing with two cases when modernizing:
- machine put into service before the CE marking was required - without a CE mark,
- a machine bearing the CE marking but in the declaration, the manufacturer stipulated that any modification of the machine results in the loss of the CE mark, the declaration is no longer valid. (p.s. even if the manufacturer does not write such a reservation, it is included in the Machinery Directive 2006/42 / EC).
Let us now consider the modernization having a significant impact on the safety conditions of the old machine, case 1 - not bearing the CE mark. We already know that we have to give the CE mark but how to do it when we do not have strength calculations and in many cases we do not even have enough material data to carry out calculations? (I omit cases where the material can be examined) It must be demonstrated that the machine is safe after modernization. We do not have to show that it will be trouble-free for a certain period of time. The CE mark is not a sign of quality or reliability. The CE mark means a declaration of compliance with the requirements of the machine specific directives. So how can you show security? We can do it on the principle of a logical comparison. If the machine was manufactured, eg 30 years ago, for a pressure of 100 bar and the loss of tightness of the turbine body does not endanger the safety, then we can assess that this element is safe. The situation is different in the case of a pipeline whose crack may cause an explosion. It can not be assumed that pipelines that were safe at the time of putting into service are still safe. Therefore, if there is no security certainty, it should be replaced by new ones.
And what about the 2 - turbine with CE marking?
Turbine and pressure directive
to be continued