Section Review Comments Section Section # Comment ... · 2. Subsea battery system Accepted Item g)...
Transcript of Section Review Comments Section Section # Comment ... · 2. Subsea battery system Accepted Item g)...
Section
TypeSection Section # Comment TypeComment Proposed Change Accepted Rejected
Review Comments
Clause 1 1.1 Technical
Statement about SIL is both unlogic and unclare. Correct: The IEC 61511 practice of establishing a
SIL rating will still be allowed, but only to the
extent as it pertains to that portion of the
complete system that operates identified safety
functions including final function element.
Delete: A SIL-defined overall intervention system
should no longer be recognized or practiced.
Accepted
Scope 1.1 will be rewritten to adress this comment
Clause 1 1.1 after e) TechnicalThis text is removing all demands for a SIL
system.
The API has to clearly state what part of the
system shall be SIL verified and to what SIL level. AcceptedScope 1.1 will be rewritten to adress this comment
Clause 1 1.1 Technical
Section 1.1 – paragraph 3
” The IEC 61511 practice of establishing a SIL
rating will still be allowed, but only to the extent
as it pertains to that portion of the IWOCS that
operates identified safety functions. A SIL-
defined overall intervention system should no
longer be recognized or practiced.”
Section 2 – IEC 61508 and 61511 as normative
reference
Comment: This is not in line with Section 1.1;
Propose to change to informative.
Comment: If it is intend that SIL shall be
informative, the IEC 61508 and IEC 61511 shall
be removed from the Normative refrences and
placed in the bibliography.
Accepted
Scope 1.1 will be rewritten to adress this comment
Clause 1 1.3(g) Technical include subsea accumulator to list 2. Subsea accumulator systems Accepted Accepted as proposed (included in mark-up)
Clause 1 1 Technical
Currently, Table 1 states that a Well Intervention
operation is Not Applicable (NA) when using a
Landing String with BOP Spacer Joint. This is
misleading as setting and pulling a tubing hanger
plug after installing a vertical tubing hanger with
a BOP spacer joint could be considered Well
Intervention.
Update the Well Intervention operation when
using a BOP Spacer Joint to include d+e (vertical
dual bore tree and vertical monobore tree).
Rejected
The basis for Table 4-1 is based on the following, where
Pulling of a TH plug is part of the completion operation:
For each mode of operation there are typically four main
operations performed (see Table 4-1):
a) subsea tree installation and retrieval;
b) well completion (e.g., production tubing/tubing hanger
installation, well perforation, and test production);
c) well intervention (e.g., through production tubing
operations, well perforation, and test production);
d) full workover (e.g., retrieval and replacement of
production tubing).
24 22, 23 2 tDD tDDp yioy
Clause 1 1 Technical
Footnote b requires clarification. Update with
the suggested change.
Well completion, well intervention and full
workover operations are limited due to lack of
barrier elements in the BOP Spacer Joint. Refer
to Section 4.6, System Review, for guidance on
how to determine if a BOP Spacer Joint is fit for
purpose for a given operation.
Rejected
Table 4-1 is labeled “Typical” and therefore is not
normative. Industry practice has been to limit operations
when using a BOP spacer joint.
Clause 1 1.1 Technical
The introduction focuses and specific topics
rather than addressing all the changes made
from the 2nd to 3rd edition of API 17G. The
discussion regarding SIL is very negative and this
text should not part of an industry standard. The
requirement regarding safety function and the
scope of SIL are well covered in the standard do
not need to be repeated in the introduction
It recommended that the Editorial team of API
17G write an introduction that briefly address
the changes made from the 2nd to 3rd edition
and the general philosophy the standard. The
following should be mentioned: 1) applicable for
designers, manufactures, service providers and
end users. 2) System based standard, but where
components can e dsign and qualified
independent of the system requirements. 3)
Stand alone standard, where Annex K, Annex J,
Annex L and Annex M have been included. 4)
Safety philosophy, safety barrires, safety
functions etc. 5) Component, equipment and
system verification and validation covering
qualification, FAT, EFAT, SIT and operations. 6)
etc.
Accepted
Introduction has been re written to address these issues
Clause 1 1.2
Titanium reference in 1, WD4 - now in 1.2 needs
to be updated - in conflict with 7.4.2
go back to WD4 and bring reference back into
WD5 - usage in the system is acceptable, this
doc focuses on ferrous materials (non-ferrous
covered in G1)
Accepted
Last para in Clause 1.2
Replace:” This API 17G Specification is limited to
components manufactured from carbon, low-alloy steels,
and corrosion-resistant alloys. Components fabricated
from composite materials and flexible pipes are beyond
the scope of this document. However, this document does
not prohibit the use of special materials.”
With the following:
“Structural design methods and criteria given in API 17G
Specification are limited to components manufactured
from materials which ensure ductile failure modes (e.g.
carbon steels, low-alloy steels, and corrosion-resistant
alloys). Components manufactured from materials which
may not ensure ductile failure modes (e.g. composite
materials, titanium and titanium alloys) are beyond the
scope of this specification, but their use is not prohibited.”
Clause 1
Scope pg
13
#2
following f)
Editorial
This lengthy paragraph appears to be primarily
tutorial and conversational, therefore, It would
be better served as a "Note:" It does not appear
to include requirements of substance. The
reference to allowing IEC 61511 SIL ratings is
supplemental unless mandated.
Make this a Note:
Accepted
Scope 1.1 will be rewritten to adress this comment
Clause 1
Scope pg
13
#3
paragraph
Editorial
For clarity of purpose, move this to ahead of the
aforementioned note which is formerly
paragraph #2
Move this to ahead of the aforementioned note
which is formerly paragraph #2
Accepted
Scope 1.1 will be rewritten to adress this comment
Clause 1
Scope pg
14
Last
paragraph
Technical
The content of this paragraph indicates that the
remainder of the content is optional and non-
mandatory; I do not believe this is the intention
of this text. If this is intent no change is
required.
Refine the wording to have the requirements of
this specification mandatory. Accepted
Scope 1.1 will be rewritten to adress this comment
Clause 1 1.3
Specific Equipment covererd in Document section g) Topside power storage item c) is
further separated into hydraulic and electrical
power. The same philosophy should apply to
item g). Suggest defining item g) as follows:
1. subsea accumulator systems
2. Subsea battery system
Accepted
Item g) revised as proposed. (included in mark-up)
Clause 1 Fig 1-1New in WD5 and requires some explanation
AcceptedIntroduction to Figure 1-1 to be provided
Clause 3 Figure 3-2
Need to update the Figure 3-2 on the CWOR to
illustrate the annulus conduit line (Section 3.4)Rejected
Moved to WD6 Comments
Ray/Brian
Clause 3 3.1 Technical
Definition of what is meant by a DH-system and
a EH-system is required to establish consistency.
Add:
direct hydraulic IWOCS
IWOCS design where the control valves for
subsea hydraulic functions are located topside,
e.g. in a hydraulic distribution unit
electro hydraulic IWOCS
IWOCS design where the control valves for
subsea hydraulic functions are located subsea,
e.g. in a subsea control module
Accepted
3.1.95 Intervention and workover control system (IWOCS)
controls and monitors intervention, retrieval, access and
deployment of subsea well control equipment with or
without a marine riser.
direct hydraulic IWOCS
IWOCS design where the control valves for subsea
hydraulic functions are located topside, e.g. in a hydraulic
distribution unit
electro hydraulic IWOCS
IWOCS design where the control valves for subsea
hydraulic functions are located subsea, e.g. in a subsea
control module
Clause 3 3.1.184 Technical
The difference b/w the SSTTA and SSTT is not
obvious
Clarify that the SSTA a subcomponent of the
SSTTA and resides b/w the Lower shear Ram and
the PSJ.
Add the SSTT acronym to the header.
Accepted,
with
modifications
3.1.183 subsea test tree (SSTT)
the SSTT alone constitutes the primary intervention well
barrier, which isolates the well from the landing string or
C/WO riser with or without wireline and coiled tubing
present. Typically includes an upper isolation valve, lower
shear/seal valve, and disconnect latch.
NOTE 1 The SSTT valves are backup barrier elements in the
primary barrier, i.e., when the SCSSV is not available, the
SSTT valves will constitute the upper closure device in the
primary barrier after a disconnect of the SSTT latch.
NOTE 2 When the landing string is connected, the
combination of the SSTT valves and SSTT slick joint work in
Clause 3
Section
3.1.23/3.1.
24
Editorial
Section 4.20 gives broad defintion of V&V.
Section 3.1.23 and 3.1.24 only refers to testing.
Although clearly stated that list is not inclusive
this tends to imply only physical testing
Suggest broadening definitions in Section 3.1.23
and 3.1.24 to inlcude other methods of V&V or
add reference to section 4.20. Rejected
Clause 3
Section
3.1.198/3.1
.199
EditorialSame as above except refers to 3.1.198 and
3.1.199
Same as above except refers to 3.1.198 and
3.1.199 Rejecteddefinition already includes: "prove by analysis or test"
Clause 3 Figure 2 editorialno description of the entire assembly EDP+WCP
= LWORP RejectedReject.
See next line item
Clause 3 3
Define: Verification (eg FAT, FEA ..) and
Validation (qualification testing). However in
the ISO 9001` is opposite … These definitions are
outlined in Clause 3:
Qualification and Validation Interchangeable -
Ref Q1 - Design validation is proof by testing -
ISO 9000 : 2005 definitions - (2) definitions in
Qualification and Validations
Accepted
Accept as follows:
Was: "Figure 3-2: Nomenclature for a typical open-water
intervention system"
change to
"Figure 3-2: Nomenclature for a typical open-water
intervention system (LWRP)"
Clause 3 3.1.71 Technical
Definition contradicts table 6 wrt. Functional
design factor
has to include pressure
Accepted
Moved to WD6 Comments
Clause 3Definitions
General
Definitions shall not include requirements and
shall be just a definition of the term. Many of
the definitions are protracted and include
several notes; this information is much better
served within the text of the standard.
Relocate all data but single phrase or sentence
definitions of the terms into the applicable text.
Rejected
Valid comment, but no specific action, except to review
existing definitions for inclusion of potential requirements.
Clause 4 4.1 Technical
Add example of loss of station fail safe
philosophy.
EXAMPLE 3: In the event of a loss of
stationkeeping of the vessel, the CWOR system
shall be validated to have a weak point above
the WCP shear/seal devices. This is inherent
chracteristic of a fail safe system and is known as
weak point analysis.
Rejected
No basis for this comment found in 4.1
Clause 4 4.2 GeneralThe responsible for barrier philosophy should be
clear.
Operators responsible to establish an overall
well barrier philosophy.Rejected
This document addresses system requirements and
strategy not company policies.
Clause 4 4.2 GeneralEnd user is reponsible to follow operating
limitations set by the contractor(s)
Operator is reponsible to follow operating
limitations set by the contractor(s)Rejected
requirement is clear in note b)
Clause 4 4.2 General
Who has the overall HMS responsible in design,
production, testing and operation?
The responsible party shall ensure that the
management of health, safety and the
environment comprises the activities, resources,
processes and organisation necessary to ensure
prudent activities and continuous improvement
Rejected
requirement is clear in note b)
Clause 4 4.2 Technical
Section 4.2
4.2.2 System engineering
a) System engineering responsible is defined as
the role responsible for the subsea well
intervention system design and integration on
behalf of the end user.
6.2.2 System design
System design is end user responsibility.
Propose to clarify that the end user is
responsible, since the end user is the final
arbiter of the system.
Rejected
requirement is clear in note b)
Clause 4 4.13 Technical
Is the retainer valve a part of a safety system in
EQD, ref safe state?
Safe state shall ensure safety for rig and
presonnel with no or limited spill to sea from the
production bore(s). Closure of the RV shall be
evaluated as part of safe state.
Rejected
requirement is clear and covers the designed system
Clause 4 4.13 Technical
Definition of safety strategy need to be clear on
critical interlocks related to HSE.
Add new sentence:
... the basis for a safe operation of the system.
This shall include requirements for interlocks
between the different barrier elements in a
safety sequence, e.g. before a EDP disconnect
can be executed isolation of well and riser shall
be verified.
Rejected
requirement is clear and covers the designed system
Clause 4 4.13 Technical
4.13 Safety strategy
“…The reliability method used to quantify the
performance shall be based on a recognized
method of analysis, see ISO TR 12489[59]…”
Comment:
Since ISO TR 12489 is not yet formally released,
this reference is misleading. Please remove
subject reference, if not published by release of
API 17G or state in bibligraphy that publication is
pending, or replace with IEC 61511. According to
ISO CS the target publication date: 2014-05-31 Accepted
requirement revised.
Clause 4 4.13 Technical
Requirements for independance between safety
functions is unclear.
Correct:
... 3. emergency quick disconnect (EQD) to
isolate well at wellhead and disconnect from the
well.
Safety-related functions shall as far as practically
possible be independent to non-safety functions
such that a failure in non-safety systems shall
not adversely affect intended safety functions.
There should be independence between the
different safety functions to the extent that the
functional integrity of the safety functions is not
compromised. The safety strategy shall define
how many functional elements in a safety
function that shall be independent, e.g.
independent control valves and upstream
functional elements but common final functional
element like a valve, ram or connector.
Periodic testing shall ...
Rejected
requirement is clear
Clause 44.15 3r
paraTechnical
The first sentance of the para does not make
sence and this para needs to be made norative
"Components and systems, which are outside
the scope of API 17G, and have an influence on
the overall system (design, manufacture, test,
operation), shall be clearly highlighted and any
effect implemented to ensure overall
system safety. In particular, equipment supplied
in accordance with component standards (e.g.,
API 6A, API 14A, API 17D, and API 16A) are
designed and qualified for designated sizes and
rated working pressures (RWPs) only (i.e.,
pressure-based design). For subsea well
intervention system applications, it is normal
industry practice to ensure that the load
combinations determined in API 17G (e.g.,
normal, extreme, and accidental loading
conditions) do not exceed the rated capacity
(i.e., normal capacity) of pressure-based
designed equipment"
Change to "Components and systems included in
a subsea well intervention system, which have
not been design and manufactured and qualified
in accordance with API 17G, shall be indentified.
A risk assessment (see Clause 4.7.1) shall be
conducted to indentify any risk associated with
use of these components and systems Corrective
measures shall be implemented, when neccasary
to ensure . In particular, equipment supplied in
accordance with component standards (e.g., API
6A, API 14A, API 17D, and API 16A) are designed
and qualified for designated sizes and rated
working pressures (RWPs) only (i.e., pressure-
based design). During operation of subsea well
intervention systems, all loads and load
combinations determined in API 17G (e.g.,
normal, extreme, and accidental loading
conditions) shall not exceed the rated capacity
(i.e., normal capacity) of pressure-based
designed equipment"
Accepted
requiremetn was partially revised for clarity
Clause 4 4.15 Technical
Table 4-2 incorrect cross references For subsea test tree replace "annex C" with
"Annex K" for design and qualification. For
lubricator and retainer valve replace "Annex C &
D" with "Annex K & l2 for design.
Rejected
requirement is clear. Modifications to the current annexes
will provide clarity
Clause 4 4.2.5 Editorialcontent stating "hold" populate to ensure all "shall" content is
captured.Accepted
requirement is revised
Clause 4 4.5.6 Generaltext stating "all parts" seems to loose to be
captured asa shall statement
previous revision spelled out which relevant
sections of ISOAccepted
requiremetn has been clarified by removing reference to
all parts
Clause 4 4.9.a Technicalthe term "well completion" does this imply
completion installation?
allow well completion (installations/retrieval),…Rejected
completion represents installatons and retrieval
Clause 4 4.10. General
"the overall system design shall be fail-safe".
How is this possible for well completion
installation on drill pipe for vertical trees?Rejected
requirement is clear. System design and exception
requirements are clear.
Clause 4Section
4.20Editorial
There are many mislabelled references to this
section throughout document. Section 4.20 is
mislabelled Section 4.19
Change mislabelled references from Section 4.19
to 4.20. There are multiple instances throughout
body of document (too many to list)Accepted
requirements revised
Clause 4
4.14, Table
2 Accepted
Moved to WD6 Comments
Add note to Tubing hanger running tool and to tubing
hanger orientation system:
Reference to Clause 4.14 paragraph 3.
Paul will propose an update to Table 2. In progress
Clause 4 4.3, Figure General
Feedback loops are open to interpretation and
should be reassessed
Re-visit the flow diagram
Accepted
Moved to WD6 Comments
Review flow diagram
Table reference is 4-1. Tony has made a new proposal
Clause 4 4.2 GeneralAdd 4.2.5 Testing Facility Testing Facility should have a written out list of
responsibilities as wellRejected
requirement is clear for service provider
Clause 4 4.2.5 General No text in section Add hierarchy of responsibilities Accepted requirement revised
Clause 4 4.12 General
Manufacturer is instructed to eliminate or
reduce hazards, but what if the manufacturer
isn't made aware of all of the potential hazards?
Say that it is the responsibility of the end user to
inform the manufacturer of all potential hazardsRejected
requirement is clear
Clause 4 4.14 General
"No single failure of a barrier… loss of well
control" is not possible with only a single metal
to metal seal or a pipe wall between bore and
the environment
Although this would be preferred, it can not be
guaranteed with only single metal to metal seals
or with a pipe wall that could have a fatigue
failure. Remove this statement, because it's
almost impossible to guarantee with a single
tube wall or a metal to metal seal
Rejected
requirement is clear
Clause 4 4.20' General
"It shall be verified that provisions contained in
API 17G, end user's specification(s), and
regulatory requirements have been met." By
who?
Who verifies this?
Accepted
requiremetn revised
Clause 4 4.13 Technical
To define
the requirements for SIL.
c) safety instrumented systems shall be used as
one of the safety barriers. The safety functions
of the safety instrumented system for subsea
well intervention systems shall, as a minimum
unless otherwise identified in the safety
strategy, be as follows:
1. process shut down (PSD) for well flowing
conditions;
2. ESD to isolate well at wellhead;
3. emergency quick disconnect (EQD) to isolate
well at wellhead and disconnect from the well.
NOTE: A SIL rating number is not a
requirement on the safety instrumented
systems, unless specifically stated in the safety
strategy.
Accepted
requirement is clear
Clause 4 4.22 General
"Requirements not specifically required by the
end user… shall be specified by the
manufacturer." How is the manufacturer to
know other requirements if the end user doesn't
specify.
Manufacturer could be put in a hard place here,
so specify that the end user must provide and
verify that all of these requirements are fit for
purposeAccepted
requirement revised
Clause 4 4.7.1 a Editorial Qunatitive should be qualitative Change first word to qualitative Accepted Revision made.
Clause 4 4.8 Editorial 3rd paragraph below (d), include Fig 4.3 ...see Figure 4-2 and Figure 4-3 Accepted Revision made to section
Clause 4 Fig 4-6 Technical
The labels are all out of order. See Figure 4-7 for
correctd labelling. Must have been a typo. I
won't list all 18 of them here, but almost all
lablel are incorrect.
Correct labels as per Figure 4-7
Clause 4 4.13 EditorialFirst paragraph under (d), second sentence.
Should be Fig 4-8, not F-4-10
Change Fig 4-10 to Fig 4-8Accepted
4.13 is now 4.11 due to Clause revision
Clause 4 4.13 Editorial NOTE: section still have [xx] in reference replace xx in reference or remove. Accepted NOTE revised
Clause 4 4.13 EditorialFirst paragraph under NOTE, first sentence.
Section should be M.1.2.15, not M.1.3.15
replace M1.3.15 with M.1.2.15Accepted
Specific reference removed.
Clause 4 4.13
To define
the requirements for SIL.
c) safety instrumented systems shall be used as
one of the safety barriers. The safety functions
of the safety instrumented system for subsea
well intervention systems shall, as a minimum
unless otherwise identified in the safety
strategy, be as follows:
1. process shut down (PSD) for well flowing
conditions;
2. ESD to isolate well at wellhead;
3. emergency quick disconnect (EQD) to isolate
well at wellhead and disconnect from the well.
NOTE: A SIL rating number is not a
requirement on the safety instrumented
systems, unless specifically stated in the safety
strategy.
Accepted
Clause 4Section 4.8,
Table 4-1Technical
Currently, Table 1 states that a Well Intervention
operation is Not Applicable (NA) when using a
Landing String with BOP Spacer Joint. This is
misleading as setting and pulling a tubing hanger
plug after installing a vertical tubing hanger with
a BOP spacer joint could be considered Well
Intervention.
Update the Well Intervention operation when
using a BOP Spacer Joint to include d+e (vertical
dual bore tree and vertical monobore tree).
Rejected
Technical review consulted and requirement not changed.
Clause 4Section 4.8,
Table 4-1Technical
Footnote b requires clarification. Update with
the suggested change.
Well completion, well intervention and full
workover operations are limited due to lack of
barrier elements in the BOP Spacer Joint. Refer
to Section 4.6, System Review, for guidance on
how to determine if a BOP Spacer Joint is fit for
purpose for a given operation.
REjected
Requirement is clear, references to other sections within
the document are expected by the users.
Clause 4
4.16.2 Ops
from a DP
vessel
Editorial
"Preventiative measures to reduce both the
probability and consequences of drift-off/drive-
off shall be implemented."
Remove the word probability. API 17G has not
influence on reducing the probability of a drift-
off/drive-off.Accepted
referenceed wording removed
Clause 4
4.16.2 Ops
from a DP
vessel
Editorial
Bullet No. 1…"measures directed toward
reducing the probability of experiencing a drift-
off/drive-off situation"
Same comment as above. API 17G has not
influence on how to reduce the probability of a
drift-off/drive-off. API 17G should only focus the
functionality of equipment designed to secure
the well should a drift-off/drive-off occur.
Probability of the event actually happening is
outside the scope of API 17G.
Accepted
Referenced workding removed.
Clause 4
Section
4.16.2,
Table 4-3
Editorial
Dynamic positioning systems, power systems
and thruster systems are outside the scope of
API 17G
Remove Table 4-3. API 17 G should only focus
on preventative measures to reduce the
consequence of a drift-off/drive-off. API 17G has
no influence around reducing probability.Rejected
4.3 is not a NOTE and used only for informational purposes
to help clarify the document.
Clause 4
4.9, 4.10.
4.11, and
4.12
Initial
Technical
Each of these subsections requires a lead-in
sentence (paragraph) that states how to apply
and use its content. Otherwise these are
interesting lists of information without an
applicability plan.
Author lead in text to assure these topics are
applied as intended. (this may apply elsewhere
in the specification these are four examples)Rejected
Requirements are clear
Clause 4 4.13 Safety
strategy
Editorial
Because there are three or more lists within this
text and they are on at least two different levels,
it is suggested that there be internal numbering
of the content to better identify the key areas of
concern and prevent the intermixing of the
thoughts provided.
Sub-divide the section into at least four parts to
support the data provided clearly
Rejected
Requirements are clear
Clause 44.14, para
#3Technical
"At least two independent and tested barriers
between the reservoir and the environment
should be to prevent unintentional flow from
the well." I believe the intention of the authors
is to have the barriers close and seal to prevent
leakage, therefore, why offer the "should" ?
Replace the "should" with "shall" and require it
to be tested to verify the sealing.
Accepted
Requirement revised.
Clause 4
Table 4.16
Table lead
in
Technical
This table contains references to many clauses
and documents of requirements, however, the
lead-in to it does not indicate if this is just to aid
in finding the data or if these requirements are
mandatory.
Clarify the purpose of the table and its contents.
If all is mandatory that is substantial, if just
recommendations for review OK too but the
user must know. Accepted
Requirement revised
Clause 44.2 in its
entirityTechnical
The content of this section is at best disjointed
and it lacks the kind of clarity that would appear
as merited. The terms verification and validation
are used but their applicability is not clear. Is
this at a system level, an operational level or at a
component level or all the above? I think I can
develop my own philosophy about these
requirements but clarity would bring ease of use
and purpose.
A complete restructure and rewording of this
section is merited, the impact is substantial, and
therefore, clarity is merited. Perform and
document design verification of each product
and product interface to the requirements of a
documented procedure and acceptance
criteria".......... and similar wording.
Documented results and approvals are
necessary.
Accepted
Requiremnts revised and clarified
Clause 4 4.5 n)
Designer's corporate system design
philosophies.
It is assumed that the term 'corporate system' is
synonomis with 'standard'. If not please clarify
the meaning of 'corporate system'. If so please
replace with the term 'standard' as it will be
more readily understood
Accepted
Requirement revised
Clause 4 4.7 l)
designer's corporate system design
philosophies.
It is assumed that the term 'corporate system' is
synonomis with 'standard'.
If not please clarify the meaning of 'corporate
system'.
If so please replace with the term 'standard' as
it will be more readily understood
Accepted
Requirement revised
Clause 4 4.9
System Functional Requirements
Add additional comment:
m) proved means for returning the well to a safe
state in the event of an emergancy
Figure 4.6 is incorrectly labelled. Please revise
Accepted
Requirement revised
Clause 4 4.14
Barrier requirements
… During emergency operations, a minimum of
two mechanical barrier elements in the system
should be available and functioned before
removal of a portion of the WCP or SSTTA, see
Subsection 5.8 and Subsection 5.18.
Systems will now have safety joints to protect
the well head, tree, etc. As per its design, the
safety joint will break before the safety barriers
are closed. Is it relevant to mention this here.
Suggested addition:
'In the event of a separation of a safety joint, the
two mechanical barriers should automatically
close in a time that meets the safety
requirements'
Accepted
Requirement revised
Clause 4 4.15 Regulations, codes, and standards Please include the safety joint in table 4-2 Accepted Requirement revised
Clause 4 4.19
Documentation, records, and traceability
...Records of the subsea well intervention
system shall be kept and maintained to
demonstrate compliance with the requirements
of API 17G throughout its lifetime, see
Subsection 11.11.
There is no section 11.11
Accepted
Reference removed
Clause 4 4.2
Verification, Validation, and Integrity
Management
...Continuous verification and integrity
management of the subsea well intervention
system shall be conducted during the life of the
system. General guidance with regard to system
reliability and technical risk management can be
found in API RP 17N[61] and ISO 20815[60].
There is no section 11.11
Accepted
Reference Removed
Clause 4 4.2
In both modes of operation the primary barrier
envelope extends to the surface tree. The
secondary barrier envelope terminates at the
subsea isolation device. In thru-BOP/drilling riser
intervention mode, primary subsea well
isolation is provided by the subsea test tree and
secondary subsea well isolation by the subsea
drilling BOP. In open water intervention mode,
subsea well isolation is provided by the well
control package (i.e. the well control package is
a common barrier element).
Definition required: Common Barrier Element
Rejected
Requirement is clear
Clause 4.13
To define
the requirements for SIL. Jamie's text
c) safety instrumented systems shall be used as
one of the safety barriers. The safety functions
of the safety instrumented system for subsea
well intervention systems shall, as a minimum
unless otherwise identified in the safety
strategy, be as follows:
1. process shut down (PSD) for well flowing
conditions;
2. ESD to isolate well at wellhead;
3. emergency quick disconnect (EQD) to isolate
well at wellhead and disconnect from the well.
NOTE: A SIL rating number is not a
requirement on the safety instrumented
systems, unless specifically stated in the safety
strategy.
Accepted
Clause 5 5.2 Technical
second last sentence of section : Rams
with bidirectional hydraulic actuators shall
include an automatic and mechanical locking
system to prevent
unintentional opening;
Rams with bidirectional hydraulic actuators shall
include an automatic and mechanical locking
system to prevent
unintentional opening or closing........ some
designs out there will close due to bore pressure
if actuator open pressure is lost, not always a
good thing if wireline is getting run at that point.
Accepted
New Text " Rams with bidirectional hydraulic actuators
shall include an automatic and mechanical locking system
to prevent unintentional opening or closing."
Clause 5 5.4 Editorial
The following should be none prefixed list items
list items: " - active (rotary) type, requiring the
rotation ……." and " - passive (helix/linear) type,
uses downward …."
Revise as commented.
Accepted
Missing letter bullets from sent WD 5 document, was
correct before hand.
Clause 5 5.4 Editorial
Ist para "The purpose of the tubing hanger
orientation system is to orientate the tubing
hanger before engagement of the
tubing hanger seals in the sealing bore(s)"
combines both a purpose and a requirement. Th
erequirem,enst is given in the 4th para. 1st
Should only include purpose.
Change "The purpose of the tubing hanger
orientation system is to orientate the tubing
hanger before engagement of the tubing hanger
seals in the sealing bore(s)" to "The purpose
of the tubing hanger orientation system is to
orientate the tubing hanger"
Accepted
New Text "The purpose of the tubing hanger orientation
system is to orientate the tubing hanger."
Clause 5 5.10.1 Technical
The following provison is not precise and can
misunderstood to mean that a singel valve shall
have both types of failure modes. "The retainer
valve shall be a remotely operated, “fail-in-
position” or “fail-safe close” isolation valve
depending on operational requirements."
This provision shall be changed to "The retainer
valve shall be a remotely operated and shall be
either “fail-in-position” or “fail-safe close”
isolation valve depending on operational
requirements." Accepted
new text "The retainer valve shall be a remotely operated,
and shall be either “fail-as-is” or “fail-safe close” isolation
valve, depending on operational requirements."
Clause 5 5.10.1 Technical
Ambiguous statement:
"Retainer valve design(s) shall support both fail-
in-position and fail-safe close configurations,
and position shall be fixed before deployment."
Statement as written is confusing and can be
understood that the same valve shall be
designed to have both failure modes and would
exclude spring assisted actuator designs.
This sentance is uncessary and the normative
requirements is covered in the preceeding
sentance (i.e."The retainer valve shall be a
remotely operated and shall be either “fail-in-
position” or “fail-safe close” isolation valve
depending on operational requirements.")
Delete the following "Retainer valve design(s)
shall support both fail-in-position and fail-safe
close configurations, and position shall be fixed
before deployment."
Accepted
Accept in principle, but the statement is required such that
the valve if it has a spring close and then have the spring
removed (as stated in comment). This is required due to
the possible saftey stratery.
New text "Retainer valve design(s) shall support both “fail-
as-is” and “fail-safe-close” configurations by either physical
or via control system logic, but the position shall be fixed
before deployment."
Clause 55.21.2 Item
eTechnical
"Hydraulic functions for EDP and TRT connectors
shall be incorporated into the intervention and
workover control system (IWOCS) operating
system"
Statement as written would exclude installing XT
on wire with ROV-operated TRT
Replace "Hydraulic functions for the EDP
connector and WCP connector (TRT) shall be
incorporated into the intervention and workover
control system (IWOCS) operating system" Accepted
new text "Hydraulic functions for the EDP connector and
WCP/TRT connector shall be incorporated into the
intervention and workover control system (IWOCS)
operating system."
Clause 5 5.18 c) Editorial
The interface connection between the TRT and
the rest of the LWRP shall have
a defined minimum combined structural
capacity equivalent the subsea tree.In addition
to the pressure capacity rating shall not less
than the pressure rating of the subsea tree;
In addition the pressure capacity rating shall not
be less than the pressure rating of the subsea
tree.
Accepted
new text "c) The tree running tool (TRT) shall interface with
the subsea tree's re-entry spool and may be integral to the
LWRP, WCP or a separate item. The TRT shall comply with
the functional requirements specified in API 17D. The
interface connection between the TRT and the rest of the
LWRP shall have a defined minimum combined structural
capacity equivalent the subsea tree. In addition the
pressure capacity rating shall not be less than the pressure
rating of the subsea tree."
Clause 5 5.18 d) Editorial
These upper interface connection(s) shall have a
defined minimum combined structural capacity
equivalent the subsea tree. In addition to the
pressure capacity rating shall not less than the
pressure rating of the subsea tree;
These upper interface connection(s) shall have a
defined minimum combined structural capacity
equivalent to the subsea tree. In addition the
pressure capacity rating shall not be less than
the pressure rating of the subsea tree.Accepted
new text "d) The WCP may be configured as a single unit or
as a sectioned unit (reference Annex A) and may be
equipped with an upper re-entry spool interface with the
EDP or with a connection to mate with the lower end of
the C/WO riser. These upper interface connection(s) shall
have a defined minimum combined structural capacity
equivalent the subsea tree. In addition the pressure
capacity rating shall not be less than the pressure rating of
the subsea tree.;"
Clause 5 5.19 Editorial
Second paragraph : Choice of
configuration will depend on the type of subsea
tree and the other types of well intervention
equipment may have accessed the well.
Choice of configuration will depend on the type
of subsea tree and any other type of well
intervention equipment that may have accessed
the well.Accepted
New text "Note: The choice of configuration will depend
on the type of subsea tree and any other type of well
intervention equipment that may have accessed the well."
Clause 5 5.21.1 p) Editorial
p) reuse of seals, seal rings/gaskets that are
replaceable on the surface vessel shall be as
specified by the
manufacturer and shall be available for
inspection and easily replaceable on the surface
vessel.
This is a repeat of 5.21.1 l)....remove one or the
other
Accepted
Remove p. see mark up
Clause 5 5.21.2 j) Technical
the connector should allow for low-pressure
back seal testing to ensure that the
connector/seal is correctly made up;
surely this requirement is introducing an
unneccesary leakpath, suggest that it removed
as a internal pressure test would always be
preferable
Accepted
Delete j). This as picked up in API colour code and it cant
be shall, as it is only a should therefore remove.
Clause 5 5.21.3 f) Technical
Riser connectors should be designed with
rotational orientation to enable monitoring of
tubing hanger angular orientation before
landing or subsea test tree latch angular
orientation prior to re-entry;
This statement suggest that the the connection
must have some sort of timing feature to ensure
it always ends up in the same orientation once
made up...how is this possiple with T&C design
riser joints ...suggest this statement is either
clarified or removed
Accepted
Remove f), as it was also yellow coloured by API.
Clause 5 5.21.1 Editorial Item L and P are the same Delete item P Accepted duplicate of Line 51.
Clause 5 5.25 Technical
these are the b) and c) that come after g) for
some reason, suggest that they become i) & ii)
of g) b) to
accommodate asymmetric pull caused by
malfunction of at least one tensioner; c)
to accommodate skew loads due to
misalignment of the vessel’s tensioner wires;
Surely these are extreme or accidental events
...we should not need to design for these but
should consider them as extreme or accidental
load cases onlyRejected
You still require to design for these conditions if they are
extreme or accidental. The design safety factors will be
different and you can document what the capability is then
it is up to the client to determine if there is enough safety
factor.
Clause 5 5.25 Technical
When tension joint is connected to Direct Acting
Tensioners (DAT), provisions should be given to
avoid large skew compression loads on the riser
following a DAT cylinder lock-up on a wave crest
Modify sub-bullet b) as follows:
to accommodate asymmetric load caused by
malfunction of at least one tensionerAccepted
new text " 2. to accommodate asymmetric pull load caused
by malfunction of at least one tensioner."
Clause 5 5.25 Technical
To ensure simple and safe make-up of the
tension joint to the uppermost standard riser
joint, connections requiring rotation and
torquing of the tension joint should be avoided.
Amend bullet f) as follows:
the bottom of the tension joint shall be
connected to a standard riser joint. The bottom
connection shall be a non-rotational quick
connector, ref. Subsection 5.21.5
Rejected
This is an optional addition and can not be mandatory
Clause 5 5.30 General
A note on responsibility for selection of
connector should be added. Wireline/coiled
tubing adapters constitute the interface
between the well intervention system provider
and the coiled tubing system provider
Add the following: "NOTE Wireline/coiled tubing
adapters constitute the interface between the
well intervention system provider and the coiled
tubing system provider" Accepted
new text "c) NOTE: Wireline/coiled tubing adapters
constitute an interface between the well intervention
system provider and the coiled tubing system provider."
Clause 5Section
5.35Editorial
Portions do not fit with the adjoining text. This
pertains to the phrases starting with "dynamic
environmental load …" and ending with "… in
accordance with API 7k".
Align these phrases with the adjoining text as
intended. If each phrase is meant to be a unique
item within this listing, the last listing within this
section will be identified by letter "t)' once
corrected.
Accepted
Changed section call out as it stated 5.35 which was
incorrect.
Wrong in WD 5.2 document but correct as per marked up
document.
Clause 5Section
5.35Editorial
Portions do not fit with the adjoining text. This
pertains to the phrases starting with "provision
of sufficient …" and ending with "… into the
marine drilling riser".
Align these phrases with the adjoining text as
intended. If each phrase is meant to be a unique
item within this listing, the last listing within this
section will be identified by letter "j)' once
corrected.
Accepted
Changed section call out as it stated 5.35 which was
incorrect.
Wrong in WD 5.2 document refer to marked up document.
Clause 5 5.7 Technical
The below requirement applies dual bore
vertical trees. Horizontal access to the annulus
on horizotnal trees is through the crossover
wing valve and not through the SSTT.
c) Permit fluid access to the production tubing
and the annulus between the production tubing
and last casing string to allow pressure testing
and fluid circulation;
Revise to clarify that this only applies to dual
bore vertical trees.
Accepted
New Text "c) Permit fluid access to the production tubing
to allow pressure testing and fluid circulation. Permit fluid
access to the annulus between the production tubing and
last casing string for vertical trees
Clause 55.10.1
5.11Editorial
"fail-in-position" used in 5.10.1 (RV) while "fail-
as-is" used in 5.11 (LV)
Change 5.11 to match 5.10.1
Accepted
Accept with in principle, changed 5.10.1 to match 5.11
new text to add to 5.10.1 " replace "fail-in-position" with
"fail-as-is"".
Clause 5 5.10.2 Technical
RV does not not need to be gas tight after
shearing coil tubing during. Some amount of
leakage could be allowed since finite source of
gas in landing string
Add comment to section. Leakage rate similar to
that recommended for RSM could be acceptable.Rejected
This is a option of cutting with the RV, however in
deepwater riser could hold a large volume of gas and as
such will have to seal. Leakage criteria given in Annex K.
Clause 5 5.21.2 Technical
sub section e) states the unlocking force shall be
greater than the locking force. This can be an
issue in deepwater in riser connectors due to
differentials between control fluid and
completion brine.
Change shall to should.
Add statement about pressure differentials as
result of completion brine and control fluid
density to be considered and reviewed during
HazOp. Accepted
Agree in principle but can not be a should otherwise it
could unlatch even in deepwater. Also modified due to API
Colour coding.
new text "e) The connector shall be hydraulic and remotely
operated. The connector design shall provide greater
unlocking force than locking force, typically 25% greater,
however, it is the responsibility of the manufacturer to
document the locking and unlocking pressures and forces ,
taking into account pressure differentials due to dis-similar
fluids."
Clause 5 5.21.2 Technical
sub section j) back testing of seals to be
provided. This can lead to excessive seperation
force if the port is plugged and a seal leaks.
Back testing of seals should be optional.
Accepted
Delete j). This as picked up in API colour code and it cant
be shall, as it is only a should therefore remove.
Clause 5 5.26 Technicalsub section a) pupose is to provide protection to
umbilcal. If there is no umbilical then there is no
need for CWJ
…protective sleeve that extends trhoguh the
rotary and protects and umbical from damage as
the rig heaves.
RejectedThis point is covered in new e) was old d)
Clause 5 5.26 Technicalsub section b) CWJ are normally rigid pipes with
a slot. The stiffness is an issue and should be
considered as part of the GRA.
Add statement that stiffness be consdiered in
GRA. RejectedThis is covered in Annex B, which details the GRA etc
Clause 5 5.26 Technical
CWJ may be required to transmit torque to align
THRT or SSTT Latch.
Add statement that troque transmission be
considered based on the project requirements.
Rejected
Correct the CWJ may have to take torque, but so will most
other connections, therfore it shold be taken into acocunt
during the design phase the use of the CWJ. I.e. is it a bolt
on or a one piece body.
Clause 5 5.27 Technical
General RSM comments:
1) They may be used alone or in combination
with CWJ's
2) The diverter may be closed on an RSM so the
strip thru load capacity needs to be defined
3) The RSM shall be rated for 500 psi external
pressure with a acceptable gas leak rate of 100
psi in 10 minutes with an initial gas volume of
6.8 ft^3
Add comments as stated
Accepted
Point 1 is rejected.
Point 2 is rejected. Strip through capacity is based on the
divertor bags
Point 3 is accepted but the on the gas rate is not applicable
to add as it depends on the diverter.
New Text.
b) The riser sealing mandrel shall provide the means to
allow closure of the riser diverter bag on its external bore
while providing a seal to protect the rig floor above it. The
riser sealing mandrel shall be rated for 500psi external
pressure and the leakage rated recorded for each 100psi
increment. The leakage rate shall be reviewed against the
diverter design during the safety strategy.
Clause 5 5.27 Technical
sub section b) states the length should be long
enough to allow compensated heave of the rig.
The RSM length and psoition is based on the
disconnect position of the string and wether it is
being used in comination with a CWJ. The
disconeect position is when the SSTTA is
unlatched and picked up to clear the LMRP /
BOP connector.
Add a section on RSM length and postion
determination
Accepted
New text
c) The riser sealing mandrel shall have internal conduits or
covered slots where umbilical hoses can be constrained
and protected from being damaged by the diverter bag.
The riser sealing mandrel shall be long enough to allow
compensated vertical movement (heave) of the rig and the
distance from the unlatch SSTTA to the LMRP / BOP
Connector point..
Clause 5 5.29 Technical
sub section e) New WOM 7-3/8 flowhead does
not have manual overide of wing valves
Change wing valves to have optional manual
overide
Accepted
Have added should has if the safety strategy states there
shall be override then it will be required.
New Text.
e) Annulus bore and main bore isolation valves shall have a
secondary means of operation/override if defined in the
safety strategy. Fail-safe-close valve type actuators (e.g.,
with spring force to close) should have override to open.
Fail-in-position valve actuators should have override to
close or open.
Clause 5 5.28 Technical
sub section a & b) On in-riser C/WO, FHD
conencts to CWJ or RSM whiel reference is to
slick joint
Add CWJ and RSM to reference
Accepted
new text for purpose "The purpose of the surface tree
adapter joint is to provide an interface between the
surface tree and the slick joint, cased wear joint or riser
sealing mandrel. Alternatively, the surface tree adapter
joint may be integral with the slick joint."
new text for "b) The bottom connection shall match the
interface with the slick joint, cased wear joint, riser sealing
mandrel or with a connection to mate with the riser."
Clause 5 5.29 Technical
subsection j) pressure monitoring at FHD is
possible but not required
no change required since statement is "should"
Rejected
j has been removed as it is a should rather than a shall and
will not pass the API colour code.
Clause 5 5.29 Technical
General FHD comments:
1) bending stresses of upper and lower subs
should be considered in GRA
2) swivel as described in section 5.3.2 may be
installed above master valve
no change required since statement is "should"
Rejected
not clear enough proposal.
Clause 5 5.31 Technicalh) rotation does not need to be accomodated if
there is a provided below.
change shall to shouldRejected
comment not clear. Rotation shall allow relative rotation
Clause 5 5.31 Technical
l) recommendation for an ingersoll rand product
should not be part of this specification. In
addition the device would need to have a speed
greater than the rig prevent injuries as personell
approached the rig floor.
change recomendation description and add
speed consideration.
Accepted
remove. K) defines winch, and agree should not list one
company supply product.
Clause 5 5 Editorial
multiple areas of the text do not reference the
correct table. For example, in section 5.2, 4th
paragraph states table 5-5 which should be table
5-1.
Accepted
Clause 5 Figure 5-1 Generalgraphics of drift bar dimensions are blurry
Acceptedbetter graphics required. Refer to word document for
clearner picture
Clause 5 5.3.g Technical
all seals shall be independently qualified… all seals shall be qualified…
more plyable for all supplier to prove their
component design meet the
environment/design specifications.
Accepted
Remove "independently"
Clause 5 5.8.j Technical
chemical injection line/port shall be located
between the valves.
shall include a chemical injection line/port with
duel sealing/backflow valve arrangement. Ideal
location is always below a well barrier. Rejected
This would be a downhole line. Ideal location is between
well barrier elements otherwise no way to stop hydrates in
this location or to see if lower barrier elemant is sealing.
Clause 5 5.8 Editorial check lettering bullets - not fluent Accepted format is not correct see mark up in document
Clause 5
5.8.a the
second "a"
bullet
Technical
shall be above the upper SSTT valve. Spell out
which valve - top well isolation valve or the
landing string/riser containment valve.
shall be above the upper well isolation valve…
Rejected
Is actually 5.8, K.1.
It states uppr valve and it is part off SSTT, therefore clear it
is the upper most valve in the SSTT.Note it is not SSTTA,
stated here.
Clause 5
5.8.c the
second "c"
bullet
Technical
shall have an active pressurized latch function to
be engaged…
change "pressurized" to "positive". Currenty it
implies only hydraulic style latches are possible.
Accepted
Is actually 5.8, K.3.
new Text "3. shall have an active positive latch function to
be engaged during the entire operation. The connection
shall be designed to allow for tagging on a subsea drilling
BOP ram."
Clause 5 5.18 EditorialFigure reference numbers in the text do not
match the picturesRejected
they match
Clause 5 5.3 n Editorial There are no clause 6.5.2.3 or 6.5.3.3 correct for appropriate clause Rejected This is not in 5.3n nor Clause 5.
Clause 5 5.4 Editorial
The following should be none prefixed list items
list items: " - active (rotary) type, requiring the
rotation ……." and " - passive (helix/linear) type,
uses downward …."
Revise as commented.
Accepted
Duplicate of Line 43.
Clause 5 5-1' General
What is the purpose of this table if it's only for
nominal flange size? What about casing,
drillpipe, etc.?
Remove table or create drift table for casing,
drillpipe, etc.Rejected
Table provides general sizes used in open water and in
riser equipment. Main section been has re-writen so sizes
can be taken for casing drill pipe etc using the same
relationships
Clause 5 5.3 Technical
d) Infers that only a single metal-to-metal seal (a
single seal) will be an adequate barrier between
the bore and the environment
If so, then there's no redundancy in sealing. Is
that ok? Specify that if a metal-to-metal seal is
used in the connection and pressure rated it can
be the stand alone sealing mechanism if the end
user agrees to just a single seal
Rejected
If metal to metal seal is used and is qaulified then single
seal can be used. If using elastomers then two barriers
required.
Clause 5 5.21.1 Editorial e) subsection 6.4.11.5 does not exist Create 6.4.11.5 or fix reference Accepted Reference should be 6.2.7
Clause 5 5.21.3 Technical
j) for a metal to metal seal which features
mating surfaces of two machined surfaces,
should this requirement still be required?
Make corrosion resistance sealing surfaces
recommended and not required Rejected
There should br cossion resistance on the parts.
new text "j) All sealing surfaces shall exhibit a means of
corrosion resistance."
Clause 5 5.22 General
a) What about drillpipe? Drillpipe is not
considered OCTG
Include drillpipe as an option for landing strings,
because drillpipe is not OCTG
Accepted
There are various areas were Drillpipe is classidied as a
OCTG, however the word shall has been replaced with
should.
New text.
Standard landing string joints should be based on oil
country tubular goods standard lengths to facilitate
racking. All standard joints should have equal length
Clause 5 5.7 EditorialBullets b) and c) missing from text for bore
selector and for landing string adapter.
Add bullet b and c.Rejected
Bullets are in WD5.2
Clause 5 5.3 and 5.4 Editorial
Would be good if you could manage the page
breaks so that the figure and the text/key are on
the same page.Accepted
Im assuming this is the figure 5-3 & 5-4 as clauses 5.3 & 5.4
do not have figures.
When editing please ensure the the figures and title are on
the same page
Clause 5 5.19 Editorial
second paragraph text refers to Fig 5-5, not 5-4. Change reference of paragraph 2 to Fig 5-5
Accepted
Comment is wrong way round. Text references figure 5.4
but should be 5.5.
This also affect clause 5.18.
Clause 5 Section 5.5 Editorial
"A BOP spacer joint does not normally include
any remote-controlled well control devices; its
use is generally limited to operations on killed
wells." This statement is misleading.
Consider revising to state that "its use is
generally limited to operations on wells that are
isolated from the production zone". Many
tubing hangers are installed in the GOM on "live"
wells using a BOP Spacer Joint along with a
mechanical barrier in the lower completion,
isolating the production zone during installation
of the upper completion.
Accepted
New Text "A BOP spacer joint does not normally include
any remote-controlled well control devices; its use is
generally limited to operations on wells that are isolated
from the production zone."
Clause 5Section
5.18Editorial
bullet d)…missing "be"…"The WCP may be
configured..."
Correct sentence
Accepted
New Text "d) The WCP may be configured as a single unit
or as a sectioned unit (reference Annex A) and may be
equipped with an upper re-entry spool interface with the
EDP or with a connection to mate with the lower end of
the C/WO riser. These upper interface connection(s) shall
have a defined minimum combined structural capacity
equivalent the subsea tree. In addition the pressure
capacity rating shall not be less than the pressure rating of
the subsea tree.;"
Clause 5 5.18 Editorial
Note 4 references figure (d) and e) as single and
sectioned WCP configurations, however the
WCP illustrated are indentical for both
Should Note 4 be revised to state the figure e)
illustrates a EDP/WCP configuration that allows a
disconnect of the riser for suspension
operations, while figure d) does not?Accepted
Accept in princple.
New Text "Figure 5-5 d) and e) illustrate WCP
configurations where at least two barrier elements are left
behind should well intervention operations be suspended
for an extended period."
Clause 5 5.29 Technical
bullet d) that all surface tree valves shall be
remotely operated and fail-safe close. This
statement should only apply during well test or
flow back operations. Such surface trees are
rarely used when landing a tubing hanger in
wells equipped with vertical trees with no
planned slickline or wireline operations and
wells with a bi-directional barrier isolating the
production zone during upper completion
installation.
Revise this bullet to state that remotely
operated and fail-safe valves shall be during well
intervention, post production or a well test. This
is not a "shall" during initial well construction.
Rejected
There are operations of landing the TH which require this
functionality as the tubing plugs will be pulled. If during
the well construction this is not required then this can be
waved during the safety strategy.
Clause 5
5 Drift
requireme
nts
#3 and #4
Technical
The terms "if possible" allow the designer to
ignore the requirements without justification.
This text would be better to use "where required
by the technical design and justified by approved
documentation a deviation from these drift
requirements may be acceptable." Combine the
next paragraphs #3 and #4.
Accepted
Due to comment plus API colour codes Section 5.2 should
now read;
"Each tubular section of a subsea well intervention system
or component within the system that requires a tool to be
passed through it shall be drift-tested
Drift testing shall be performed at both the system level
and the component level.
At a system level, drift testing shall be conducted with the
system’s minimum bore size.
At the equipment level, it shall be drift tested to the
equipment’s nominal bore diameter.
The purchaser shall specify the drift requirements of the
tubing hanger through-bores.
In cases where an alternative nominal bore size is used, the
same relationship between drift major and minor
diameters and nominal bore size shall be maintained.
Note: Consideration should be given to component
deflections, flow-by area during tool string operations,
changes in center lines, and steps in equipment packages
Clause 5
5.8 Subsea
test tree
Requireme
nts listing
Editorial
Within the letter identified listing, an anomaly
occurred after item k) on page 78. I believe the
intent may be to start a new listing after the
new item a). However, the letter designation
does not indicate that correctly. Additionally,
the next 14 items start with "shall" this term
can therefore be used in the lead-in sentence to
eliminate the redundancy
Re-structure this listing ro add clarity, eliminate
redundancy and to provide a clear purpose.
Rejected
Formating is corerct on WD5.2
Clause 5 5.10.1 Technical1. failure mode of the retainer valve (e.g., fail in
position or fail-safe-close);
1. failure mode of the retainer valve (e.g., fail-as-
is or fail-safe-close);Accepted
Clause 5 5.10.2 (c.) Technical
API Colour code issue with current text.
may be designed to allow closure of the subsea
drilling BOP annular preventer on the external
surface. If this design feature is included, then
the following shall apply
c) If the design allows closure of the subsea
drilling BOP annular preventer on the external
surface, then the following shall applyAccepted
Clause 5 5.10.2 (d) Technical
API Colour code issue with current text.
d) As defined within the safety strategy, the
retainer valve may be required to cut coiled
tubing, braided wireline, and slickline and seal in
accordance with Annex K procedures and as
specified by the end user requirements.
d) If defined within the safety strategy, the
retainer valve may be required to cut coiled
tubing, braided wireline, and slickline and seal. If
cutting is defined, then cutting shall be, in
accordance with Annex K procedures and as
specified by the end user requirements.
Accepted
Clause 5 5.10.3 (a) Technical
API Colour code issue with current text.
a) The retainer valve or EDP shall include
features to vent trapped pressure between the
closed retainer valve and the shut-in WCP to
open sea in the case of an EQD. Any venting
functionality may be ported to the
circulation/kill line(s) to prevent venting into the
open sea.
a) The retainer valve or EDP shall include
features to vent trapped pressure between the
closed retainer valve and the shut-in WCP to
open sea in the case of an EQD.
Note: Any venting functionality may be ported to
the circulation/kill line(s) to prevent venting into
the open sea.
Accepted
Clause 5 5.10.3 (c.) Technical
c) As defined within the safety strategy, the
retainer valve may be required to cut coiled
tubing, braided wireline, and slickline and seal,
in accordance with Annex L procedures and as
specified by end user requirements.
c) If defined within the safety strategy, the
retainer valve may be required to cut coiled
tubing, braided wireline, and slickline and seal. If
cutting is defined, then cutting shall be, in
accordance with Annex L procedures and as
specified by end user requirements.
Accepted
Clause 5 5.18 (g) Technical
add in new item to list service conditon etc insert as a new item
The following service condition classes and
ratings shall apply for well control devices in the
LWRP:
1. Service specification level (i.e. SSL-Liquid and
SSL-Gas) shall be in accordance with Annex L.2.1.
2. Pressure rating shall be in accordance with
Annex L.2.2.1.
3. Temperature rating shall be in accordance
with Annex L.2.2.2.
4. Material class rating shall be in accordance
with Annex L.2.2.4.
5. Safety class (i.e. safety function class and
normal operation class) shall be in accordance
with Annex L.2.2.5.
6. Service class (i.e. sand class I, sand class 2 and
sand class II) shall be in accordance with Annex
L.2.2.6.
7. Shear class i.e. wireline/coiled tubing class and
safety head class ) shall be in accordance with
Annex L.2.2.7.
Accepted
Clause 5 5.18h Technical
add "be operated by " h) Other interfaces may be operated by a diver
or remotely operated vehicle (ROV) control
function interfaces. The ROV interface shall
comply with API 17H;
Accepted
Clause 5 5.18l Technical
Remove "Bores in the LWRP should be the same
or larger then the bore of the subsea tree". API
Colour issue & not really required
Necessary transitions shall be provided in mating
riser components to accommodate changes in
bore sizes or bore spacing to the tree bore
spacing specified in API 17D, to allow passage of
drifts or through-tubing tools for vertical access
into these bores whenever applicable;
Accepted
Clause 5 5.18m Technical
m) Consideration shall be given to the possibility
of overhead clearance problems when stacking
or handling the LWRP and subsea tree together
in the cellar deck. Stack-up height will affect
riser design relative to moment loading at the
subsea tree and LWRP interfaces. Allowable
stack-up height shall therefore be agreed in
each case.
API Colour issue & not really required
m) Consideration shall be given to the possibility
of overhead clearance problems when stacking
or handling the LWRP and subsea tree together
in the cellar deck. Allowable stack-up height shall
therefore be agreed in each case.
Note: Stack-up height will affect riser design
relative to moment loading at the subsea tree
and LWRP interfaces
Accepted
Clause 5 5.20. TechnicalAdd a note in front of "A WCP may typically
include the following components". API colour
code issue
Note: A WCP may typically include the following
components: Accepted
Clause 5 5.20. Technical
Delete "The number of sealing rams or shearing
valves used in the shear/seal device may vary
depending on the design
of the closure device and the purchaser’s
requirements. The WCP shall include, as a
minimum, the following
valves:
a) an upper bidirectional isolation valve in every
through-bore;
b) a shearing device in any bore that will have
coiled tubing or wireline equipment (or any
other tool/device) in the bore."
new text: "The number and type of well control
devices, safety class of well control devices, and
shear class of well control devices shall be
configured to achieve a safe-state condition for
each applicable safety function as specified in
the safety requirements specification, see
section 4.13 and Annex M.1.2.16. As a
minimum, the vertical through access bores in
the WCP shall include the following well control
devices:
1) an upper bidirectional isolation valve in every
through access bore;
2) a shear/seal device in any bore that will have
coiled tubing or wireline equipment (or any
other tool/device) in the bore.
The shear class, safety head class for well
control devices, shall be selected when there is a
risk for accumulation of multiple work strings in
the vertical through access bores(s) of the WCP
and/or when anything more than a wireline or
coiled tubing shall be run through the WCP.
Selection of shear class shall be included in the
safety requirements specification"
Accepted
Clause 5 5.20. Technical
The is para should be moved further down in
the clause “The WCP shall provide all mechanical
support and be able to withstand the combined
effects of both riser tension and bending, as well
as internal and external pressure.”
move to the end of the section
Accepted
Clause 5 5.21.1 Technical
Bullet points G, H & M require to be moved to
the end of the section as notes rather than
bullet points.
Note 1: Connectors and/or associated running
tool(s) should provide positioning and alignment
of mating components such that connection can
be accomplished without damage to sealing
surfaces or structural connection devices;
Note 2: If an environmental seal is used,
consideration to pressurizing control lines by
possible communication with the production or
annulus bore should be given;
Note 3: Effects of pressure end loads acting over
the area enclosed by the environmental seal
should also be considered in the design because
one or more of the interior seals could leak;
Accepted
Clause 5 5.21.1 (q) Technical
API colour issue, remove "Dimensional control
may be performed with go/no-go gauges in
place of regular interchangeability tests, if
applicable."
machining tolerances and clearances shall be set
such that all connectors of the same design and
configuration are interchangeable. Production
dimensional control shall be performed to
ensure interchangeability.
Accepted
Clause 5 5.21.2 (i) Technicalmissing text "and shall be" An external position indicator shall be provided
and shall be suitable for observation by
ROV/diver
Accepted
Clause 5 5.21.3 (k) Technical Delete as covered in Section 5.3 Delete J Accepted
Clause 5 5.21.3 (m) Technical
API Colour code issue. "A back-seal test, i.e., a
low-pressure test to check correct installation of
seal, can achieve this" should be a note not in
main text
The connector may provide a means for pressure
testing of the connection after makeup without
pressurizing the C/WO riser.
Note: A back-seal test, i.e., a low-pressure test to
check correct installation of seal, can achieve
this.
Accepted
Clause 5 5.21.4 (€) Technical
API Colour Issue & following statement causing
confiusion.
"For example, this requirement may be achieved
with the use of an inlay or surface coating. "
All sealing surfaces shall exhibit a means of
corrosion resistance. Accepted
Clause 5 5.21.4 (c.) Technical
API Colour Issue & following statement causing
confiusion.
"A suitable flange, a hub, or a proprietary riser
connector may be used. "
c) The lower end of the stress joint shall be
suitable for connecting to either the EDP
connector or the TRT. Accepted
Clause 5 5.21.4 (g) Technical Delete as covered in Section 5.3 Delete J Accepted
Clause 5 5.26 (a) Technical
Split (a) into to sections and create a new (b)
and also remove "The cased wear joint, if
installed, shall "
A & B should be as per below.
a) Shall provide a protective sleeve that extends
through the rotary table. Unless otherwise
agreed upon, the sleeve shall be removable to
enable inspection and maintenance of interior
pipes.
b) The sleeve length shall be sufficient to pass
through the rotary table, diverter, and ball/flex
joint, including extra length to allow for vessel
motion relative to the riser string.
Accepted
Clause 5 5.26 (b) Technical
Remove "The bending stiffness introduced by
the sleeves should be reduced to reduce the
bending moments introduced in the connecting
riser joints. Continuous or segmented sleeves
may be applied." due to API colour issue and
moved to end of section as a note.
Note:The bending stiffness introduced by the
sleeves should be reduced to reduce the bending
moments introduced in the connecting riser
joints. Continuous or segmented sleeves may be
applied.
Accepted
Clause 5 5.26 (c.) Technical
Remove "The top end of the cased wear joint is
connected to the surface tree adapter joint. The
bottom end of the cased wear joint may be
connected to the tension joint or a spacer joint
(pup joint)."
C wording now "c) The cased wear joint shall,
unless otherwise specified, be equipped with
standard riser connectors. " Accepted
Clause 5 5.26 (d) Technical
Below wording requires re-wording due to API
colour comments.
A control umbilical may run in parallel with the
cased wear joint. In such cases, it shall either run
inside the outer sleeve or be properly supported
on the outside in a suitable groove or recess in
the sleeve to prevent damage to the umbilical as
it passes through the rotary table, diverter, and
ball/flex joint.
new wording "e) if a control umbilical is used
with the cased wear joint, it shall either be run
inside the outer sleeve or be properly supported
on the outside in a suitable groove or recess in
the sleeve to prevent damage to the umbilical as
it passes through the rotary table, diverter, and
ball/flex joint."
Accepted
Clause 5 5.28 (c.) Technicalc) The adapter joint shall be made made as short
as possible
c) The adapter joint shall be designed with the
shortest possible lengthAccepted
Clause 5 5.29 (b) (c.) Technical
b) The surface tree shall be a vertical through-
bore design. The vertical bore(s) shall permit the
clear passage of wireline/coiled tubing tool
strings. the number of bores should be
compatible with the landing string or C/WO riser
design and operation.
(c.) should be removed and incorporated into b
New Text.
b) The surface tree shall be a vertical through-
bore design. The vertical bore(s) shall permit the
clear passage of wireline/coiled tubing tool
strings.
Delete c) The vertical bore(s) shall permit the
clear passage of wireline/coiled tubing tool
strings
Accepted
Clause 5 5.29 (d) Technical
remove current (d) wording and replace due to
Tony's comments to tie in with Annex L
new text
"The number of well control devices and safety
class of well control devices shall be configured
to achieve a safe-state condition for each
applicable safety function as specified in the
safety requirements specification, see section
4.13 and Annex M.1.2.16. As a minimum, the
surface tree well control device arrangement
shall consist of:
1) One valve in each vertical bore.
2) One wing valve for each vertical bore unless
specified otherwise by the end user.
3) All valves shall be remotely operated.
4) Wing valves shall be remotely operated, fail-
safe-close with bidirectional sealing.
5) Master and/or swab valves shall be remotely
operated, fail-in-position with bidirectional
sealing; "
Accepted
Clause 5 5.29 (i) Technical
"Wing and kill outlets should be arranged 90°
down" to be moved as a note in the text, due to
API coloour code
i) Outlets shall have provisions for attachment of
flexible pipes or swivel connections. Bending,
tension, and shear loads induced by the flexible
jumpers, combined with internal pressure, shall
be considered in the design of the outlets.
Note: Wing and kill outlets should be arranged
90° down.
Accepted
Clause 5 5.29 (k) Technical
"The wireline/coiled tubing adapter may be
separate or an integral part of the tree" to be
moved as a note in the text, due to API coloour
code
k) The top of the surface tree shall support the
wireline/coiled tubing adapter.
Note: The wireline/coiled tubing adapter may be
separate or an integral part of the tree.
Accepted
Clause 5 5.30. Technical
API Colour issues. Bullet point a) needs to go
into the introduction. Bullet b) needs to habve
"for colied tubing operations, a flange or
specifiatly connector is preferred.
New Text:
The purpose of wireline or coiled tubing
adapters is to allow the connection of
wireline/coiled tubing BOPs and lubricators to
the surface tree or directly to the riser. The
adapter may be integral or non-integral with the
surface tree or riser.
The following requirements apply to
wireline/coiled tubing adapters:
a) The connection shall be qualified for all
relevant make/break loads, pressures,
temperatures, and external loads.
b) The adapter shall be provided with a profile to
interface with a standard casing elevator. The
outer diameter and load shoulder in such cases
shall be consistent with standard casing collars
of similar size. The adapter shall be capable of
maintaining the pressure integrity/seal between
the wireline/coiled tubing BOP and the adapter
in operational conditions.
Accepted
Clause 5 5.31 (f) Technical
API Colour code issue. "Provisions should be
made for handling and make/break of the
bottomhole assembly in the frame. " should be a
note not in main text
f) The tension frame shall have sufficient height
to allow installation of the wireline/coiled tubing
components.
Note: Provisions should be made for handling
and make/break of the bottomhole assembly in
the frame.
Accepted
Clause 5 5.31 (h) Technical
API Colour code issue. "90° rotation about the
vertical axis should be accommodated. " should
be a note not in main text
h) The design of the tension frame shall allow
relative rotation between the frame and surface
tree. Typically
Note: , 90° rotation about the vertical axis
should be accommodated.
Accepted
Clause 5 5.31 (m) TechnicalAPI Colour code issue. "Provisions shall be made
for anchoring personnel safety harnesses
suitable areas. "
new text "Anchoring of personnel safety
harnesses shall be placed at suitable areas.) Accepted
Clause 5 5.32 (a) Technical
This should be the introduction to the swivel not
a bullet point.
First paragragh: "A pressure-containing swivel
may be included in the landing string or C/WO
riser to allow relative rotations between the riser
and the workover vessel. The main purpose of
the swivel shall be to maintain the same surface
tree and surface tree tension frame orientation
relative to the drill floor. Relative rotations
normally occur during landing of the tubing
hanger and due to heading variations on
dynamically positioned vessels.
The following requirements apply to the swivel:"
Re-number the bullet points
Accepted
Clause 5 5.32 (e) Technical
e) All seal surfaces that may be exposed to
hydrocarbons shall be of corrosion resistant
alloy (that is, inlay welded).
This has an API Colour issue
Reword to the following
"All sealing surfaces exposed to hydrocarbons
shall exhibit a means of corrosion resistance. "Accepted
Clause 5 5.33 (a) Technical
Remove "A flexible circulation line(s) may be
used to provide annulus fluid access." from (a)
due to API colour issue and as a note at the
bottom of the section
as per comment
Accepted
Clause 5 5.33 (b) TechnicalRemove due to API colour issue and is covered
in the note section already at the bottom of the
section
removeAccepted
Clause 5 5.33 (c.) TechnicalRemove due to API colour issue and is covered
in the note section already at the bottom of the
section
removeAccepted
Clause 5 5.33 (note) TechnicalRemove "flexable" and replace with "Auxillary" new text "Auxillary circulation line(s) may be
used for"Accepted
Clause 5 5.34 (e.) Technical
Current wording had an API colour code issue
"e) During operation, all work on the spider
should be possible by personnel while they are
standing on the drill floor.
new text "e) During operation, all work on the
spider shall be possible by personnel while they
are standing on the drill floor, unless otherwise
agreed by the relevant parties. "
Accepted
Clause 5 5.35 (d) Technical
Missing shall in "d) The length of the handling
tool shall be minimized, but have sufficient
length to allow makeup and break-out of the
drillpipe or casing elevator and adequate space
for makeup of any control or test lines"
d) The length of the handling tool shall be
minimized, but shall have sufficient length to
allow makeup and break-out of the drillpipe or
casing elevator and adequate space for makeup
of any control or test lines
Accepted
Clause 5 5.36 (a) TechnicalThe word "umbilical" should have been removed
as per previous comments.
as per commentAccepted
Clause 5 5.36 (b) TechnicalThe word "umbilical" should have been removed
as per previous comments.
as per commentAccepted
Clause 5 5.3a Technical
Confusion over existing wording and also
conflict with API Colour code.
a) The design of the subsea well intervention
system shall include inputs for functional and
technical requirements to include (but not
limited to) the following:
1) internal and external cleaning and
preservation of the system;
2) identification of system components;
3) identification of components or areas of the
system where enclosed fluid volumes require
evacuation prior to disassembly;
4) consumables;
5) seals and gaskets, which are intended to be
made up on the vessel
Accepted
Clause 5 5.3b TechnicalConfusion over existing wording and also
conflict with API Colour code.
Inculded in comments in 5.3aAccepted
Clause 5 5.3d Technical
Conflict with the below text during the API
Colour code review. The below text to be moved
as a note such that you still have the
information.
Resilient, elastomeric, or metal-to-metal seals
may be used as primary seals to contain
hydrocarbons, well control, completion, and kill
fluids on riser system assembly interfaces and
riser connectors
Where metal-to-metal seals are not used as a
barrier to the environment, redundant seals
(primary plus backup) shall be provided.
Note: Resilient, elastomeric, or metal-to-metal
seals may be used as primary seals to contain
hydrocarbons, well control, completion, and kill
fluids on riser system assembly interfaces and
riser connectors
Accepted
Clause 5 5.3e Technical
Conflict with the below text during the API
Colour code review, eg part to be moved as a
note such the information .
Connection pressure separation loads shall be
based on worst-case sealing conditions.
Note: (e.g., leakage to largest diameter
redundant seal shall be assumed unless relief is
provided).
Accepted
Clause 5 5.3o Technical
Conflict with the below text during the API
Colour code review. The below text to be moved
as a note such that you still have the
information.
A general guideline on bolted flange joint
assembly is presented in ASME PCC 1-2000 [37]
Bolted flange connections shall be assembled
and made up in accordance with a written
procedure that has been qualified by test to
achieve the specified bolt pretension.
Note: A general guideline on bolted flange joint
assembly is presented in ASME PCC 1-2000 [37].
Accepted
Clause 5 5.5p Technical
The three bullet points under p) should be
separate bullet points as per supplied WD 5
comments 10-08-13.
q) Maximum anticipated rotation required for
tubing hanger orientation and the torsional
resistance of the downhole completion and
landing string shall form the basis for
determining requirements for torque capacity.;
r) Torsional resistance shall account for static
and dynamic effects (i.e., orientation at
maximum landing speed).;
s) For non-oriented tubing hangers, anti-rotation
features might not be required.
Accepted
Clause 5 5.7i Technical
Make sure that component structural capacities
shall be established and documented in
accordance with API 17G to allow the
performance of an overall system design
analysis
Component structural capacities shall be
established and documented in accordance with
API 17G to allow the performance of an overall
system design analysis
Accepted
Clause 5 5.7p (3) Technical
3. the subsea test tree (SSTTA) manufacturer
shall have a contingency procedure/method that
will operate the valves and connectors of the
subsea sea test tree in the correct sequence to
isolate the well.
3. SSTTA manufacturer shall have a contingency
procedure/method that will operate the valves
and connectors of the subsea test tree in the
correct sequence to isolate the well. Accepted
Clause 5 5.8i Technical
API Colour code issue with current text g) provision shall be made to avoid damage to
electric equipment connected above and below
the point of shearing due to cutting of the
electric line.
Accepted
Clause 5 5.8k (9) Technical
API Colour code issue, therefore need to add
some text as notes.
9. shall include sufficient clearance from the
subsea drilling BOP shear rams to allow milling
and fishing. An internal fish-neck may be
provided as backup for running an overshoot
tool.
9. shall include sufficient clearance from the
subsea drilling BOP shear rams to allow milling
and fishing.
Note: An internal fish-neck may be provided as
backup for running an overshoot tool. Accepted
Clause 5 5.8m (4) Technical
4. shall include sufficient clearance for closure of
subsea drilling BOP rams to account for stack-up
tolerances in the subsea drilling BOP stack and
SSTTA .
4. shall include sufficient clearance for closure of
subsea drilling BOP rams.
Note: Stack-up tolerances in the subsea drilling
BOP stack and SSTTA to be accounted for.Accepted
Clause 5 5.9(e, f & g) Technical
bullets e, f & g were supposed to be under 1
bullet. API Colour code issue therefore
reworded. Coomets were also provided under
WD 5 comments 10-08-13.
e) Qualification shear trails are the responsibility
of the end user and shall follow one of the
following:
1) BOP Shear trial of shear sub. The shear trial
qualification specimens shall include
external/internal hydraulic lines, slick line,
braided wire and coiled tubing (single or
multiple) as specified by the end user.
Shear sub orifice size shall be documented after
BOP shear test to determine if the remaining
orifice size will have sufficient flow area for
bullheading after post milling/dressing. Refer to
Annex J for additional information on the cutting
trials.
2) Physical cutting trials maybe waved by the
end user, if data from previous shear trials using
the same shear sub material properties,
hydraulic line types and identical BOP ram type
were used.
3) Calculations from the BOP manufacturer (or a
qualified independent 3rd party engineering
representative) verifying that the BOP can shear
the shear sub can accepted by the end user if
physical data to calculation results are
representative.
Accepted
Clause 5 5.11 Technical
Remove "is an optional valve that " A lubricator valve is typically located near the
top of either an open-water intervention mode
C/WO riser or thru-BOP/drilling riser
intervention mode landing string. The purpose of
a lubricator valve is to seal off the bore in the
landing string or the C/WO riser to allow
lubrication of long wireline or coil tubing tool
strings without having to close the SSTT/WCP
and depressurize the entire landing string or
C/WO riser. A lubricator valve may also be used
to assist with the circulation of fluids and
isolation and pressure testing of the
landing/riser string.
Accepted
Clause 5 5.14 Technical
API Colour code issue with current text.
The ported annular slick is typically located
between the lubricator valve and retainer joint
on the SSTTA. Its purpose is to allow for isolation
of the subsea drilling BOP from the marine
drilling riser by closure of a subsea drilling BOP
annular preventer. The ported slick joint shall:
The purpose is to allow for isolation of the
subsea drilling BOP from the marine drilling riser
by closure of a subsea drilling BOP annular
preventer. The ported slick joint shall:Accepted
Clause 5 5.15 Technical
Original comments below were agreed to be
changed in Technical commitee meeting.
The tubing hanger running tool adapter provides
the interface between the tubing hanger
running tool and the ported slick joint, either on
the SSTTA or the BOP spacer joint.
Requirements for the tubing hanger running
tool adapter shall be as follows:
a) include a lower interface compatible with the
tubing hanger running tool or with an interface
as specified by the end user;
b) include a upper interface compatible with the
SSTTA and/or the BOP spacer joint;
c) structural capacities of the upper interface of
the adapter shall be established and
documented in accordance with API 17G. The
structural capacities of the lower interface shall
be defined by the tubing hanger running tool
provider to API 17D criteria.
NOTE The tubing hanger-running tool is
included within the scope of API 17D.
The tubing hanger running tool adapter provides
the interface between the tubing hanger running
tool and the SSTTA or the BOP spacer joint.
Requirements for the tubing hanger running tool
adapter shall be as follows:
a) include a lower interface compatible with the
tubing hanger running tool which is provided by
the tubing hanger running tool provider or with
an interface as specified by the end user;
b) include a upper interface compatible with the
SSTTA and/or the BOP spacer joint;
c) structural capacities of the upper interface of
the adapter shall be established and
documented in accordance with API 17G. The
structural capacities of the lower interface shall
be defined by the tubing hanger running tool
provider to API 17D criteria.
d) it shall be designed for effects of internal and
external differential pressure in combination
with the applicable external lading conditions in
accordance with this document.
e) tubing hanger running tool provider shall state
if any component in the tubing hanger running
tool limits the internal or external pressure
rating of the tubing hanger running tool adaptor
due to design or functionality.
Accepted
Clause 5 5.16 Technical
Remove "A bore selector may be used in thru-
BOP/drilling riser intervention mode and open-
water intervention mode" and move to end of
section as a note due to API colour code
comments
Note: A bore selector may be used in thru-
BOP/drilling riser intervention mode and open-
water intervention mode Accepted
Clause 5 5.17 Technical
remove "during well testing." from first
sentence
The purpose of an adjustable fluted hanger is to
allow for temporary hang-off of well completion
equipment and allow space out of the SSTTA
inside a subsea drilling BOP. Accepted
Clause 5 5.19 Technical
Remove "A flange…." From the below
statement, due to API colour issue.
The upper end of the EDP shall have a
connection to mate with the lower end of the
riser. A flange, hub, or a proprietary riser
connector may be used.
The upper end of the EDP shall have a
connection to mate with the lower end of the
riser. A flange, hub, or a proprietary riser
connector may be used. Accepted
Clause 5 5.22 Technical
Remove the folllowing sentance as not appliable
to the functionality of a landing joint and API
Colour issue.
"A control umbilical(s) may be used to provide
hydraulic supply and electrical signal/power to
the SSTTA and tubing hanger running tool
functions. Suitable umbilical clamps shall be
installed to attach the umbilical(s) to the landing
string joint at specified intervals. "
delete "A control umbilical(s) may be used to
provide hydraulic supply and electrical
signal/power to the SSTTA and tubing hanger
running tool functions. Suitable umbilical clamps
shall be installed to attach the umbilical(s) to the
landing string joint at specified intervals. "Accepted
Clause 5 5.29 Technical
add from Tonys mark ups and to tie in with
Annex L.
"The following service condition classes and
ratings shall apply for well control devices in the
surface tree:
1) Service specification level (i.e. SSL-Liquid and
SSL-Gas) shall be in accordance with Annex L.2.1.
2) Pressure rating shall be in accordance with
Annex L.2.2.1.
3) Temperature rating shall be in accordance
with Annex L.2.2.2.
4) Material class rating shall be in accordance
with Annex L.2.2.4.
5) Safety class (i.e. safety function class and
normal operation class) shall be in accordance
with Annex L.2.2.5.
6) Service class (i.e. sand class I, sand class 2 and
sand class II) shall be in accordance with Annex
L.2.2.6."
as per comment
Accepted
Clause 5 5.3 Technical
Below statement was agreed, but removed from
WD 5.2. This should be added back in.
All equipment that can be subject to net
external pressure (i.e., from hydrostatic head)
shall be designed to withstand hydrostatic
collapse
Add. All equipment that can be subject to net
external pressure (i.e., from hydrostatic head)
shall be designed to withstand hydrostatic
collapseAccepted
Clause 5 5.36 Technical
API Colour issues, thefore slight reword to below
text required.
"2. provision of sufficient clamping force to
support the weight of the filled umbilical(s)
between clamps. The the required clamping
force shall account for weight of the filled
umbilical(s) between clamps, umbilical outside
diameter tolerances, operational friction
coefficient of the umbilical outer sheath, outside
diameter contraction due to clamping force and
external hydrostatic pressure; "
new text "2. the required clamping force shall
account for weight of the filled umbilical(s)
between clamps, umbilical outside diameter
tolerances, operational friction coefficient of the
umbilical outer sheath, outside diameter
contraction due to clamping force and external
hydrostatic pressure;" Accepted
Clause 5 5.4 Technical
API Colour code issue, therefore need to add
some text as notes & also bullet point 2 was not
editied as per supplied WD 5 comments 10-08-
13
"Note: Selection of the orientation system is
dependent on the type and design of the tubing
hanger. Typically, there are two types of
orientation systems:"
"2. passive (helix-type/linear) type: uses
downward or upward motion of the running
string to engage a pin or key in an orientation
device that automatically orients the tubing
hanger relative to the wellhead/tubing
head/horizontal tree."
"Note: Typical orientation devices are:"
Accepted
Clause 5.5 Technical
Below text to be moved to end of section and
added as a note.
Depending on the type of well and type of
subsea tree, the BOP spacer joint may include
the following components,; see Figure 5-2:
a) tubing hanger orientation joint or device;
b) intermediate (annular) slick joint;
c) upper (annular) slick joint;
d) pressure containing pipe-in-pipe spacer sub
to convey two or more tubing bores, hydraulic,
chemical or electrical lines.
Note: Depending on the type of well and type of
subsea tree, the BOP spacer joint may include
the following components,; see Figure 5-2:
a) tubing hanger orientation joint or device;
b) intermediate (annular) slick joint;
c) upper (annular) slick joint;
d) pressure containing pipe-in-pipe spacer sub to
convey two or more tubing bores, hydraulic,
chemical or electrical lines.
Accepted
Clause 5.7 Technical
API Colour code issue, therefore need to add
some text as notes
Note: Depending on the type of well and type of
subsea tree, the SSTTA may include the following
components (see Figure 5-3 and Figure 5-4):Accepted
Clause 5 5.8 Technical
The SSTT shall consists of a minimum of two
valves and a latch and can include additional
means of cutting coiled tubing or wireline.
The SSTT shall consist of a minimum of two
valves and a latch and can include additional
means of cutting coiled tubing or wireline.Accepted
Clause 6 6.5.4 Technical
Equations, symbols and subscripts have been
changed from ISO 13628-7:2005, this means
that all code check sofware will have to be re-
written. This will results in uncesssary costs with
out any added value
All equation, symbols and subscripts should be
revised back to ISO 13628-7:2005.Accepted
ref ISO 13628-07 : 6.5.2.2 (Equation 10: ) Min Pipe Burst
capacity , closed end
Clause 6 6.5.4.5
NOTE 1
NOTE 2
error regarding D/t below 25
Change "D/t ratios below 25" to "D/t ratios
above 25"Accepted
Clause 6 6.7.3.9.3
Table 25. Normative requirement to life time
(endurance) is not pratical as life time relaibility
modesl are not well estblished and API 17 N
Annex D is an over simplification
Recommned that informative guidance is given
to monitor valve/ram cycles in operation. For
temporary applications life time will depend on
inspected condition.
Accepted
Ref API 17N -- Does this apply to Life time endurance ?
"However other confidence levels maybe established by
the End User "?
Clause 6 6.8.8 e) Editorial
It is considered that requirement shall not be
normative but a recommedation
Change to "e) Swivel joint should have a manual
locking device to prevent rotation during
handling."
Accepted
No Action - already in text.
Clause 6 6.8.9 Technical
This clause needs to be re-written, The
formulation of technical provisions are not
adequate for an industry standard. The allowed
utilisation of 0.72 is not code calibrated and is a
safety issue.
API Editorial committe to appoint a responsbile
party to re write this clause.
Accepted
Alternatively, the manufacturer can conduct extra quality
checks to confirm structural integrity and reduce the
FAT….. (Delete / edit paragraph)
Change to:
1. FAT test pressure cannot be altered or changed per code
(0.9 Sy) shall be used.
2. Supplier cannot conduct extra quality checks to reduce
FAT test pressure integrity checks for equipment.
Clause 6 6.8.9 c Technical
NDE inspection for surface and subsurface
defects in all four quadrants for the entire
tubular cross section
per API 6A PSL3 requirements.
API 6A PSL 3 allows cracks for MPI, if this is
acceptable for a shear sub, this comment can be
removed.
API 6A PSL 3 NDT requirement is not ref Clause
7.
Rejected
No surface cracks are allowed.
Clause 6
Table 6-X
Clause
6.8.11
Technical
Use of tubing and casing is not defined for open
water intervention mode.
This option may be applicable for future
development of typically upset pipes with
integral connectors.
Add a column for open water intervention
modes, all section for material, design, testing
etc shall comply to API 17G Rejected
Clause 6
Table 6-X
Clause
6.8.11
Technical
Connection material
Specification
API 5 DP defines material requirements for tool
joints used in a friction welded configuration.
API 7-1 defines material requirements for none
friction welded components, such as pup joints
and saver subs etc.
Add additional reference to API 5DP for column
referring to API 7-1
Accepted
WG to review and propose change
Clause 6Table 6-X
Clause Editorial
Change "ISO 13679" to "API 5C5" all casesAccepted
WG to review and propose change
Clause 6
Table 6-X
Clause
6.8.11
Technical
All columns shall include internal pressure
design factor and combined internal pressure
and effective tension design factor. Also stated
design factors for normal, extreme and
accidental based on elastci analysis in
accordance with API 5C5 for casing and API 7G
for drill pipe.
Incude a internal pressure design factor and
combined internal presseur and effetcive
tension of 0.6 for capped ends, at design
temepature, including corrosion allowance. For
API 7G and API 5C5 design factor shall be based
on elastic von Mises stress criteria.
Accepted
WG to review and propose change
Clause 6
Table 6-X
Clause
6.8.11
Technical
Pipe material specification
General reference to API 5D
API 5DP replaces API 5D
Change reference to API 5DP
Accepted
WG to review and propose change
Clause 6
Table 6-X
Clause
6.8.11
Technical
Welding requirements
API 7G, (API RP 7G?)
Welding requirements are given by API 5DP
Add reference to API 5DP instead of API RP 7G
Accepted
WG to review and propose change
Clause 6
Table 6-X
Clause
6.8.11
Technical
Welding requirements pipe open sea well
intervention
Clause 7
Clause 7 does not address friction welding.
Clause 7 does not address friction welding.
Propose to add section in clause 7 that gives
modifications to friction welding as given in API
5DP. As an option, this section may include
requirements for forge welding /die welding
such that future development is not restricted.
Accepted
WG to review and propose change
Clause 6
Table 6-X
Clause
6.8.11
Technical
Pipe material specification
Clause 7 gives requirements for upset pipe that
might not be feasible to get a drill pipe
manufacture to implement into their production
line
Might be that the strictly process definition,
implementation and process control being used
by typically Drill Pipe supliers for line production
(as per API standards) is sufficient or even
exceeds requirements for such production,
thinking specially of NDE requirements as part of
production line
Propose that this is addressed in clause 7, a GAP
analysis should be performed and typical Drill
Pipe suppliers should be given the option to give
input and comments.
Accepted
WG to review and propose change
Clause 6
Table 6-X
Clause
6.8.11
Technical
Connection material
Specification
Clause 7 does not cover tool joint and pup joint
manufacturing as performed today.
Tool joints are forged to shape, however it may
not be feasible to perform 100% manual UT
after forge due to forge geometry. The way tool
joints are produced may give confident that
internal defects are not presented after final
forging , the rolled bar that are being used to
forge connectors has been UT checked prior to
sawing to specified length.. A spot UT check of 5
to 10 % of all forgings may cover such
requirement.
Pup Joints and saver subs are machined from
rolled bars, manufacture of such bars performs
NDE according to API 7-1 , which does not
comply with requirements given in clause 7.
Propose to address this in clause 7, a gap
analysis should be performed to API 5DP and
typical drill pipe suppliers should be given the
option to give input and comment.
If section 7.6.2 is intended to cover the
requirements for drill pipe accessories produced
from rolled bars, it should be specified.
Accepted
WG to review and propose change
Clause 6 6.8.10 Technical
Clause 6.8.10 needs to be re-written, such that it
clearly defined which barrirer shall be protected,
these barrirers shall be defined in the safety
strategy. Clearly define the weak link philosophy
and acceptance criteria
FMC will write a new proposal for clause 6.8.10
for review by the API editoral committe. This
proposal will be submitted by 30th September
2013.Accepted
WG to review and propose change
Clause 6 6.8.10 Technical
Clarify which well barrier (envelopes) to protect.
Please note that it may be severe pressure
energy in the riser itself (primary barrier
envelope)
The responsible party shall ensure sufficient
protection of primary and/or secondary barrier
envelope for excessive loads.Accepted
WG to review and propose change
Clause 6 6.8.10 EditorialBe presice on the wording 'release' - complete
separated or stroked out (telescope)?
Typically, such device may release the vessel
(change from will) AcceptedWG to review and propose change
Clause 6 6.8.10 TechnicalThe device may also include activation joints to
initiate ESD / EQD
Add a bullet point; d) Tension and/or bending
activated deviceAccepted
WG to review and propose change
Clause 6 6.8.10 Technical
Please note that pressure balanced safetyjoint
may be beneficial for the system. The
safetyfactor Fd is normally used on effective
tension, bending and internal pressure (burst
and end-cap). A pressure balanced design may
remove the safetyfactor for end-cap. A note
should be added.
Note: Pressure balanced design will change the
usage of design case factor Fd (safety factor) on
internal end-cap pressure. This factor will only
be added on effective tension, bending and
burst. Sufficent robustness shall therefore be
evaluated and included for in the design.
Accepted
WG to review and propose change
Clause 6 6.8.10 EditorialNote 3' is a typo and should be changed to 'Note
4', page 159
Note 4Accepted
WG to review and propose change
Clause 6 6.8.10 Editorial
The confidence intervall may be missused /
missunderstood, please add a figure which
explains allowable operating loads and how to
use the intended standard deviation i.e. 95%
intervall.
Include a figure to explain how to use.
Accepted
WG to review and propose change
Clause 6Section
6.2.3Technical
Would like to add a bit more clarification to the
last paragraph regarding the motivation/uses of
the global load analysis
Add the following text to the last paragraph
ending with "and interference checks.":
"The purpose of the global load analysis is to
define expected component loads during service
for defined metocean conditions and operations.
Comparing expected component loads to
component capacities allows for setting
operational limits, including metocean
conditions, for various planned operations of the
riser.
Accepted
WG to review and propose change
Clause 6Section
6.2.3Technical
The three Notes at the end of this section are
not necessary.
Remove Note 1, Note 2, and Note 3 at the end of
Section 6.2.3.Accepted
WG to review and propose change
Clause 6
Section
6.2.4
through
Section
6.10.9 (and
related
Annexes)
Technical
In our opinion, these sections (and annexes) are
way too long and overly prescriptive. This is
very good information but better suited for a
textbook.
All of Sections 6.2.4 through 6.10.9 (and all
related Annexes) should be replaced with
Section 4, 5, and 6 (and related Annexes) of API
Standard 2RD (2nd edition, September 2013).
Accepted
The following are meant to provide some further
explanation of our concerns that led to these
comments/suggestions. Note that these are listed in no
particular order.
- Completion/intervention risers and top-tensioned risers
are similar systems and basically just "pipe". However, the
API documents addressing the design/analysis of these
systems (Working Draft 5 of 17G and 2RD) are quite
different. The recently issued revision of 2RD includes a
total of less than 80 pages (including Annexes), while for
comparison, this draft of 17G includes more than 660
pages. It would be advantageous for this document to
better align with the "less is more" philosophy used in the
recent 2RD re-write.
- There are a number of topics within this document that
are already addressed with other existing API documents
(e.g., Spec 2RD, RP 16Q). It would be advantageous for
17G to merely reference these existing for appropriate
topics. Doing so would reduce the chance for confusion by
the user (where differences/inconsistencies may exist), as
well as remove the need to update multiple documents
when changes are needed.
- Due to their prescriptive nature, the methodologies
Clause 6 6.4.4.4 Technical
Change paragraph: If the calculated fatigue life
is less than 10 times the service life.....
Based on the precedent within the airline
industry of using a MFOP on fatigue based
inspections at 1/3 of design life. Use a risk
based approach as long as the loads remain
within the Normal operating load limits.
Rephrase as proposed:
Fatigue life tracking and subsequent inspection
plan should be defined based upon the following
factors; Maintenance free operating period,
fatigue life, load cycles within normal load limits,
DNV OS-F201/RP-C203 guidance and internal
company best practice. Fatigue inspections to
begin no later than 1/3 of estimated fatigue life.
All excursion(s) above normal load limits will
accelerate fatigue life consumption for the asset
and shall be analyzed and logged as unique
events. As these may trigger immediate
inspections and accelerate fatigue depreciation
of the asset.
Accepted
WG to review and propose change
Clause 6 6.5.4.2 Technical
Equation (5) has an error the denominator in equation (5) should be as
modified on left where 2 is replaced by the 4
Accepted
4
Clause 6Table 6-8
WD5.2Technical
What does "-" mean in table. If it means "Not
Applicable" then replace with N/A. In either
case, add footnote to clarify.
Change "-" to "N/A" and and footnote N/A
meaning: Not Applicable AcceptedWG to review and propose change
Clause 6 6.5.4.2 TechnicalFirst paragraph. D/t < 3,1 should be D/t > 3,1 Change D/t < 3,1 to D/t > 3,1 in first paragraph
AcceptedWG to review and propose change
Clause 6 6.3.2.2 Editorial
duplicate sentence in 4th paragraph. Change to: Alternatively the design
temperatures can be determined from
calculations, tests, or service experience based
on measurements. Any heat transfer calculation
shall be performed on the assumption that there
is no heat loss due to wind. Heat loss due to
seawater can be considered for submerged
parts; however, only conduction heat loss to
seawater shall be considered. Convection heat
loss due to seawater current flow shall not be
included.
Accepted
WG to review and propose change
Clause 6Table 6-7
WD 5.2Technical
Landing String shear subs have no guidance
listed
Landing String Shear Subs; Design code : API
17G, General Design Requirements : Subsection
6.4 and 6.5, Additional Design Requirements :
6.8.9
Accepted
WG to review and propose change
Clause 6Table 6-7
WD 5.2Technical
Additional design Requirements and testing
columns not correct for PIPE.
Row "Pipe" Additional Design Requirements :
6.8.11, Qualification Testing : Subsection 6.7 AcceptedWG to review and propose change
Clause 66.4.3.6
WD5.2Technical
Delete material requirement which is covered in
Clause 7
Delete paragraph ; Furthermore, the yield
strength used in design ….Accepted
WG to review and propose change
Clause 6 6.5.4.2 Technical
Current paragraph above equation (5) implies
the normal internal design pressure rating is
calculated in equation (18) and is based on burst
calculation in equations (3) or (4) and only the
FAT proof test is reduced the pressures in
equation (5) or (6). To keep a 1.5 proof test and
to clarify, recommend rewrite this paragraph.
Minor distortion may occur during hydrostatic
pressure testing when using equations (3) or (4).
In cases were no distortion is acceptable during
hydrostatic pressure testing, the minimum
pressure to initiate yielding on the inside of the
pipe will be used to determine the maximum
FAT proof test. The normal internal design
pressure rating will therefore be equal to 2/3 of
this (Max proof test -500 psi). The 500 psi is the
recomended allowance pressure testing
tolerance but can be adjusted to the
manufacturing testing capability. For open-end
pipe the minimum pressure to initiate yielding
on the inside of a pipe may be calculated by
equation 5:
Accepted
WG to review and propose change
Clause 6 6.8.11.1 Technical
Pressure testign of subsea equipment should
not be limited to MEG fluid. MEG definition is
not correct.
Change "shall" to "should" and state reason is to
prevent hydrates. MEG stands for
Monoethylene Glycol.Accepted
WG to review and propose change
Clause 6 6, Table Technical
Functional limit is 1.0 so does that mean no FOS
is required for functional limits. Also if functional
limit limits, then capacities are the same for all
operating conditions
review and consider safety factors
Rejected
Moved to WD6 Comments
Table 6.1 has been amended to address lack of clarity.
Clause 6 6.4.2 TechnicalTable 11: This table is in complete Complete Table 11. Moved to WD6 Comments
Clause 6 sub team to complete asap
Clause 6 6.5.5.2 Technical add an additional note for equation 23 to
connect table 6Accepted
What needs to go in the note??
Clause 6 6.5.4.2 Technical
Equation (5) has an error the denominator in equation (5) should be as
modified on left where 2 is replaced by the 4
Rejected
See 6.5.4.2 Eq 5 in WD6 Additions folder
Clause 6 6-1 GeneralThe table is not easy to follow, especially for the
Pressure design portion. What is meant by 0.90
for make-break in structural?
Try to make the table easier to follow, because
it's not immediately apparent to the reader what
any of these factors mean
AcceptedWG to review and propose change
Clause 6 6.2.5.2 GeneralIn the NOTE, it says that pressure/ temperature
cycling may also be included in fatigue testing if
significant
If it is significant, add a test or test procedure for
this fatigue evaluation AcceptedWG to review and propose change
Clause 6 6.3.1.2 General
NOTE 2 says the internal pressure will rarely be
above RWP then it says that the pressure will be
equal to or greater than RWP in the following
paragraph
Make sure these two statements agree
Accepted
WG to review and propose change
Clause 6 6-6 General
For these temperature design classes, the
maximum temperature only goes to 350F, but in
Table 6-10, it goes to 390F.
Need to establish the maximum temperature
covered within the scope of 17G. If the
temperature (this goes for pressure as well),
then there needs to be a contingency of what
that means to have loading conditions outside
the 17G. (Reference API 17TR8 HPHT?)
Rejected
Clause 6 6.4.3.7 General
Design calculations are performed for min and
max coeff's of friction. What if the manufacturer
of the thread compound used for making up a
threaded connector only supplies a single
friction factor?
Remove statement since the connector
manufacturer uses the thread compound
manufacturer's value(s) Accepted
WG to review and propose change
Clause 6 9' TechnicalCheck equation to see if correct, because when
equation attempted, it didn't come out as
expected.
Check equationAccepted
WG to review and propose change
Clause 6 10' Technical
Check equation to see if correct, because when
equation attempted, it didn't come out as
expected.
Check equation
Accepted
WG to review and propose change
Clause 6 14' TechnicalIt says that the equation is for plastic capacity,
but only using the yield stress
Take out plastic capacity and switch it to yield
capacity or the equivalentAccepted
WG to review and propose change
Clause 6 15' TechnicalIt says that the equation is for plastic capacity,
but only using the yield stress
Take out plastic capacity and switch it to yield
capacity or the equivalentAccepted
WG to review and propose change
Clause 6 19, 22 Technical
Using the net differential pressure does not
equate to the same stress in the material as
using simultaneous internal and external
pressure. Ex. 10,000 psi internal pressure and
5,000 psi external pressure does not create the
same stress distribution or loading as simply
applying 5,000 psi internal pressure, or the net
differential pressure
Fix these equations, because these equations are
not equivalent do 18 and 20, respectively
Accepted
WG to review and propose change
Clause 6 6.6.3.4 Technical
What is meant by short-term and long-term
relaxtion of preload?
Provide details as to what's considered "short-
term" and what's considered "long-term". How is
this tested? If it's required, put this test in Annex
I.
Accepted
WG to review and propose change
Clause 6 6-16' General
What is meant by Applied Tensile Load
Dependence?
Explain column
Accepted
WG to review and propose change
Clause 6 6.6.7 General
"Seals shall be made from metallic materials or
elastomers that are resilient… external fluid."
Needs to include other materials, such as PTFE
or PEEK since they are not technically
elastomers. Casing connections use PTFE rings as
sealing mechanisms.
Add a term such as "thermoplastics" so that
PTFE and PEEK can be included as a sealing
materialAccepted
WG to review and propose change
Clause 6 6.8' GeneralDrillpipe is not considered and OCTG product.
Referenced as OCTG several times within this
section.
Do not reference drillpipe as an OCTG product
anywhere within the spec. AcceptedWG to review and propose change
Clause 6 6.8.4 GeneralSo do drillpipe landing strings have to be in
accordance to 17G since 6.8.2 is for landing
strings as well?
Specify if drillpipe landing strings have to be in
accordance to 17G AcceptedWG to review and propose change
Clause 6 6-X General
This table is very ambiguous and needs to be
reworked and better explained in regards to
what it's trying to accomplish
Since this is a brand new table from WD4 to
WD5 and there are many issues that would be
difficult to explain, please contact Paul
Beauchamp (NOV) for discussion
Accepted
WG to review and propose change
Clause 6 6-X GeneralThere is full sour service drillpipe, even for the
friction weld
Fix footnote 'a' to reflect thatAccepted
WG to review and propose change
Clause 6 6-X General
What about drillpipe connections outside of 7-
1?
There are premium drillpipe thread designs that
could be used for these riser joints, so the Table
needs to not limit drillpipe to the thread designs
seen in 7-1. Premium drillpipe connectors also
have metal to metal seals and other features
which can enhance the sealing and torque of
these connections.
Accepted
WG to review and propose change
Clause 6 6-X General
No drillpipe connections that are manufactured
exactly to 7-1 and 7-2 is suitable for any of these
purposes since there’s not seal designs in those
specs
Acknowledge that premium drillpipe
connections are capable of meeting the seal
design requirementsAccepted
WG to review and propose change
Clause 6 6-X General
There is full sour service drillpipe right now, so
for the open water intervention mode in H2S
requirements should say NACE MR0175
For the H2S row, include NACE MR0175 to the
open water well intervention mode drillpipe
column, otherwise, this will limit drillpipe
capability
Accepted
WG to review and propose change
Clause 6 6-X GeneralMake-up torque for drillpipe should be 7G or
manufacturer’s specification
Add that manufacturer can specify make-up
torque for drillpipe connectionsAccepted
WG to review and propose change
Clause 6 6-X General
What’s the difference between mill pressure
test and hydrostatic body test? They’re both
Factory Acceptance Tests
Explain the difference between mill pressure
test, hydrostatic body test, and FAT test.
Confusing here.Accepted
WG to review and propose change
Clause 6 6-X General Drillpipe has own drift requirements Reference drillpipe spec drift requirements Accepted WG to review and propose change
Clause 6(6)
Table 6-1Technical
Applying design factor for normal operations (Df
= 0.67) with metal at design temperature does
not follow the argument that design factors are
a function of factors including consequence.
Test pressure applied from the rig will typically
represent significantly lower consequence, and
temperature will typically be less than max
design temperature.
Include row for in-service pressure testing. Ref
API 17G 2nd edition Table 11.
Evaluate if Df = 0.80 can be acceptable for
pressure testing that will not compromise barrier
element integrity.
Rejected
In service pressure testing is not a governing load case. In
service pressure is equal to RWP and as pointed out
temperature is lower than Normal operating case.
Clause 6(11)
Table 6-7General
Spiders and Bails refer to API 17A Annex K for
design codes. API 7K and API 8C should be
included.
Update to include API 7K and 8C as design codes
for spiders and bails respectively.
Clause 6(12)
Table 6-8Technical
Suggest allowing Structural scaling of Swivels
and Telescopic riser components, as these are
not particularly different from connectors and
flanges from a structural point of view. Sealing
and friction are covered by seal qualification and
"Functional" scaling requirements.
Allow "Structural scaling, column 'a', for Swivels
and Telescopic riser components.
Clause 6 6.4.3.7 Technical
Value for maximum friction coefficient of 0.02 is
to conservative in light of accumulated field
history with connectors with self locking tapers.
Clause 6 6.4.4.2 GeneralRequirement in bullet b) and last note are both
vague as what can be considered small and
sharp are relative.
Rephrase
Clause 6 6-2, Table General
Note B is carried across from previous draft
version, and should be either removed or be
applicable to the two first lines not only second
line.
Apply note B to both first and second line in
table.
Clause 6 6.4.4.4 GeneralHow "first fatigue inspection" and "Following a
succesfull fatigue inspection" relates to
calculated service life is unclear.
Reword to specify that inspection intervals after
the initial service life has been expired should be
based on fracture mechanics.
Clause 6 6.3.10 General
A number of the items listed must be the
responsibility of the operator/purchaser to
provide; d (partly), f, g, h, l, m, q, r, s
Include statement on requirement for
operator/purchaser to provide required
information, or reference to relevant section in
Annex F
Accepted
Clause 6 6.10.6 General
e)question applicability of assigning
responsibility for recail analysis with CWOR
supplier, as tension system and top drive is
typically provided by others
Rejected
Scope of clause 6.10.6. is model validation. Resposibiølity is
contractual
Clause 6 6.10.7.5.1 General
Two items listed should be noted to include
operator responsibility;
- system risk review to evaluate accidental load
scenarios
- drift of/drive of limitations should be evaluated
by or specified by operator
Include note on operator/purchaser
responsibility to contribute.
Clause 6(22)
6-19,C110 Editorial
Accronyme ADB is not defined Include definition ADB = Analysis Design BasisAccepted
Clause 6 6.10.8.3.3 General
Responsibilities and limits are not defined in
Note 2. Who evaluates if consequences are high,
and who determines what the allowable limts
are.
Rephrase to define purchaser/end user
involvementAccepted
Clause 6 6.10 Editorial
clause 6.9 and clause 6.10 are the same.
Delete “6.10 Non-pressurized equipment design
requirements” such that title of clause 6.9
harmonizes with clause 6.8.
The clause numbering should now be as follows:
6.8 Specific design requirements – pressurized
equipment
6.9 Specific design requirements – non
pressurized equipment
6.10 Global load and response analysis.
Accepted
Clause 7 7.3.1 Technical
Bullet d) example 1, last line "Minimum
hardness may be used to reduce tool marks on
connectors" Minimum hardness will increase
tool marks.
Delete this line The comments do not refer to the latest version (they do not
match paragraph number, bullets, subject…). We addressed all
comments received as a group before sending the clause to you
at the end of February.
Clause 7 7.3.5 Technical
Bullet (e) Hydraulic ports and related hole. This
bullet is redundent to bullet (a)
Delete this bullet The comments do not refer to the latest version (they do not
match paragraph number, bullets, subject…). We addressed all
comments received as a group before sending the clause to you
at the end of February.
Clause 7 7.3.5 Technical
Item e. I have not seen that hydraulic ports are
overlaid. If there are some chemical injection
lines on HH trim the fittings will see the well
fluid( Medium pressure fittings)
Clarify to apply only to those ports which may
see well bore fluids.
The comments do not refer to the latest version (they do not
match paragraph number, bullets, subject…). We addressed all
comments received as a group before sending the clause to you
at the end of February.
Clause 7 7.4.3.1 Technical
Line below Table 7-9. Low S, P and B required
for fasteners. Low values shall be for fatigue
critical fasteners.
Add ….seamless pipes, forgings and fatigue
critical fasteners, the following ..
The comments do not refer to the latest version (they do not
match paragraph number, bullets, subject…). We addressed all
comments received as a group before sending the clause to you
at the end of February.
Clause 7 7.4.3.4 Technical
7.4.3.4 requires that the Inspection and Test
Plan shall show the acceptable ranges for
dimensions.
Finish dimensions and their accepable ranges are
proprietary information and will not be part of
an FMC ITP.
The comments do not refer to the latest version (they do not
match paragraph number, bullets, subject…). We addressed all
comments received as a group before sending the clause to you
at the end of February.
Clause 7 7.6.4.2 Technical
Wedge testing requirements and Macroetch
requirements on critical fasteners. What is
critical fasteners, load bearing and or pressure
containing. This requirement can result in delays
in project, fasteners can be long lead items.
Remove or at least be detailed of what is
considered critical. Pressure containing and or
load bearing.
The comments do not refer to the latest version (they do not
match paragraph number, bullets, subject…). We addressed all
comments received as a group before sending the clause to you
at the end of February.
Clause 7
Section 7.0
(and
related
Annexes)
Technical
In our opinion, these sections (and annexes) are
way too long and overly prescriptive. This is
very good information but better suited for a
textbook.
All of Section 7.0 (and all related Annexes)
should be replaced with Section 7, 8, and 9 (and
related Annexes) of API Standard 2RD (2nd
edition, September 2013).
The following are meant to provide some further
explanation of our concerns that led to these
comments/suggestions. Note that these are listed in no
particular order.
- Completion/intervention risers and top-tensioned risers
are similar systems and basically just "pipe". However, the
API documents addressing the design/analysis of these
systems (Working Draft 5 of 17G and 2RD) are quite
different. The recently issued revision of 2RD includes a
total of less than 80 pages (including Annexes), while for
comparison, this draft of 17G includes more than 660
pages. It would be advantageous for this document to
better align with the "less is more" philosophy used in the
recent 2RD re-write.
- There are a number of topics within this document that
are already addressed with other existing API documents
(e.g., Spec 2RD, RP 16Q). It would be advantageous for
17G to merely reference these existing for appropriate
topics. Doing so would reduce the chance for confusion by
the user (where differences/inconsistencies may exist), as
well as remove the need to update multiple documents
when changes are needed.
- Due to their prescriptive nature, the methodologies
Clause 7
Section 7.0
(and
related
Annexes)
Technical
In our opinion, these sections (and annexes)
should only define requirements, not
procedures. In other words, this document
should focus on the "what" and not the "how".
The following are meant to provide some further
explanation of our concerns that led to these
comments/suggestions. Note that these are listed in no
particular order.
- Completion/intervention risers and top-tensioned risers
are similar systems and basically just "pipe". However, the
API documents addressing the design/analysis of these
systems (Working Draft 5 of 17G and 2RD) are quite
different. The recently issued revision of 2RD includes a
total of less than 80 pages (including Annexes), while for
comparison, this draft of 17G includes more than 660
pages. It would be advantageous for this document to
better align with the "less is more" philosophy used in the
recent 2RD re-write.
- There are a number of topics within this document that
are already addressed with other existing API documents
(e.g., Spec 2RD, RP 16Q). It would be advantageous for
17G to merely reference these existing for appropriate
topics. Doing so would reduce the chance for confusion by
the user (where differences/inconsistencies may exist), as
well as remove the need to update multiple documents
when changes are needed.
- Due to their prescriptive nature, the methodologies
Clause 7Table 7-5 &
7-9Technical
A class of material that meets API 17G (2006)
needs to be kept in the standard to allow a path
for qualifying existing equipment made to the
present release of 17G. Changes in Table 7-5
and Table 7-9 obsolete all existinng equipment.
If these changes are justified, then does existing
equipement designed to API17G (2006) need to
be de-ratred? If not, then are the material
changes really needed. If yes the change are
needed then how do we go about de-rating
existing equipment made to 17G (2006)?
technical discussion are ongoing
Clause 7 7.6.2(s) Technical
230 HV10 hardness gives tverytight range to
meet 80 ksi minimum yield material. Material
will loose strength after welding and PWHT.
Higher hardness closer to upper end is
necessary to allow for reduction in strength due
to PWHT.
Change: higher hardness for base material is
allowed provided supplier proves through
qualification testing that after welding and
PWHT base material will comply with the
hardness requirements. ET - recommend drop
the 230 maximum all together and permit to 250
HV. WPS can be qualified on like material.
further, essential variable established on girth
welds in table 36 make this restriction not
necessary.
Accepted
Moved to WD6 Comments - need more info - John to
resolve
Valid technical point
Clause 7 7
qualification of titanium seals
Titanium (seals) references should be in
brackets? - see table 7.2 (Grade 1, 2, 28, 29)
tbd
Accepted
The comments do not refer to the latest version (they do
not match paragraph number, bullets, subject…). We
addressed all comments received as a group before
sending the clause to you at the end of February.
Clause 7 7
"assess add'l requirements" - define what that
means (Strain based? Load based vs.
displacement Accepted
The comments do not refer to the latest version (they do
not match paragraph number, bullets, subject…). We
addressed all comments received as a group before
sending the clause to you at the end of February.
Clause 7 7.3.18
remove in entirity, but reference in other
sections - NDT sections (Add statement in NDT
section 7.4.4.2 stating that CTOD’s are used for
identifying min. flaw size and during inspection
for fatigue life of equipment)
remove 7.3.18 - add in 7.4.4.2….. Re-word
Accepted
Moved to WD6 Comments. John to modify (charpy and
lateral expansion….)The comments do not refer to the
latest version (they do not match paragraph number,
bullets, subject…). We addressed all comments received as
a group before sending the clause to you at the end of
February.
Clause 7 7.4.3.4
The use of prolongation may be acceptable
provided that section thickness, degree of
mechanical work, and thermal history are the
same as the critical regions of the component.
needs to be required, look for other
prolongation references throughout doc for
usage Accepted
Moved to WD6 Comments. The comments do not refer to
the latest version (they do not match paragraph number,
bullets, subject…). We addressed all comments received as
a group before sending the clause to you at the end of
February.
Clause 7 7.4.3.4
Change the use of Prolongations … omit the
term "may" use.
Accepted
Moved to WD6 Comments
Review the prolongation usage of the terms in various
locations of the document. -- This should be changed from
the work that John is doing. The comments do not refer to
the latest version (they do not match paragraph number,
bullets, subject…). We addressed all comments received as
a group before sending the clause to you at the end of
February.
Clause 7 7.3.19.1
charpy (combined with Lateral expansion
requirement 0.015 , % shear test) to make sure
your material as Quality Assurance function, and
use the CTOD's for the high strength . Location
should be reworded.
Accepted
Moved to WD6 Comments
Chevron Prevention of Brittle failure: -- Tight Chemistry,
Take the Prolongation (sacrificial forging, Inspection ,
testing at high stress location, etc. --- hydrogen
embrittlement is big issue for low alloy materials. Vote:
Charpy to be used strictly for Quality assurance
Clause 7 7.6.2(s) Technical
230 HV10 hardness gives tverytight range to
meet 80 ksi minimum yield material. Material
will loose strength after welding and PWHT.
Higher hardness closer to upper end is
necessary to allow for reduction in strength due
to PWHT.
Change: higher hardness for base material is
allowed provided supplier proves through
qualification testing that after welding and
PWHT base material will comply with the
hardness requirements. ET - recommend drop
the 230 maximum all together and permit to 250
HV. WPS can be qualified on like material.
further, essential variable established on girth
welds in table 36 make this restriction not
necessary.
Accepted
Valid technical point - Is this ready to go into document? Is
this a cut/paste?
Clause 77.3.18 -
Table 29Technical
Define forging as section wall thickness greater
than 3 inches, otherwise use pipe column
suggestionRejected
Should be added as note - Where does this go? Table 7-
18??
Clause 7 7' General
No reference to friction welds. In order for
drillpipe to be used as a riser, friction welds
MUST be referenced and discussed in Clause 7
Reference friction welds on drillpipe or refer
friction welding back to a drillpipe specification
The comments do not refer to the latest version (they do not
match paragraph number, bullets, subject…). We addressed all
comments received as a group before sending the clause to you
at the end of February.
Clause 7 7' General
Standard ISO 15156 does not apply to friction
welds. It is possible to produce sour service
friction welds for intervention risers.
Add some qualifying statements with regards to
friction welds for use in H2S. Contact Paul
Beauchamp or Lucien Hehn from NOV.
The comments do not refer to the latest version (they do not
match paragraph number, bullets, subject…). We addressed all
comments received as a group before sending the clause to you
at the end of February.
Clause 7 7.3.4 General
"Girth welds shall have an actual strength equal
to or higher (overmatching properties) that the
actual strength of the adjacent base materials."
With a drill-pipe based intervention riser, the
cross-sectional area at the weld could be around
twice the cross-sectional area of the tube (the
part of the assembly with the lowest cross-
sectional area). If the cross-sectional area of the
weld is is much greater than the tube, there is
no problem with the yield stress of the weld
being lower than of the tube. The stress in the
weld at any time in service will always be far
below that of the tube. Insisting on having the
weld yield stress equal or exceed that of tube
would not be reasonable and would place an
unnecessary severe manufacturing hurdle for
the weld without justification.
The passage should read something like "The
maximum in-service stress of the weld should
always be less than or equal to that of all other
components of the adjacent base metals in the
assembly. In addition, the weld yield stress must
be less than the maximum in-service stress of
the weld"
The comments do not refer to the latest version (they do not
match paragraph number, bullets, subject…). We addressed all
comments received as a group before sending the clause to you
at the end of February.
Clause 7 7.3.7 General
Who is responsible for the corrosion protection
application? End user
Make end user responsible for the corrosion
protection application, because manufacturer
may not be qualified for this type of application
The comments do not refer to the latest version (they do not
match paragraph number, bullets, subject…). We addressed all
comments received as a group before sending the clause to you
at the end of February.
Clause 7 7.3.8 General
Are the alloys in Table 7.3.8 suggestions as
written or required? Typically, advanced
engineering companies develop “modified”
alloys that are based off these basic alloys.
These modified alloys have greatly improved
properties over the base alloys they are based
on and hence should not be prohibited from
being used.
The table should give suggested alloys but not
prohibit alloys from being used since they can be
modified to be highly suitable for a given
environment or use.
The comments do not refer to the latest version (they do not
match paragraph number, bullets, subject…). We addressed all
comments received as a group before sending the clause to you
at the end of February.
Clause 7 7.5' Technical
In comment g below the table, the impact test
temperatures for welds are required to be
lowered by 18 F. The required test temperatures
(-4F) are already far lower than the weld would
experience in-service. Lowering the test
temperature another 18 F lower is arbitrary and
serves no purpose. This will only serve to make
manufacturing more difficult and drive costs
higher with no benefit.
Recommend removing this requirement. The comments do not refer to the latest version (they do not
match paragraph number, bullets, subject…). We addressed all
comments received as a group before sending the clause to you
at the end of February.
Clause 7 7-8 GeneralPg 215 and 216 are missing. Need to see all
tables
Include pages 215 and 216 and all associated
tables
Clause 7 7.3.2 General
"Some tools and temporaty applications...". All
intervention equipment is by definition
temporaty (not permanently installed). This
section can be misinterpreted. The exact
equipment/components to which this relaxation
applies shall be clearly specified.
"Non-ISO 15156 compliant materials may be
allowed for cutting inserts and cutting blades."
Rejected
Already permitted exclusion in NACE
Clause 7 7.3.2 Technical
NOTE 2 is incorrect. Hardness
requirements/limits do not always apply for all
materials and product forms in ISO 15156-3.
- Remove NOTE 2; or
- Make NOTE 2 specific for carbon and low alloy
steels; or
- Rephrase NOTE 2 to "If applicable, hardness
requirements in ISO 15156 shall apply for
materials used in H2S service.
Accepted
Re-Written
Clause 7 7.3.3 Editorial 7th paragraph: "... shall be allow..." Rephrase to "shall allow" Accepted Re-Written
Clause 7 7.3.3 Technical
"... The selected minimum tempering
temperature shall be allow post-weld heat
treatment and still meet the minimum specified
mechanical properties."
This is only required if mechanical tests after
simulated PWHT are not performed. As long as
simulated PWHT, with temperatures and cycle
times equal to any subsequent PWHT, are
performed for each material heat and heat
treatment batch, then this should provide
sufficient evidence that the material is capable
of withstanding the PWHT without negative
effect on the mechanical properties.
It should be noted that tests after simulated
PWHT are addressed in the next paragraph
(same section) and other places throughout the
spec.
Remove this paragraph, or rephrase it to state,
"unless mechanical tests after a simulated PWHT
are performed for every material heat and heat
treatment batch. The simulated PWHT cycle
times and temperature shall be equal to any
subsequent PWHT to be performed on the
material."
Accepted
Removed
Clause 7 7.3.4 General
"Welding consumables for girth welds and other
pressure-containing welds shall be qualified by
testing during welding procedure qualification
or during welding production. This includes all
wires and wire/flux combinations."
It is not clear if the intention is to qualify each
consumable make (brand name), each batch, or
each AWS/EN classification. The boundaries in
which this requirement apply need to be
clarified.
"Each consumable brand name used for girth
welds and other pressure-containing welds shall
be qualified by testing during welding procedure
qualification or during welding production. This
includes all wires and wire/flux combinations.
This does not apply for solid wire provided
documentation of no change in AWS or EN
grouping and nominal chemical composition."
Accepted
Clause 7 7.3.5 Technical
Ref. NOTE in the end of this section. It is possible
to qualify procedures for repair of CRA overlay,
even if the overlay thickness is 3 mm (remaining
thickness prior to welding of 1.6 mm).
Rephrase to state, "unless the manufacturer is
able to document the repair of lower overlay
thicknesses, through welding qualifications. The
remaining overlay thickness prior to welding
during qualification shall be the minimum
remaining overlay thickness used production."
Accepted
Clause 7 7.3.6 Editorial"When it is not feasible to perform test a
sacrificial component..."
Remove the word "perform".Accepted
Clause 7 7-2, Table TechnicalType 22Cr and alloy 825 are also susceptible to
crevice corrosion in seawater
Refer note b also to type 22Cr and alloy 825.Accepted
Table Deleted
Clause 7 7.3.11 Technical
50 HBW units difference between ring groove
material and alloy 625 weld overlay cannot be
guaranteed.
Re-write this requirement to:
"The ring groove material, i.e. Alloy 625/725
weld overlay, shall be harder than the BX-type
seal ring."
Alternatively, if a limit must imposed, it should
be a more realistic value, such as 10 or 20 HBW
units. 50 is not achievable.
Accepted
Clause 7 7.3.12 General
Temperature de-rating factors are provided in
section 6.4.3.6 and Table6-10, but this section
(7.3.12) references ASME Division II, Tables Y-1
and U-1.
Refer to section 6.4.3.6 and Table 6-10, instead
of ASME Division II.Accepted
Clause 7 7.3.13 Technical
Ref. NOTE 1. Does the responsibility for
specifying low temperature limits for elastomers
lie with the manufacturer or the end user?
It may not straight forward for either to carry-
out the thermal analysis. While the
manufacturer has the equipment details
(dimensions and geometry), the flow conditions
may not be easy to estimate.
Selecting a conservatively low design
temperature (such as the standard Charpy V-
notch impact test temperature) may be an more
easily achieved.
Specify whose responsibility it is to define low
temperature limits.
Allow for a conservative low design temperature
(defined as the standard Charpy V-notch impact
test temperature), as long as the compound/seal
can be tested to this temperature.Accepted
Clause 7 7.3.14 General
Coating qualification tests and documentation of
suitability are losely defined. Who is responsible
for defining the requirements of coating
suitability? Manufacturer or end user?
Define documentation requirements and
responsibilities.Accepted
Clause 7 Section 7? Editorial"Valves and Actuators" section is not number. Number "Valves and Actuators" section as
appropriate.Accepted
will get tech writer to update - RC
Clause 7 7.3.17 Technical
"For carbon and low-alloy steels, Charpy V-notch
temperature may be adjusted for
locations/sections in components and for
components with low-applied tensile stress in
accordance with Table 7-6."
It doesn't make sense to adjust test
temperature, unless it can be shown that the
component or section within the component is
not exposed to low temperatures. In case of low-
applied tensile stresses, it may be considered to
reduce the impact energy requirement, but the
test temperature should remain the same, as
long as the equipment is exposed to that
temperature.
Add impact energy adjustment factors, instead
of test temperatures adjustments. Replace Table
7-6 accordingly.
Accepted
Removed temperatures adjustments
Clause 7 7-5, Table General
There are impact energy requirements for both
transverse and longitudinal direction. However,
the standard does not define if testing shall be
carried out in both direction, or if only one of
the two is sufficient.
Define if testing is required in both direction, or
if only one testing direction is sufficient.
Accepted
Clause 7 7-5, table Technical
The terms "longitudinal" and "transverse" do
not completely define the orientation of test
samples. The crack plane direction is not
defined, i.e. even if the sample "transverse" to
the direction of the central axis, the direction of
crack propagation can still be oriented in two
different ways.
Define the crack plane directions in foot note f.
Suggest to make reference to ASTM E1823.
Crack plane directions are:
Long = L-T (for rectangular sections) or L-R ( for
bar and hollow cylinder)
Trans = T-L (for rectangular sections) or C-L (for
bar and hollow cylinder)
Accepted
Clause 7 7-6, Table Technical
It doesn't make sense to adjust test
temperature, unless it can be shown that the
component or section within the component is
not exposed to low temperatures. In case of low-
applied tensile stresses, it may be considered to
reduce the impact energy requirement, but the
test temperature should remain the same, as
long as the equipment is exposed to that
temperature. See also comment to section
7.3.17.
Replace Table 7-6 with impat energy adjustment
factors.
Accepted
Deleted temperature adjustments
Clause 7 7-8, Table TechnicalSuggest adding AISI 4130 as riser pipe material Add AISI 4130 for riser pipe.
Accepted
Clause 7 7-8, Table TechnicalFootnote d. Metal plating is not the only
acceptable coating method for self-seating
pressure energized seals.
Add the following to footnote d: "...or
molybdenum disulfide coating if qualified." Accepted
Clause 7 7.3.20 General
At early design phase (when the materials
selection report shall be prepared), qualification
reports for all materials and manufacturers may
not be available yet. Qualification may be
performed at later stages.
Remove the requirement to have references to
qualification reports in the materials selection
report.Rejected
Even in early design stages, materials that do not have
current documented performance should not be presented
as options in the materials selection report.
Clause 7 7.4.5 General
Dimensional and surface roughness inspection
are not material requirements.
Suggest moving this clause to section 5
(Functional Requirements), Section 10
(Inspection, maintenance, reassessment and
monitoring), or section 11 (Documentation)
Accepted
Clause 7 7.5 General
Quality system and control (including pressure
measuring devices and personnel qualifications)
are not material requirements.
Suggest moving this to a separate section
altogether.Rejected
Clause 7 Several Technical
The term "Crack-like defects" appears in several
sections throughout the document, but it is not
defined. Whose responsibility is it to interpret if
a linear indication is a "crack-like" defect?
Define "crack-like defects" in section 3.1, or
change the term "crack-like defects" to "linear
indications". Accepted
Clause 7 7.6.3 Technical
Ref. sub-item s). SSC tests should only apply if
materials and/or welds are not capable of
meeting sour-service hardness limits or other
limitations imposed in ISO15156.
If material is processed according to ISO 15156
and meets the hardness limits imposed therein,
SSC tests are not needed.
Remove sub-item s) or add statement "if
materials and/or welds do not meet sour-service
hardness limits or other limitations imposed in
ISO 15156."Rejected
Could not find reference
Clause 7 7-11 Technical
Footnote d is not relevant. All materials and
alloys used in critical forged components shall
have material specifications prepared by the
manufacturer. Reference is given to section
7.4.3.2 and 7.6.3.3.
Remove footnote d.
Accepted
Clause 7 7.6.3.2 Technical
"Significant loading (high stress level)" is not
defined. How high do loads/stresses need to be
so that they are defined as "significant loads"?
Define "significant load (high stress)" in section
3.1.Accepted
Clause 7 7.6.3.8 Technical
Guidance note is not relevant. As long as the
material shall be qualified with mechanical
testing after simulated PWHT, the mechanical
properties after PWHT will be insured,
regardless of the relation between tempering
and PWHT temperature.
Remove NOTE.
Accepted
Clause 7 7-12, Table Technical
Furnace loading.
It is ok to require a sketch of furnace loading,
but this cannot be part of the heat treatment
procedure. Heat treatment procedures are
normally general documents, whereas a sketch
of furnace loading is typically job specific (it
depends on how many items are being heat
treated together, and their sizes). If this sketch
shall be part of the procedure, then a new heat
treatment procedure shall be created each time.
This is not practical.
In addition, the responsibility to review and
approve the stacking sketch is not specified. Is it
the end user, manufacturer, or supplier who
shall approve this? Or shall this document be
part of the final documentation, but it does not
require formal approval?
Sketch of furnace loading shall be prepared as
part of ITP, or MPS.
Define the responsibilities of approval of
stacking sketch.
Accepted
Approval responsibilities will be the same for MPSs if
drawing is included in MPS
Clause 7 7-12, Table Technical
Sketch of heat-treatment facility showing
furnace(s) and quenching bath relative to each
other is not relevant. The actual transfer time
from furnace to quench bath is more important
than the relative position.
Remove this requirement.
Accepted
Clause 7 7-12, Table EditorialThere is no cross-reference to footnote a in the
table.
Cross-reference "Equipment qualification" to
footnote a.Rejected
N/A - not footnotes in this table
Clause 7 7.6.3.9 Technical
"Significant loading (high stress level)" is not
defined. How high do loads/stresses need to be
so that they are defined as "significant loads"?
Define "significant load (high stress)" in section
3.1.Accepted
Clause 7 7.6.3.9 General
"The prolongation shall be a full cross section on
the thickest end of the forging if not otherwise
agreed as part of the qualification."
This requirement conflicts with section 7.4.3.4,
3rd paragraph, which states that the
"manufacture procedure shall be derived from
sacrificial components of similar dimensions and
include the specified range of mechanical tests.
The use of prolongation may be acceptable..."
Align both sections. What is the base case,
prolongation or sacrificial? And what are the
conditions for accepting the other?
Accepted
Clause 7 7-14, Table TechnicalFor flat ring forgings, the heat-treated thickness
(T) shall be the smallest between axial length
and radial thickness.
Define T as: "The nominal thickness shall be the
smallest between the axial length and radial
thickness."
Accepted
Clause 7 7-16, Table Technical
Footnote c. It is not necessary to measure the
hardness of components to be welded in Vickers
(HV10), as long as weld qualifications are
performed for the same material, using the
Vickers (HV10) method.
Remove this requirement.
Accepted
Clause 7 7-16, Table Technical
PMI is not applicable for carbon and low alloy
steels. PMI only applies for stainless steels and
CRA's. If verification of chemical analysis shall be
done for carbon and low alloy steels, it shall be
performed by OES.
Remove this requirement, make it specific for
stainless steels only, or call it "Chemical analysis"
instead of PMI and add a note explaining the
difference between PMI and OES and when each
apply.
Accepted
Clause 7 7-16, Table TechnicalRef. footnote i. All manufacturers produce high-
volume of forgings.
Remove this requirement, remove this note, or
define high-volume.Accepted
Clause 7 7.6.3.10 Technical
"For a production part with a complex shape or
variying cross section, the prolongation shall be
an extension of the largest cross section of the
part."
There is a potential conflict between this
requirement and section 7.4.3.4, which reads
"The use of prolongation may be acceptable
provided that section thickness, degree of
mechanical work, and thermal history are the
same as the critical regions of the component."
The reduction ratio of (degree of mechanical
work) or largest cross section prolongation may
not be the same as the for the critical regions.
Clarify and remove conflict.
Accepted
Clause 7 7-17, Table EditorialFootnote a is not cross-referenced anywhere on
the table.
Cross-reference footnote as appropriate.Accepted
updated
Clause 7 7-17, Table Technical
Footnote b, sub-item 4. Testing all forgings (or
two of them as described in this section) is over
strenuous. Before heat treatment, one would
not know which forging will have lowest
hardness and which forging will have higher
hardness. Therefore, all forgings would have to
be designed with prolongations. This would
result in unreasonably high material costs.
Furnace callibrations, sketches of furnace
loading and measuring of transfer time from
furnace to quench bath are measures taken to
avoid large variations. This requirement
becomes overkill
Remove this requirement.
Alternatively, use this method as a fallback
solution for cases where the hardness or
different parts differ more than 20 HBW (ref.
Table 7-16, footnote c)
Accepted
Clause 7 7.6.3.10 Technical
Paragraph describing simulated PWHT is not
prescriptive enough and leaves room for
misunderstandings. It statest that the simulated
heat treatments shall include temperature,
times and cooling rates, but it does not state
what these should be.
Add the following to the paragraph describing
PWHT:
"Simulated PWHT temperature shall be equal to
or higher than the PWHT temperature to be
used on the component during fabrication. Heat
treatment cycle time shall be equal to or longer
than the cycle time to be used during
fabrication. Heating and cooling rates shall be
equal to or slower than the heating and cooling
rates to be applied during fabrication. The
number of cycles applied shall be equal to or
larger than the number of cycles to be applied
on the component during fabrication. The
possibility for future repairs should be evaluated
and, if applicable, additional simulated heat
treatment cycles may be carried to account for
such situations."
Accepted
Clause 7 7-21, Table Technical
100% surface hardness by indentation method is
not standard industry practice.
Suggest the following:
"Hardness of 10% of the items per batch (same
heat and heat treatment lot, with no additional
heat treatment cycles) shall be done by
indentation method. 100% of the fasteners
(including those tested by indentation) may be
tested by other methods (such as magnetic
bridge). All items shall be tested by indentation
if:
- there is a difference of more than 2 HRC points
between the measurements by indentation and
the measurements by magnetic bridge; or
- there is a scatter larger than 3 HRC within the
same batch; or
- any of the items within the batch fall outside
the specified acceptance criteria."
Accepted
Clause 7 7-21, Table Editorial
Footnote c reads:
"The tension tests shall be taken from the bar
used in the manufacture of the nuts and used
for impact testing."
This is sentence is confusing.
Rephrase to:
Tension tests and impact tests shall be taken
from the bar used in the manufacture of the
nuts and used for impact testing."
Accepted
updated
Clause 7 7-21, Table Technical
Footnote c prevents the use of forged nuts,
since they are not manufactured from a bar.
Suggest adding:
"If forged nuts are used, tensile and impact tests
shall be carried out from a block of the same
material (same heat and heat treatment lot),
which has been forged to the same reduction
ration as the nut it represents. The size of the
separate test block shall be such that it allows
for the machining of all test samples and the
heat treated thickness (as defined in Table 7-14)
shall be at least equal to or larger than the
thickness of the nuts it represents."
Accepted
Clause 7 7.6.5 TechnicalMaterial for metal seal rings does not need to be
forged, but it shall have a wrought structure.
Replace "forged" with "wrought" in the second
paragraph of this section. Accepted
Clause 7 7.6.5 Technical
Metal seal rings are normally not exposed to
tensile loads or to impact loads. Especially BX-
type rings, which are loaded only in
compression. Hardness tests are sufficient.
Remove the requirement for impact and tensile
testing of metal seal rings.
Alternatively, remove this requirement for BX-
type rings.
Rejected
Tests are need to insure quality not just fitness for service
Clause 7 7.7.1 Technical
Sub-item e) "All welding of components exposed
to wellbore fluid shall comply with the welding
requirements of ISO 15156" is not applicable if
sour-service does not apply, i.e. if the wellbore
fluid is not sour. See also section 7.7.5.5.4
Rephrase to:
"All welding of components exposed to sour-
service shall comply with the welding
requirements of ISO 15156."Accepted
Clause 7 7.7.3 Technical
Simulated PWHT: It is a requirement to qualify
the base material with tests after simulated
PWHT. As long as the simulated PWHT
parameters used for mechanical testing of the
component are equal to the paramers used
during welding, the properties of the base
metals are already qualified. There is no value-
added in repeating these tests for the welding
procedure. See also comment above to section
7.6.3.10.
Remove this requirement, or add "if the base
materials to be welded have not been qualified
with simulated PWHT, as described in section
7.6.3.10."
Rejected
Clause 7 7.7.3 Technical
Sub-items identifying when no further testing in
simulated PWHT condition is necessary should
be essential variables of the welding procedure,
and not related to simulated PWHT only.
Remove these items from this section add them
to table 7-23 as additional essential variables.Rejected
Editorial
Clause 7 7.7.5.1 Technical
"Time between each layer" is not a relevant
essential variable. Typically, during weld
qualification, the time between layers is longer
than in production welds, due to logging
activities (such as measuring the length of the
weld bead, interpass temperatures, etc.). It is
not practical to repeat this during production.
Remove this requirement.
Accepted
Clause 7 7.7.5.2 Technical
The allowable temperature range cannot be
based upon "nominal temperature". All heat
treatment methods (furnace, heating elements,
induction, etc.) will have built-in temperature
variations. If the allowable range is based upon
"nominal" temperature, then the actual
temperature can be even further than 14°C from
qualified, due to variations within the heat
treating equipment.
The allowable temperature range shall be based
upon actual temperature.
Replace "nominal" with "actual".
Accepted
Clause 7 7.7.5.5.3 EditorialReference is made to "Table 29". This table
doesn't exist.
Correct cross-reference.Accepted
now, table 7-27, updated
Clause 7 7-23, Table Technical
Footnotes a and b specify when to use CE(Pcm)
and CE(IIW). However, the "chemical
composition" line references both of them.
Clarify if both are to be used, or only one of
them, as suggested by footnotes a and b.Accepted
Clause 7 7-23, Table Editorial
Post-weld heat treatment:
There is a conflict with section 7.7.5.2, which
allows a temperature range of +/- 14°C, while
this table allows +/- 20°C.
Correct table to +/-14°C
Accepted
now table 7-21, updated
Clause 7 7-23, Table Technical
Post-weld heat treatment:
The unit of heating and cooling rates needs to
be specified. 5% of °F/hour is not the same as
5% of °C/hour.
Specify unit (°C/hour)
Accepted
Clause 7 7.7.7.1 Technical
"The procedure shall identify the essential and
non-essential variables and address the
permissible number of re-heat treatments."
The number of heat treatments in a weldment is
determined by the weld qualification. Addition
or deletion of PWHT is an essential variable
requiring re-qualification.
If the complete weld overlay and HAZ is
removed, then this is accounted as a new weld,
and a new PWHT can be performed, as per
WPS/WPQR. However, the ability of the base
material to withstand the additional PWHT cycle
needs to be verified throug mechanical tests
after simulated PWHT. This is not related to the
WPS/WPQR qualification.
Remove "and address the permissible number of
re-heat treatments."
Accepted
Clause 7 7.7.7.2 Technical
"nominal temperature of +/- 14°C"
Nominal is not sufficient. See also comment to
section 7.7.5.2.
Replace "nominal" with "actual".
Accepted
Clause 7 7.7.7.3.1 Technical
Weld overlay in sealing faces is loaded primarily
in compression. Tensile and impact testing are
irrelevant. They will add a significant amount of
work and effort to the qualification of weld
procedures, in return to very little value added
to the quality of the overlay or seal face.
Remove the requirement to perform tensile and
impact tests for overlay of sealing faces.
Accepted
Clause 7 7-24, Table Editorial
Number of tests for Charpy V-Notch and for
Microstructural Examination is not specify.
Correct accordingly.
Accepted
The comments do not refer to the latest version (they do not
match paragraph number, bullets, subject…). We addressed all
comments received as a group before sending the clause to you
at the end of February.
Clause 7 7.7.7.3.6 TechnicalMicrostructural examination of solid solution
nickel based alloys should not be required.
Add "except for solid solution nickel based alloy
overlays, where microstructural examination is
not required"
RejectedThe exam is for thickness not microstructure
Clause 7 7.7.7.3.7 Technical
There is a potential conflict with section 7.7.7.1,
which states that "the minimum overlay
thickness used for the production shall be used
for the welding procedure qualification tests."
If all-weld tensile test samples are to be
machined from the weld overlay, then it may
not be possible to qualify with the minimum
thickness to be applied during production.
Clarify and remove conflict.
Rejected
Clause 7 7.7.8.3 GeneralAWS A2.4 is also a valid standard for welding
symbols.
"Symbolic presentation of welds shall be
according to ISO 2553, AWS A2.4, or equivalent." Accepted
Clause 7 7.7.8.6 TechnicalFCAW (136/137) produce welds of similar or
better quality than SMAW (111).
Add FCAW (136 / 317).Accepted
Clause 7 7.7.8.10 Editorial
There is a confict between this section and
section 7.7.3, which requires PWHT for joints
exceeding 20 mm.
Remove the first paragraph of this section.
Accepted
The comments do not refer to the latest version (they do not
match paragraph number, bullets, subject…). We addressed all
comments received as a group before sending the clause to you
at the end of February.
Clause 7 7.7.8.10 Technical
Heating rate, cooling rate and soaking
temperature shall be specified on the WPS, and
it shall be equal to the parameters used during
qualification. It is not necessary to include this
information also on a PWHT procedure.
Remove sub-items a), b) and c).
Accepted
Clause 7 7.7.8.12 TechnicalProduction tests may not be possible for repairs
and re-certification, due to lack of material
available to run such tests.
"For the fabrication of new systems, a
production test program shall be established..." RejectedIf material is not available, then a wavier can be considered
Clause 7 7.7.8.12 Technical
SSC testing should not be required if both
welding procedure and production tests show
hardness in accordance with ISO 15156.
"SSC testing is required for production if
hardness testing fails to meet the requirements
per ISO 15156."Accepted
Clause 7 7.7.9.2.1 Technical
Grinding flush of weld root may not be practical
or possible in all locations. Welds located far
from the ends of the riser joints may not be
accessible.
Replace "shall" with "should whenever possible"
Rejected
Accesibility can be assesed at time of issue
Clause 7 7.7.9.4.1 Technical
Weld overlay in sealing faces is loaded primarily
in compression. Qualifying as a buttweld for this
application is irrelevant. This will add a
significant amount of work and effort to the
qualification of weld procedures, in return to
very little value added to the quality of the
overlay or seal face.
Remove the requirement to qualify weld overlay
which is part of a sealing system as a butt weld.
Accepted
Still required if strength of overlay contributes to design
Clause 7 7.7.9.4.1 Technical
How should overlay welds be qualified as
buttwelds? Base materials on both sides, with a
groove and overlay material used as filler metal?
This is not representative of the actual weld
configuration.
"When weld overlay strength is considered as
part of the design the clad shall be qualified with
tensile test accross the fusion line, all weld metal
tensile test, and impact test of the weld metal,
fusion line, FL+2mm and FL+5mm. The weld
configuration should be agreed between the
parties involved, and it should be as close as
possible to the actual configuration on the
finished component, but at the same be of a
geometry and size that allows for the machining
of all relevant test samples."
Rejected
If the overlay is included in strenghth calculations, it must
be qualified as a load bearing system. If this is not desired,
don’t include the overlay as part of the strength
Clause 7 7-32, Table Technical
"No visible indication, i.e. surface shall be free
from cracks and other linear defects."
Does this mean that rounded indications are
acceptable?
Remove the word "linear".
Rejected
Redundant
Clause 8 8.3.4 TechnicalLock and unlock connector 6 times. 6 cycles is
unnecessary and may cause unnecessary wear.
Lock and unlick the connector 2 times.Accepted
Requirement revised
Clause 8 8.9 TechnicalItem B-5. Testing the Stress joint atop of EDP
can be a challenge and not practical.
RemoveRejected
Requirement remains as stated
Clause 8 8.9 TechnicalItem B-8. Pressure testing before and after
disconnect of EDP can be a challenge.
RemoveRejected
Requirements remain as stated
Clause 8 8.9 Technical
Bullet b) 4)
Disconnect of EDP under riser load conditions
are not a practical test to perform. High angle
release capability under loads are verified during
qualification, and only a verification that
additional structure doesn't limit the connector
performance could be required.
REMOVE this from SIT as High Angle disconnect
capability is part of Performance Qualification,
not SIT.
Accepted
Requirement revised
Clause 8 8.3.1 General
Fourth paragraph states that gas testing shall be
performed as part of qualification testing. For
equipment not designed for gas service this is
considered to onerous.
Distance from pipe ends shall be at least 2T or
no greater than 122 (305mm).Accepted
Requirement revised
Clause 8 8.3.1.2 General
Consistency required 8.3.1.3 mentions test
pressure but here we mention minimum test
pressure which is correct?
Suggest removal of "minimum"
Accepted
Requirement revised
Clause 8 8.3.1.3 GeneralConsistency required 8.3.1.3 mentions test
pressure but 8.3.1.2 mentions minimum test
pressure which is correct?
AcceptedRequirement revised
Clause 8 8.3.1.4 General
Agree with this but 8.3.5 does not exist.
Previous WD2 mentioned testing Riser Joints to
API 6A PSL 3 requirements with the exception
that they could be painted. Is this the intention?
Clause 8.3.5. should read 8.3.2
Accepted
Revised to a NOTE
Clause 8 8.3.1.4 TechnicalWhat about external proof test pressure; 1.1
MWP for control linesRejected
Covered in another referenced standard
Clause 8 8.3.1.5 General
Is gas body (leakage) testing required for the
manufacturer to perform? The wording is
slightly confusing in the opening statement.
More clarification.
Accepted
Requirement revised
Clause 8 8.3.2.1 a) Editorial Reference to 8.3.5.2 does not exist. Fix reference. Accepted requirement revised
Clause 8 8.3.2.2 TechnicalJustification for 1.25 x Pd as test pressure? Justification required
AcceptedRequirement revised
Clause 8 8.3.3 GeneralAgree with tests.
Caveat:- Should a separation of the hub faces be
included in the Lock - unlock test?
add a separation of the hub faces be included in
the Lock - unlock e.g. unlock - separate - engage -
lock
AcceptedRequirement revised
Clause 8 8.3.1.2 Technical
Unclear statement on allowable pressure drop
(Jonas to propose)
8.3.1.1 Start of hold periods
Hold periods shall start after pressure and
temperature stabilization has occurred and the
equipment with
a pressure-monitoring device has been isolated
from the pressure source. The time specified for
hold
times shall be a minimum.
Initial pressure shall be between specified test
pressure and 5 % above.
Temperature shall be considered stabilized when
the rate of change is less than 0,5 °C/min (1
°F/min).
8.3.1.2 Acceptance criteria - hydrostatic pressure
testing
The following acceptance criteria shall apply for
all hydrostatic pressure testing:
a) No visible leakage during the hold period;
b) Pressure drop curve should be approaching
zero rate in change;
c) The allowable pressure drop is 3% of the test
pressure per hour.
Note: the pressure during the hold period may
drop below the specified test pressure as long as
the acceptance criteria are fulfilled.
Partially
Accepted
Requirement revised
Clause 8 8.3.2.1 GeneralIncomplete statement of how long minimum
hold times shall be
Complete statementAccepted
Requirement revised
Clause 8 8.3.3.1 GeneralSays that each riser joint must be hydrostatic
tested, but Table 6-X says drillpipe doesn’t need
hydrostatic testing
Fix confusion between 8.3.3.1 and Table 6-X for
hydrostatic testing RejectedNo table in Clause 8
Clause 88.3.2.4 &
8.3.3.2Technical
Pressure testing is 1.5x rwp and 1.25 design
pressure in another place. Needs consistency
Keep the pressure testing consistent. There's
several references to different values and it's
hard to keep straight.
AcceptedRequirement revised
Clause 8 8.3.1 General
Fourth paragraph states that gas testing shall be
performed as part of qualification testing. For
equipment not designed for gas service this is
considered to onerous.
Rephrase to state that equipment qualified for
gas service shall be qualified with gas.Accepted
Requirement revised
Clause 8(8.3.1.5)
8.3.2.5Editorial
Remove reference to water as test medium for
gas testing.Accepted
Requirement revised
Clause 8 8.3.2.2 Technical#### Justification for 1.25 x Pd as test pressure?
####Accepted
Requirement revised
Clause 8 8.9 Technical
Bullet b) 3)
Drifting of TSJ and EDP potentially poses
significant HSE risk from working at very high
elevations to get access. Benefit from this test
arguably doesn't provide enough benefit to
justify this as long as a seal arrangement that
can be verified to be driftable is used.
Remove bullet b) 3)
Rejected
Requirement shall remain as stated.
Clause 8 8.9 Technical
Bullet b) 4)
Disconnect of EDP under riser load conditions
are not a practical test to perform. High angle
release capability under loads are verified during
qualification, and only a verification that
additional structure doesn't limit the connector
performance could be required.
"Connect and disconnect angles shall be
simulated to verify that framework, control
interfaces or other details don't inhibit proper
function of the EDP connector. Interface shall be
pressure tested before and after a
disconnection."
Accepted
Requirement revised
Clause 8 8.3.1.5
A hydrostatic body test shall be performed prior
to any gas testing.
Can the equipment be stripped and dried after
the Hydroststic body test before carying out the
Gas test? There is no suggestion that the hydro
is directly before the gas test only that it has to
be carried out.
Accepted
Requirement revised
Clause 8 8.3.1.5
Water or water with additives shall be used as
the test fluid. Any additives shall be
documented in the test records.
This intimates that the hydro test is directly prior
to the gas test. Gas testing with Nitrogen will
cause any water to freeze. This could be an
issue.
Request addition of strip down and drying of the
tool between hydro and gas testing. OR removal
of this paragraph.
Accepted
Requirement revised
Clause 10 10.2 Technical
Inspections should include material testing i.e.
HISC
Inspections relating to areas such as the
following may be necessary for subsea well
intervention system components: j) material
degradation (HISC)
Rejected
Methodology to be further discussed and included in the
next WD
Clause 11 11.4.2 b)
b) design criteria with reference to applicable
codes, standards, and regulations for:
- strength and leak-tightness for normal,
extreme, testing, accidental load conditions
based on minimum specified strength/preload
values;
- safe break joints (weak links) based on
maximum specified strength values;
- maximum cyclic peak stress ranges, i.e.,
SCFs/stress distributions for fatigue assessment.
shall be documented. SCFs introduced by the
connector in the connecting pipe girth weld
location (both inside and outside diameter)
without any eccentricity shall also be
documented;
"b)" needs to include minimum breakage value
as well as maximum. This may be project specific
so may not be available until a GRA has been
carried out.
Accepted, see
update
Wording should reflect minimum breakage values, not
maximum:
"b) design criteria with reference to applicable codes,
standards, and regulations for:
- strength and leak-tightness for normal, extreme, testing,
accidental load conditions based on minimum specified
strength/preload values;
- safe break joints (weak links) based on minimum specified
strength values;
- minimum cyclic peak stress ranges, i.e., SCFs/stress
distributions for fatigue assessment, shall be documented.
SCFs introduced by the connector in the connecting pipe
girth weld location (both inside and outside diameter)
without any eccentricity shall also be documented;"
All All General Technical
The term "qualified" is used through the
specification, it has little to no substance unless
it is connected to a related requirement. Such
as: qualified to the requirements of ISO 28781
or the like. See 5.3 g) as an example
Replace the term "qualified" with conforming to
the requirements of…. or validated to the
requirements of ….. In each use
Moved to WD 6 comments
All
All
Section
s
GeneralTerminologies "elastic ideal plastic" and "elastic
perfectly plastic" are used interchangeably,
which may be confusing.
Align terminology. Moved to WD6 Comments
Need input from Finn to resolve
All
All
Section
s
Technical
Reference is made to kill and circulation cap.
This is a specific system reference (FMC?) it
should be defined or explained better
No correction
made
Moved to WD6 Comments
All
All
Section
s
Additionally there is no reference made to single
top tension operations. Not all operations use
riser tensioners. This needs to be allowed for
throughout this section
Accepted
Moved to WD6 Comments
move to technical - Agree with comment
All
All
Section
s
Pull 17B design reference out of the document Accepted
Moved to WD6 Comments
need further clarification - ask Brian
All
All
Section
s
ALL General
reveiw entire annex to remove mention of
applying pressure upstream or down stream of a
valve. Annex is for valves with different primary
seal directions, ie RV only function is to seal
from 'above', where pressure would be applied
from the 'downstream' direction. according to
this annex it would only be tested from the
'upstream' direction.
Replace 'upstream' with 'primary sealling
direction' and 'downstream' with 'secondary seal
direction' Accepted.
Test
procedures
are often
ambiguous.
Technical writer to work with Paul/Ray to clarify intent of
each instance of upstream/downstream. Possible alternate
method would be uniform "above" or "below" relative to
operating position. EG retainer primary sealing direction is
"from above". What is the primary direction for a
lubricator? Pump-through behavior may complicate things.
Accepted to Change throughout doc and add to definitions
Annex B B.4.8 Technical
Larger angles in upper flex joint than in ISO
13628-7
Table B-15 gives recommended values for
minimum ball/flex joint angle tolerance for a
landing string. Depending
on operational region, and water depth, it may
be necessary to design the landing string with
better tolerance,
to achieve sufficient environmental limits. Table
B-15 is difficult to understand. Tolerance is
normally applied to design value. A specified
tolerance without a design valve is has no value.
Tolerance is normally related to measurement
accurracy and therefro shall be constant for load
conditions. What is the definition of "lower" and
and "upper"
Table B-15 shall be revised such that it can be
understood.
Annex C C.6.3.3 GeneralEq. (C.5) would be easier to understand if a
figure was included.
Include figure. Accepted
comment relates to WD 4 numbering. Moved to WD6
Comments
Fk to include figure. Now in section C.6.1.3
Annex C C.1.2 TechnicalReferences 480F when 350F was the highest
possible through Table 6-6
Fix temperature maximumRejected
move to note- limitations on creep only. Does not mean
that section 6 is wrongAnnex C Table C-3 Editorial Update table C-3 to inlcude figures update table Accepted See WD6 Additions folder and replace table
Annex D Table D.1 Technical
States that surface friction exceedance is a
separate failure mode, but it is covered by the
plastic collapse assessment. Unzipping of the
thread will cause a reduction in connection
stiffness, an increase of load to the threads still
in contact and therefore this will be visible as a
drop in the plastic collapse load from the
respective assessment.
Merge the friction exceedance and plastic
collapse modes of failure in the table.Mod - text to
be part of the
analysis
however not a
separate
criteria.
Rejected
Moved to WD6 Comments
Discuss with Team. -- Keep Separate in the Plastic collapse
analysis - Unzipping. Note: No specific criteria for each
failure mode - Need to propose a level.
Annex D D.2, Table Technical
primary & secondary plastic limit is 3x and not
2x. 2x comes from 3x times 2/3 safety factor.
change allowable stress at plastic collapse to 3.0
Rejected
Moved to WD6 Comments
Note: Increase in 50% load capacity from Elastic to Plastic -
Load Limit theory
Annex D D.2, Table Technical
Limitations on shear and bearing have been
removed they should be reinstated if people are
to be allowed to use linear-elastic method.
Reinstate shear and bearing allowables.
Accepted
Moved to WD6 Comments
Need to add shear and bearing stress allowables.
Annex D D.2 Technical
Remove bullet point f) - contradictory to e). Remove bullet point f). Rejected -
Shear subs are
unique from
speciality
Moved to WD6 Comments
Annex D D.2.3.2 GeneralParagraph 1 - Some components in a tool may
not be applicable for 'plastic collapse capacity'
analysis.
Add better definitionRejected
Moved to WD6 Comments
Annex D D.2.3.2 GeneralSecond sentence in Note 2 refers to "elastic
plastic material" whereas "elastic ideal plastic
material" is meant.
Change "elastic plastic material" to "elastic ideal
plastic material". RejectedMoved to WD6 Comments
Annex D D.2.3.4 GeneralParagraph 2 - What does 'Friction imply also
friction angle due to contacting angle' mean?
Please clarify statement in documentAccepted
Moved to WD6 Comments
Annex D D.2.3.4 C Technical
does not make sense for this feature - by
definition it is self locking and has no effective
exceedence capacity
clarify Accepted -
need to add
Figure D2
(illustration of
the pre-load
exceedance)
However "self
locking"
within a range
Moved to WD6 Comments
Annex D D.2.3.6 Editorial
description of preload exceedence capacity
varies throughout some times exceedence of
preload capacity - confusing. Need to stick to
one title & description throughout standard.
Table D.1 defines as Preload Exceedence, so use
that
Change D.2.3.6 title to "Preload Exceedence
Capacity" Change content G.1, G.2.2 to "preload
exceedence" Made no
change
Moved to WD6 Comments
Move to Technical -- rewording of the statement by
original author required.
Annex D D.2.3.6 Technical
This para needs some clarification but in general
the point is not carried through the rest of the
standard. The seal face preload capacity is
different to the hub face preload capacity. Also
further clarification required in relation to seal
prep separation
Add after "relative displacements at the hub
faces" the sentence "This may give rise to two
preload exceedance capacities - at the seal prep
(inner) and at the hub face (outer), which should
be determined and used as appropriate to assess
connector and seal performance". Alter standard
throughout to add seal prep preload capacity.
D.2.6.2.1 and I.2.2 to be changed to read "hub
face separation at seal preps"
Rejected Add
after "relative
displacements
" "Preload
exceedance
capacities - at
the seal prep
(inner) and at
the hub face
(outer).
D.2.6.2.1 and
I.2.2 to be
changed to
read "hub face
separation at
seal preps"
Moved to WD6 Comments
Annex D D.2.3.7 General
For me it is not clear what shall be calculated
regarding permanent loss of preload.
1. From the first paragraph and the sentence
"The permanent loss of preload is the maximum
load the connector can sustain before there is
reduction in the original preload exceedance
capacity" it seems the permanent loss of
preload capacity is a load, e.g. 4000 kN or 1500
kNm, i.e. the maximum load that can be applied
without loasing preload exceedance capacity.
2. However, from the paragraph after the note
(and Figure D.3) it seems the idea is to calculate
how much preload exceedance capacity is lost
after application of different collapse capacities,
i.e. this would be a number, e.g. 5 % loss or 95 %
remaining preload exceedance capacity.
Clarify
Needs
clarification -
Moved to WD6 Comments
Annex DD.2.3.7,
continuedGeneral
If 2 above is the intention, this is not really a
capacity, rather a number (percentage)
describing the remaining preload exceedance
capacity after various load scenarios. If 1 above
is the intention, the permanent loss of preload
capacity would be a single load, independent of
normal, extreme or accidental load. Ref. also
Table D.4 and D.5.
Clarify
Rejected
Moved to WD6 Comments
Annex D D.2.3.8 Technical
Double use of per unit length. Change phrase "...can be 200 N/mm (1150 lbf/in)
per circumferential unit length mm (inch) of seal
contact to provide a gas tight seal" to "...can be
200 N/mm (1150 lbf/in) of seal contact to
provide a gas tight seal".
Accepted
Moved to WD6 Comments
Seal contact stress shall be analyzed as part of the static
analysis to evaluate gas seal tightness for variations
connector load cases as defined in Figure (xx- Preload
exceedance).
Annex D D.2.3.8 Technical
Standard has slipped into describing seal design
performance criteria which is not a compete
description and is not guarantee of
performance. The standard should not be
attempting to provide MTM seal design
criterion.
remove paragraph starting Metal-to-metal and
replace. "The performance of a MTM seal is
subject to many parameters and it is outside the
scope of this standard to specify performance
criteria. The seal used should be assessed for
performance in the context of the connection
characteristics e.g. separation at seal preps and
in line with the performance criteria for the seal
in question"
Accepted
Moved to WD6 Comments
The performance of a MTM seal is subject to many
parameters and is outside the scope of API 17G
Annex D D.2.3.9 General
How do we cover this galling mechanism in
Analysis. Unless some methodology can be
identified, I suggest that this requirement is
moved to the testing.
Either define an appropriate methodology to
consider galling or move to a testing section.
Reject - Galling
is outside the
scope of this
Annex D
Moved to WD6 Comments
Annex D D.2.4 General
Paragraph7 - How do you 'ensure' that for every
tension there is a single collapse moment if
there is load path dependency as stated may the
case in the previous paragraph?
See comment
Accepted with
comments.
Moved to WD6 Comments
The designer needs to perform "load path and sequence of
applied loads will impact calculations to determine the
collapse load limitations..
Annex D D.2.5.2 Technical
Linear elastic (e) - How do you have 'plastic
collapse' for a linear elastic analysis?
Please clarify statement or delete Accepted:
Load limit
static analysis
shall include
both elastic
and plastic
collapse
Moved to WD6 Comments
Perhap point is to conduct comparison between elastic and
plastic collapse
Annex D D.2.5.2 Technical
Point c) in list states that linear elastic analysis is
not applicable for "cases which requires
separation of stresses into primary and
secondary stresses". This seems to contradict
sec. D.2.5.3 which requires that stresses be
"decomposed into primary and secondary
stresses".
Delete Point "c) … Moved to WD6 Comments
Ref Addition: 2.5.3. note: Impossible to split the stresses
and needs to be summed .
Annex D D.2.5.3 Technical
Paragraph above Table D.2 - If permanent
deformation is present, why is elastic stress
analysis allowed?
Line of discussion is wrong and confusing,
consider deleting
Accepted--
need to
review the
2.5.2 with
Moved to WD6 Comments
Annex D D.2.5.4 General
Is it allowed to perform new analysis in
accordance with the the API 17G 2nd ed. and
still be compliant with API 17G 3rd ed.? Or is the
statement in the NOTE only for existing
analyses?
Clarify
Rejected
Moved to WD6 Comments
Annex D D.2.6 Technical
Note 6 - First sentence about linear element
types is not true for tetrahedral elements.
Remove NOTE 6: -- Discuss with
Team -
Tetrahedral
elements --
Moved to WD6 Comments
Replace to Should ---
Annex D D.2.6.3 Technical
no partial threads - might be OK for some
designs but especially large threads need to
consider half a partial thread at each end so
threads are N-1 and not N-2
change "with no credit for partial threads" to "up
to a maximum of one half of a partial thread may
be considered"
Moved to WD6 Comments
Paul to comment
Annex D D.2.6.3.1 GeneralParagraph 1 - Why does one need to find the
'thread load distribution'? How do you report
that as a function of applied load?
Moved to WD6 Comments
Paul to comment
Annex D D.2.7 General
Paragraph 6 - States 'See previous comments
relating to member extensions being added to
the geometry'. Where are the previous
statements? I did not find them.
Rejected
Moved to WD6 Comments
Annex D D.2.7 GeneralWhat is the purpose of adding Note 3? I do not
understand the comments.
Moved to WD6 Comments
Annex D D.2.7 Technical
Loss of preload capacity too - many load steps -
excessive analysis requirements. No one should
be operating after 90% & 100% loads anyway.
reduce to 67% (working) and 80% (extreme) Reject: Part of
Limit state
design method
to evaluate
load range of
component
Moved to WD6 Comments
Annex D D.2.7 Technical
As part of the typical load sequence list it is
stated that we must include
"Pressure/temperature cycling of metal seals as
per ISO 10423:2009 F.1.11 or 3 pressure cycles
in cases where thermal effects can be
neglected;". If thermal effects are being
neglected why do we need to perform an
additional 3 pressure cycles after the FAT. These
will not overcome the induced residual stress
state from the FAT.
Reword to "Pressure/temperature cycling of
metal seals as per ISO 10423:2009 F.1.11 where
thermal effects cannot be neglected;".
Accepted
Moved to WD6 Comments
Annex D D.3 Technical(c) - I do not agree with this method for the
stress-strain curve as shown in Figure D.6.
Where does this come from?
AcceptedMoved to WD6 Comments
Annex D D.3 Technical
Point c) in list states "Set onset of plasticity to
sy..." and refers to Figure D.6. However, the
curve in Figure D.6 shows non-linearity prior to
yield.
It should be specified that elastic ideal plastic
models should have a cut off at yield and maybe
give recommendations for elastic plastic curves
with hardenability.
Accepted with
additional
strain and no
strain
Moved to WD6 Comments
Annex D D.3 GeneralPoint f) in list: Should "loss of preload capacity"
be "preload exceedance capacity"?
Consider changingAccepted
Moved to WD6 Comments
Annex D D.3, Figure TechnicalMisses seal prep displacements (as discussed in
D.2.3.6)
add additional line to graph illustrate seal prep
separationAccepted
Moved to WD6 Comments
Annex D D.3, Table Technical
Friction - zero or artificially low COF can NOT be
used in taper connectors at the dog/cam
interface
Add after first sentence "it is accepted that taper
connectors will need to apply friction at the
cam/dog interface". Rejected
Moved to WD6 Comments
It is accepted that taper connectors will need to apply
friction at the cam / dog interface with very low values to
allow convergence of the model.
Annex D D.3, Table Technical
The use of worst case dimensions during finite
element analysis will included worst case
(minimum metal) thread dimensions. The
analyst shall consider the effect of other
possible dimensional variations and dimensions
expected to limit capacity shall be modeled at
worst case.
Modify to "The use of significant worst case
dimensions during finite element analysis will
included worst case (minimum metal) thread
dimensions. The analyst shall consider the effect
of other possible dimensional variations and
dimensions expected to limit capacity shall be
modeled at worst case.
Accepted,
update
change
Moved to WD6 Comments
"other dimensional variations are ovality, corrosion loss,
coatings, max/min tolerance conditions, taper
dimensioning tolerance, etc.
Annex D D.4 Technical(e) Where does the equation for the true strain
at failure come from?
Please defineRejected
Moved to WD6 Comments
Annex D D.4 Technical
Too many actuals are required. Some are not
sensitive to capacity
change "elastic-plastic FEA shall be performed
considering the following" by adding "where
these are deemed to be significant"
Accepted
change
Moved to WD6 Comments
Annex D D.6 General
(g) I do not agree that the deformed and un-
deformed shape should be superimposed for
the failure location? What is the purpose
Remove this requirement Moved to WD6 Comments
Annex D D.6 General(h) (8) What is the purpose of showing the
thread load distribution?
Remove this requirement Moved to WD6 Comments
Annex D D.6 General (i) This comment is overly prescriptive. Remove 'shall'. Moved to WD6 Comments
Annex D D.6 General(j) Why is the principle stress direction needed?
Which principle stress?
Moved to WD6 Comments
Annex D D.7 Technical
"Therefore, strain gauges shall be located to
obtain
results due to primary loading, and to avoid
results due to secondary and peak effects."
Strain gauges can not sensibly be put at key
sections and attempts to do so will alter results
due tio modifications (grooves/holes) and/or the
results are meaningless due to the size of gauge
Therefore, strain gauges shall be located to
obtain
results due to primary loading, and to avoid
results due to secondary and peak effects. Add
"where this is not possible, then analysis and
correlation of results is required".Accepted
Moved to WD6 Comments
Annex DEquation
D.7General
Pc in equation D.7 is not defined. Give definition of Pc in list above equation Shift to
definition -
need to add -
"Collapse
Pressure"
Moved to WD6 Comments
Annex D Figure D.1 General
Terminology of Figure D.1 is not aligned with
terminology in Table D.1 and text in general.
This applies to several places in Annex D where
"Loss of hub separation" and "Hub face
separation capacity" is used instead of
"Permanent loss of preload capacity" and
"Preload exceedance capacity"
Align terminology of Figure D.1 with terminology
in Table D.1 and text in general.
Accepted
Moved to WD6 Comments
Annex D Figure D.3 GeneralTerminology of figure not aligned to general
terminology, ref. comment to Figure D.1
Align terminology of Figure D.3 with terminology
in Table D.1 and text in general.
Moved to WD6 Comments
Annex D Figure D.5 Technical
Why does the 'elastic-plastic without strain'
utilize plasticity up to the offset yield? I do not
know of anywhere else that this is used.
I.e. include the use of strain-hardening into
analysis
Rejected : this
is part of limit
state design
and captured
in the Design
Factor.
Moved to WD6 Comments
Annex D
In
particular
sec. 6,
Annex D,
ALL
SECTIONS
Technical
The use of plastic collapse as structural criterion
with a design factor of 2/3, 0.8 and 1 (0.9) in
normal, extreme and accidental operation
respectively may give a considerably increased
structural capacity compared with the previous
edition of API 17G. The pipe example in Annex E
gives an increase of 32 %, ref. Table E.1. Is this
intended? Also, in accidental mode this will
actually allow the part to collapse unless the
capacity is limited by a functional criteria. For
reference ASME VIII Div. 2 Part 5 (2011) is using
a safety factor of 2.4 against plastic collapse, see
Table 5.5 of ASME. In addition, ASME has a local
failure criterion that needs to be satisfied, which
would limit local plastic strains, ref. ASME sec.
5.3.3.1.
Consider adjusting design factors and
introducing local failure criterion, in particular
when elastic-plastic material with strain
hardening is used.
TBD
Moved to WD6 Comments
Annex D
Note 2
below fig
D.6
Technical
Can we not simply use the ASME Sec 8, Div 2….
Curve?
This should have limited impact, since we
typically limit the designs to around 2% strain
limits, not run this all the way to break
Reject : Design
methods are
based on limit
load analysis.
Moved to WD6 Comments
Annex D Table D.1 General
Progressive plastic deformation is not included
in the table although it is include in Table 17 and
treated in sec. D.2.3.5
Include structural failure mode "Progressive
plastic deformation". To include racheting
Moved to WD6 Comments
Update table to include racheting as a structural failure
mode
Annex D Table D.3 GeneralGeometry - What imperfections 'shall' be
included?
Either add specifics or delete comment from
table.
Moved to WD6 Comments
Annex D Table D.3 GeneralDetermination of capacity - What is meant by
'analysis increment scheme'?
add additional information Moved to WD6 Comments
Annex D D.2.3.4 Technical
Exceedance of surface friction. Capacities for
exceedance of surface frication will
automatically be evaluated in the plastic
collapse
analysis.
Exceedence of surface friction poorly defined.
Should instead be named: "Unlock resistance"
Accepted -
need to add
Figure D2
(illustration of
the pre-load
exceedance)
However "self
locking"
within a range
Moved to WD6 Comments
Annex D D.7 General Move section to Annex I Moved to WD6 Comments
Annex D D.2.6.2 TechnicalReconsider making 3D FEA required for
threaded connectors.
Make 2D axisymmetric FEA required for thread
connectors and 3D optional.Rejected
Requirement is clear and consistent
Annex D D-4' GeneralIs this table for FEA or for physical testing? What
is its purpose? Is this related to Annex I?
Specify what this table is forRejected
Requirement is clear and consistent
Annex D D-5' General Explicitly state that this table is for FEA See comment Rejected Requirement is clear and consistent
Annex E E.3.3 General
The use of a pipe as analysis example raises the
question of whether it is allowed to use FEA
(elastic plastic with strain hardening) to
determine pipe capacities. This is especially so
considering the statement that "It is further
seen that there are large reserves in plastic
collapse capacities determined by elastic-ideal
plastic analysis compared with capacities
determined by elastic-plastic analysis as
required by API 17G". What does "as required by
API 17G" refer to, i.e. exactly what is the
requirement in API 17G? My impression before
reading Annex E was that we could freely choose
between elastic, elastic ideal plastic or elastic
plastic with strain hardening for components in
general, but that the formulas in sec. 6.5 are to
be used for pipe.
Clarify Moved to WD6 Comments
Finn to re-write
will not be addressed in WD6 - Annex placed on hold
Annex E E.3.4.2 Technical
It is stated that "The analysis is performed with
linear elastic material." This is combined with
the HS curve. But according to sec. C.9 point b)
1) an elastic-plastic material model shall be used
in combination with the HS curve. If a linear-
elastic model is used, it shall be combined with
B1 curve. As the objective of Annex E is to
illustrate calculation of cyclic capacities (ref. E.1
b)) it is strange to not follow the requirements in
Annex C.
Clarify Moved to WD6 Comments
Finn to address
will not be addressed in WD6 - Annex placed on hold
Annex E E.3.4.2 General
Just after Figure E.7 it is stated that "The elastic-
plastic material model with strain hardening has
been applied in the analysis." Earlier in this
section it is stated that a linear-elastic material
model is used, ref. comment above. It is unclear
exactly where the elastic and the elastic-plastic
material model has been used.
Clarify
Moved to WD6 Comments
Finn to address
will not be addressed in WD6 - Annex placed on hold
Annex E E.3.4.2 General
The Local Stress Max values in Table E.3 are not
found in the corresponding Figure E.8.
Correct Moved to WD6 Comments
Finn to address
will not be addressed in WD6 - Annex placed on hold
Annex E Figure E.4 General
Sy and Su are incorrect. Change labels Sy and Su to "elastic ideal plastic"
and "elastic plastic with material hardening"
respectively.Accepted
click on figure, go to chart tools, see "example pipe 3" on
Excel spreadsheet, and update columns AD and AJ - will
need to resize the chart and legend
will not be addressed in WD6 - Annex placed on hold
Annex F F Technical No mention of Flow Spool/Flow Head Added Flowhead Accepted Requirement is revised
Annex F F TechnicalNeed to clarify Subsea tree should this be SSTT? None
RejectedRequirement is clear
Annex I I.5.2.2.5 Technicalapproaching zero - lacks clarity Use acceptance standards per 6A & 17D
Acceptedleakage criteria is linked to annex 8 though I.5.3 (What
needs to be changed?? (Emailed Paul, 9/16)
Annex I I General
Must all test samples come from the actual
production string? For instance, if the connector
is machined from bar stock or forgings, could
the bar stock or forgings be used to perform the
external load testing, seal/ gasket testing, etc?
These samples would not include any welds
connecting the connection to the pipe body as
would be done in the production string, but
these samples would be able to be tested much
more easily. Having only test production order
samples to perform all of the testing would
mean that the production order would have to
to already been completed before testing could
even begin. This is not advantageous for the
manufacturer.
Allow the use of bar stock or forgings of the
same material, chemistry, grade, etc. into the
tests.
Rejected
Annex requirement is clear and consistent.
Annex I I General
If Annex I only covers qualification of connectors
(and welds between the connectors and pipe)
then there's no part of 17G which covers
qualification of the tubes.
Add some qualification of the tubes. Only reason
why this is brought up is because for drillpipe,
the mode of failure in fatigue testing most
oftenly occurs in the pipe rather than the
connection or weld
Rejected
Annex is clear and consistent. Tubular qualification is
addressed in Clause 6.24
Annex I I.1.2 GeneralDrillpipe, or rotary shouldered, connectors are
missing from the EXAMPLE
Add drillpipe or rotary shouldered connectors
into the EXAMPLERejected
Annex requirement is clear and consistent.
Annex I I.2.3.1 General
Manufacturer may not fully understand end
user’s full scope of performance and
simultaneous loading so end user must play a
bigger role in the testing/ load schedules. A
connector could go through several load cycles
before leaking could occur, so it's critical that
the end user specifies more specific loading
sequencing rather than the just the final loads.
End user must be held accountable in their
specification of loading conditions to the
manufacturer/ testing facility, because
depending on the sequence of loading (i.e.
pressure before tension or tension before
pressure) there could be different results.
Rejected
Annex requirement is clear and consistent.
Annex I I.2.3.1 General
Could seal/gasket testing and static load testing
be combined to have load, pressure,
temperature simultaneously? Also since the
riser string typically sees it's highest stress at the
top and bottom of the string, shouldn't these
two areas be highlighted within the load
schedule/ testing?
Combine the two test types for a load schedule
or test which combines bending, tension,
pressure, and temperature, because that's a
more accurate depiction of the actual loading
conditions of the string. For a reference of how
this load schedule/ test could look, see the load
schedule associated with ISO 13679 Cal III Series
A, B, or C. Although that specification is meant
only for casing and tubing, it could be modified
to accomodate all types of connectors.
Rejected
Annex requirement is intentional, clear and consistent.
Annex I I.2.3.1 General
Mimicking the load sequence during
qualification inherently asks the end user to
determine the loads for the manufacturer
because the manufacturer doesn’t know the
load sequence or intended use completely.
Need more end user input for load sequencing
and testingrejected
Annex requirement is clear and consistent. Reference
Annex D. Load sequence should be considered
Annex I I.2.3.2 General
Although Cal IV or III of ISO 13679 is used for
casing and tubing, the specification could maybe
be modified to test all connectors used within
the 17G.
ISO 13679 could be used as a baseline for a test
schedule instead of the seal/ gasket and static
load testsrejected
Annex requirement is intentional, clear and consistent.
13679 should be a reference
Annex I I.3.1 GeneralIndependent verification is required for what
parts?
The independent verification/ witnessing
statement is vague and needs to be more
specific
AcceptedWG will review and revise for clarity
Annex I I.3.2.2 Technical
Temperature range shall not exceed +/- 1.0% Maybe open up the percentage error for
temperature, because when using a
thermocouple, the two ends won't always be the
same distance apart when tacked into place on
the samples
Annex I I.3.3 Technical
Increase the scan rate for digital data systems Increase the scan rate from one every 15
seconds to at least one every 5 seconds. Big
changes in axial load and pressure can happen
very quickly so need a higher resolution on data
acquisition. Temperature can have lower
resolution but load, pressure, etc. needs higher
scan rate
Accepted
WD will review and clarify the Annex requirement
Annex I I.3.3 TechnicalChange pressure load rate Pressure load rate should be an actual pressure/
min. Ex. 15,000 psi/ min not stress rate increase AcceptedWD will review and clarify the Annex requirement
Annex I I.3.3 Technical
Each individual load type needs 5 mins to
gradually remove load or all loads combined
needs 5 mins?
Be more specific in unloading time
Accepted
WD will review and clarify the Annex requirement
Annex I I.3.3 Technical
Also, when the load needs to be removed over
the course of 5 minutes, what if the load is only
10 kips? That should take 5 minutes to remove
the load and so should removing a load of 2,000
kips.
Propose a max rate of removal in load
Accepted
WD will review and clarify the Annex requirement
Annex I I.3.4 General
It says that "for welded connectors strain gauges
shall be located at the girth weld…" What about
friction welds i.e. the welds on drillpipe risers?
Include friction welds and other types of welds
Accepted
WD will review and clarify the Annex requirement
Annex I I.3.4 TechnicalHow many gages and what type of gages at each
weld?
Specify number and types of gages at the weldsAccepted
WD will review and clarify the Annex requirement
Annex I I.3.6 TechnicalLoading sequencing could conflict with loading
explained in I.3.3
Use consistent loading sequencing throughout
Annex IAccepted
WD will review and clarify the Annex requirement
Annex I I.3.8 General
Says that the seal shall not be greased or
lubricated, what if the metal-to-metal seal is
part of the connection and always lubricated
with thread compound? What’s the difference
between greased, lubricated, and oiled? Oil is a
lubricant. What about thread compound?
Be more specific in the lubrication and areas of
lubrication. Metal to metal seals on casing and
rotary shouldered connections typically will
require thread compound in order to prevent
galling
Rejected
Annex requirement is clear and consistent
Annex I I.3.9 General
Need specifics as to what would be on the tick
off and sign off sheets. Who signs or ticks off on
procedure completion?
Provide an example sheet for tick off and sign off
boxes for individual procedures that requires
this verification. End user maybe should specify?
Annex I I.3.9 General
What’s considered “each step in the
procedure”? how specific?
Need more specifics on what's "each step" and
need a table provided in 17G. Each step to the
end user, manufacturer, and testing facility
could be considered different things. End user
maybe should specify?
Annex I I.4.3 TechnicalMinimum preload can't be +/- 5%. Inherently
incorrect
Correct to say minimum preload + %, can’t be
below minimum preloadAccepted
WD will review and clarify the Annex requirement
Annex I I-1 General
For make/break test, a) says that the connector
needs to demonstrate that it can be stabbed/
landed and made up in the field . This would
require the manufacturer or testing facility to
acquire field machines in order to determine
this criteria. Realistically, an Iron Roughneck or
power tongs will not be the machine used for
make and breaks at a testing facility. In order to
provided proper preload for a threaded
connector, the testing facility will probably use a
continuous turn or ratchet-style torque unit
Modify this purpose to include typical make and
break machines such as a continuous turn or
ratchet-style torque unit.
Accepted
WD will review and clarify the Annex requirement
Annex I I-1 Technical
For burst testing, typically the manufacturer
doesn't know if the connector can maintain a
pressure that's equal to or greater than the pipe
burst capacity without testing the connector.
Structurally it may stay together but the
manufacturer won't know if it would leak.
Make the burst testing required and test the
connector to 1.0 of the pipe burst capacity or to
a value that would be close to the pipe's burst
capacity. Inherently with this test, the connector
would have to be welded onto a stronger tube
or machined onto the end of bar stock or thick
walled tube that's of the same chemistry and
mechanical properties as the connector to be
used in the field
Accepted
WG to revise Table for clarity to include stabbed conditions
and wordng to include there be some verification of the
compressive force on the couplings
Annex I I.5.2.2.3 Editorial"The time specified for hold times shall be a
minimum." Not complete
Complete the sentenceAccepted
WD will review and clarify the Annex requirement
Annex I I.5.2.2.5 TechnicalWhat's the manufacturer's/ testing facility's
course of action if there's a leak during testing?
Need a contingency for if the sample leaks. Is the
test restarted or are changes required? AcceptedWD will review and clarify the Annex requirement
Annex I I.5.2.2.6 TechnicalWhat's the manufacturer's/ testing facility's
course of action if there's a leak during testing?
Need a contingency for if the sample leaks. Is the
test restarted or are changes required? AcceptedWD will review and clarify the Annex requirement
Annex I I.5.2.3 Technical
Check the Eq. 2 to ensure that it's correct. It
seems that the Rp,c and Rmax,test need to be
swopped. Also, throughout the spec, the letter
"p" has been used to denote pressure, why is it
"R" now? Confusing…
Check equation and change R to p
Accepted
WD will review and clarify the Annex requirement
Annex I I.5.2.5 GeneralWho specifies if testing will do the survival
fatigue testing or fatigue to failure testing?
Specify when survival and failure fatigue testing
are involved. When is one chosen over the
other? It's confusing
RejectedAnnex requirement is clear and consistent
Annex I I.5.2.5 General
Where does the M-N curve, or the calculated
fatigue capacity come from? Does it come from
the small scale testing mentioned in Annex C.6.2
NOTE 3?
Mention that the M-N curve can come from
small scale fatigue testing.Rejected
Annex requirement is clear and consistent
Annex I I.5.2.5 GeneralIs there only one acceptance criteria for survival
fatigue testing?
If so, then no need to letter a), but there should
be more than one acceptance criteria anyway
Annex I I.5.3 GeneralThe goal of each test isn't explicitly stated Each test needs a paragraph at the beginning of
its section providing a scope of why the testing is
being completed
RejectedAnnex requirement is clear and consistent
Annex I I.5.3.2 General
"Connectors shall be made-up using tools typical
of those in the field." That statement implies
that threaded connectors can only be made up
with iron roughnecks, power tongs, etc. These
types of tools are typically used in testing
facilities or by the manufacturer
Re-write the statement so that continuous turn
or ratchet-style torque units can be used to
perform make and breaks on these test samples
Accepted
WD will review and clarify the Annex requirement
Annex I I.5.3.2 General
Connection will be completely cleaned after
every break-out? Threaded connectors need to
have thread compound fully removed after each
break-out?
This doesn't necessarily happen in the field, so
no need to fully clean the surfaces of the
connection until that every 5th break-out for
photographs
Rejected
Annex requirement is clear and consistent
Annex I I.5.3.2 GeneralWho determines whether the connection needs
leak-tightness testing after every 5th break-out?
Specify who determines whether leak-tightness
testing is required after every 5th break-out RejectedAnnex requirement is clear and consistent
Annex I I.5.3.2 GeneralThe minimum make-break tests required for
temporary threaded connectors is 10. Does this
include threaded riser connectors?
Be more specific with the threaded connector
that's also a riser connector RejectedAnnex requirement is clear and consistent
Annex I I.5.3.3 General
If individual seals and then the complete seal
arrangement are to be tested, then if there are
2 seals that means there needs to be 3 tests? (1
test for the 1st seal, 1 test for the 2nd seal, and
a 3rd test for both seals) If so, for rotary
shouldered connections, the torque shoulder is
often considered a seal but it should not have a
pressure rating. For rotary shouldered
connections, should these shoulders be
bypassed to only test the seals that will have a
pressure rating?
Be more specific on the number of tests required
per the number of seals in the connection. Also,
be more specific on what constitutes as a seal
(aka a seal should have some sort of pressure
rating and that all other contacting surfaces
which may contain pressure but do not have a
pressure rating should be bypassed during
testing of the pressure rated seals)
Annex I I.5.3.3 General
Does it make a difference that the ISO 10423
Annex that's used for the seal/gasket test is an
Informative annex and not Normative?
Comment on the fact that it's an Informative
section, possiblyRejected
Annex requirement is clear and consistent
Annex I I.5.3.3 General
Is Seal/ Gasket Test only for installable metal-to-
metal seals or does it apply to metal-to-metal
seals that are machined into the connection i.e.
for casing and drillpipe connections?
Specify the type of metallic seals
Rejected
Annex requirement is clear and consistent
Annex I I.5.3.3 General
Do non-metallic seals that are only being used as
environmental seals (and are not meant to seal
against well fluids) still need to be tested to ISO
10423 F.1.13?
Specify that non-metallic seals which are not
meant to see or seal against well fluids only need
to be tested to ISO 10423 F.1.11 and not F.1.13Rejected
Annex requirement is clear and consistent
Annex I I.5.3.3 General
Without tension, compression, or bending
during this test, it does not seem to hold as
much merit as it could
Incorporate some tension, compression, or
benidng, because leaks might not occur until the
connection is under external load. Either modify
ISO 10423 F.1.11 or incorporate a some sort of
modified ISO 13679 Series C type load schedule
Rejected
Annex requirement is clear and consistent
Annex I I.5.3.4 Technical
The manufacturer doesn't know if the
connection can hold more pressure than the
pipe until the connection is tested.
Propose a change to weld/ machine the
connection onto a stronger pipe or bar in order
to test the connection to a pressure equal to 1.0
of the pipe burst pressure or to a high pressure
Accepted
WD will review and clarify the requirements in Table I-1
Annex I I.5.3.5 General
For the situation where the connector is
stronger than the pipe, in order to test the
connection, the connection would need to be
welded onto a pipe other than the pipe that
would be used for the actual riser string or it
would have to be machined onto the end of a
bar with sufficient bore back and turned down
OD but of the same chemistry as seen in the
production order. Does this mean that these
two methods would be the acceptable methods
for this test? In this case the actual pipe that
would be used in the string would not be tested
nor the weld
Specify methods in which the external load test
can be completed where the riser pipe and
possibly the weld connecting the riser to the
connection would not be tested. Additional
testing may come of this…
Rejected
Annex requirement is clear and consistent
Annex I I.5.3.5 General
The end user must specify if the load will be
tension or bending, because manufacturer does
not know the loading sequence that the
connection will see
Make it the end user's responsibility to specify
more detailed loads and load scheduleRejected
Annex requirement is clear and consistent
Annex I I.5.3.5 GeneralIt says that both tension and bending must be
performed, so no external load can’t just be one
or the other as previously stated
Fix the inconsistency between tension and/ or
bending to performed in the test RejectedAnnex requirement is clear and consistent
Annex I I.5.3.5 Technical
It says say that normal is 0.67Fd and extreme is
0.80Fd, but in 6.8.11.1 & 6.8.11.2 casing
connections and drillpipe connections both
specify normal is 0.50Ty and extreme is 0.60Ty.
Fix the design factor references due to the
specified design factors of casing and drillpipe
connections Accepted
Review for clarity against Clause 6
Annex I I.5.3.5 TechnicalWhat stress level is 0.10 fatigue damage
accrued? Low, medium, or high?
Specify which bending moment/ stress level to
be used for the fatigue damage prior to the load
testing
RejectedWG will review for clarity.
Annex I I.5.3.5 General
Is bending moment/ tension increased when the
pressure goes from Design pressure to Low
pressure during the Normal and Extreme cycles?
Specify what happens to the bending moment/
tension when pressure is decreased.Rejected
Annex requirement is clear and consistent. WG to consider
placing a NOTE for guidance.
Annex I I.5.3.5 General
Gow are temperature effects tested here? How
will the seals hold at higher temperatures? How
is the reduction in yield strength due to
temperature tested?
Basically, this load schedule needs to be more
thorough and extensive. Ex. See ISO 13679 Cal III
Series C for loading, cycling, temperature, etc.
for an example of an extensive load schedule. A
modified ISO 13679 load schedule could be a
good model going forward
Rejected
Annex requirement is clear and consistent
Annex I I.5.3.5 General
Where the test sequence explains to make-up
and perform hydrostatic pressure test, is that an
additional pressure test to I.5.3.1 or are they
one in the same?
Be more specific in the hydrostatic test in the
I.5.3.5 mentioned in the test sequenceRejected
Annex requirement is clear and consistent
Annex I I.5.3.5 General
f) needs better description. What is bending
moment 1? Where is bending moment 1 seen in
the load schedule see in Table I-2? Is the
bending moment capacity based on the
expected pipe failure point or is it based on the
connection failure point? “Cycle down to low
pressure and back?”
Reword and be more descriptive in the test
sequence of the I.5.3.5 test
Rejected
Annex requirement is clear and consistent
Annex I I.5.3.5 Technicalg) three additional cycles or a total of three
cycles?
Clarify the number of normal and extreme cycles
performed in the load scheduleRejected
Annex requirement is clear and consistent
Annex I I.5.3.5 Technicali) Fd does not equal 1.00 for drillpipe and casing
according to 6.8.11.1 & 6.8.11.2, it equals 0.75.
Fix the design factor references due to the
specified design factors of casing and drillpipe
connections
AcceptedReview for clarity against Clause 6 (design factors to be
deleted)
Annex I I.5.3.5 Technical j) 2-300psi Should say 200-300 psi Accepted WG to revise the requirement
Annex I I.5.3.6 Technical
Mean stress representative of the riser in
operation at what location? Who specifies the
mean stress and how it's applied? How does the
mean stress affect the expected fatigue life if
the M-N curve was based on samples that did
not have a mean stress during testing?
Need more description of where this mean
stress is in the riser string, who specifies the
mean stress, and how it will affect the fatigue
life, possibly Rejected
Clarification is provided in Annex C as stated in the
document
Annex I I.5.3.6 Technical
Are the fatigue to failure tests on small scale
samples as per the specs referenced in C.6.2
NOTE 3? If so, please reference. What if the
connection isn’t what fails in fatigue, but instead
the pipe? Ex. drillpipe typically has fatigue
failures in the pipe and not in the connector or
weld. Many joints from production would have
to be used to determine an M-N curve for the
failure location on the production pipe before
Annex I testing could even begin? It would also
be very expensive
Be more specific of how the M-N curve can be
generated using DNV-RP-C203 because that RP
references several methods. Reference small
scale testing to correlate back to stress
concentration at the expected fatigue failure
location in the string. Also, discuss what the
contingency is for riser strings where the fatigue
failure isn't expected to occur in the connection
or weld. Even though Annex I is "qualification of
connectors", this needs to be discussed
Rejected
WG will review for clarity referencing requirements in
Annex C
Annex I I.5.3.6 GeneralAre the fatigue to failure tests the same tests
reference in I.5.2.5?
Cite I.5.2.5 if soAccepted
WG to review and clarify
Annex I I.5.3.6 General
f) is the cyclic loading continued until 20% past
the expected fatigue life as mentioned in
I.5.2.5?
Cite I.5.2.5 if so
Accepted
WG to review and clarify
Annex I I.5.3.6 Technical
Don’t need internal pressure to determine that
there is a fatigue crack in the sample. If the
strain gages are location on the sample and they
are anywhere near the fatigue crack location,
the strain gages will show that a crack has
developed.
Specify that real-time strain gage data can help
determine if a fatigue crack has occurred
Rejected
Annex requirement is clear and consistent
Annex I I.5.3.6 Technical
What if the connection, weld, and pipe are
qualified one time via Annex I and then the
connection, weld, and pipe are needed for
another end user, location, etc. but the loading,
temperature, and pressure are not as severe as
the original qualification? Do the connection,
weld, and pipe need to be qualified with these
less extreme loading conditions? Because in that
case, could the connection, weld, and pipe
complete Annex I testing one time at its
absolute peak capability so then it will be
qualified for all loading conditions within the
peak capability envelope?
Specify if the connection, weld, pipe, material
grades, etc are all tested one time to a very high
stress level and pass the qualification testing,
that the string does not have to be requalified to
if the string will be used for a less severe
application
Rejected
Annex requirement is clear and consistent
Annex I I.2.2 General
The wording in the 'EXAMPLE' may be
interpreted as structural and fatigue testing
shall be performed to failure, whereas
alternatives to testing to failure exists.
Rephrase
Rejected
Example is offered as a NOTE only
Annex I I.5.2.1 General
Wording of last paragraph has come out wrong.
It states that the replacement interval can be
twice the tested endurance of the gasket,
should be half the tested endurance.
Rephrased to be in line with equation (1) in same
subsection:
"Gaskets and seal rings may be reused if agreed
upon with the end-user. The replacement
interval of gaskets and seal rings should not be
more than one half of the number of successful
make-break tests before any leakage occurs."
Accepted
WG to review and revise requirement
Annex I I.5.2.5 General
The definition of factor 'c' is impresise and
incomplete. The definition is a fragment not a
sentence "c is the factor (...)."
The factor represents the DNV SN curve
providing a 2 standard deviation probability of
survival.
Rephrase with reference to probability of
survival of reference SN curve.
Accepted
WG to review and revise requirement
Annex I I.5.5 GeneralSubsea replacement of seals should be included
as an alternative for batch completion. RejectedAnnex requirement is clear and consistent this is
qualification not operational
Annex I(I.5.9)
I.5.3.5General
Bullets a) through l) do not match Table I.2 Update bullets to reflect sequence in Table I.2Accepted
WG to review and revise requirement
Annex I I.5.9 General
It is specified that 100 cycles to verify loosening
should be used. A design factor for this is
already presented in Table 7. Testing should
allow the manufacturer to select number of
cycles provided the design factor in Table 7 is
adherred to.
Accepted
WG to review and revise requirement
Annex I I.5.2 Technical
Text is vague/unclear which specific tests are
associated with Annex K;
Current text: "SSTT latch testing shall comply
with the requirements in Annex K"
Add additional verbiage to clarify:
SSTT latch make/break testing shall comply with
the requirements in Annex K.
Rejected
Annex is clear and consistent
Annex J J.2.1 Editorial 17G is now a specification, not a proposal change proposal to specification
Annex J J.3.4.b Technical"after installation" needs a stipulation stating
this is only performed not to in danger well
operations.
after installation in a agreement with operations
risk assestment. RejectedRequirement is clear and consistent. Risk assessment is
covered in safety strategy
Annex J J.3.4 Technical
last paragraph in this section needs to be
removed or reworded because the operations
will not be on stand-by in an emergency
situation.
If a control station is not functional, then a risk
assestment with the operations shall be
conducted to identify contengency plans for
operations until the control station is operable
again.
Rejected
Requirement is clear and consistent. Language may be
modified to say "or required" within the requirement
Annex J J.5.2 Editorialfirst paragraph, reference to "subsection 11.3" I
could not locate. Check refernce numbers. acceptedComment in WD6 J.6.2 references now ok
Annex J J.1, Table General
There is no reference to the SSTT in the "Barrier
Implementation Table"
Suggestion to include SSTT and change the order
so that it reflects the order in which the barriers
would be placed in reality.
Rejected with
comment
Moved to WD6 Comments
See new proposed table J-1.
Annex J
Update crew drils and clarify the link with RP 96
, , controls performance to (Validation) to the
well control operaitons. … accepted
Moved to WD6 Comments
ray working with Tore on crew drills
Annex J J.1 Editorial
Recommend that we not use the term "leak"
unless we are talking about the ability to
physically observe some leakage. The term leak
test is frequently used, when we really mean a
pressure test and observe for a loos/gain in
pressure. Most of the time we are not "looking
for a leak."
First incidence is J.1 in the NOTE. Replace detect
leaks with verify integrity. This is also consistent
with the existing J.3.1
NOTE: Pressure testing is the periodic
application of pressure to verify integrity in a
well barrier, well barrier
element, or other objects that are designed to
confine pressurized fluids (i.e., liquid or gas). Rejected
Referenced comment is not a requirement.
Annex J J.2.1 Editorial
3rd paragraph. Reword last half of the sentence
for clarity. We should have no unacceptable
risks. Not say that we'll manage unacceptable
risks.
These systems shall be installed, maintained,
tested, and operated in a manner that ensures
safe well control
during well operations and to ensure there are
no unacceptable risks to personnel health and
safety and the environment.
Accepted
WG to revise and clarify the requirement
Annex J J.2.1 EditorialFourth paragraph, last sentence. Include "and
tested/verified" in addition to just identifiying
the barriers.
All barriers shall be identified and tested/verified
before commencing any well operation... AcceptedWG to revise and clarify the requirement
Annex J J.2.2.2 Technical
First paragraph after (b). Next to last sentence.
Not sure I understand, and therefore not sure I
agree, that the fluid barrier "cannot be included
in the list of testable barriers once well
intervention operations commence."
Fluid barriers are classic example of "inflow
tested." The well is continuosly monitored to
ensure it is not taking, or giving up, fluid. And
periodically, we do a "flow check" which is really
an "inlfow test" to ensure the hole stands full
and static.
Especially if you are running a system like Fig 3-
1, without a SSTT, fluid is the primary barrier.
Delete:
"...and cannot be included in the list of testable
barriers once well intervention operations
commence."
Accepted
WG to review and clarify the requirement.
Annex J J.2.2.3 Editorial
Second Paragraph. I don't think it is a "shall"
statement to have barrier schmatics. The
information can be convey satisfactorially with a
table. The schmatic are a big help, but are not
required to the level of "shall." Suggest using
should.
Suggest replacing shall with should.
"Well intervention barrier schematics should be
developed as a practical method…"Rejected
the requirement is clear and consistent
Annex J Table J-2 EditorialLet's not use the term BOP when talking about
"WL BOP" as for the next to last entry in the
table.
Change WL BOP to WL PCE. PCE is Pressure
Control Equipment and is more representative of
the equipment than BOP.
acceptedComment draft was sent out without change will amend
for final.
Annex J J.3.2 Editorial
As mentioned above, lets not use the term
"leak" unless looking for a leak.
(d) change leak to pressure:
" d) reasons for the performance of pressure
testing shall be in accordance with Annex J.3.5."
(g) delete word leak:
"acceptance criteria shall be in accordance with
Table J-3."
Accepted
WG to review and clarify requiremnt
Annex J J.3.2 General
The word "leakage" is accurate in paragraph 4
because we are looking for a leak as stated in
the last sentence.
I will recommend to use the term "deviation" for
table J-3 for consistency.
Add "or deviation":
"...provided that no detectable leakage or
deviation occurs during the specified pressure
hold periods of the test."
Rejected
The requirement is clear and consistent
Annex J J.3.2 EditorialBullet e) add specified by manufacturer "Typical cleanliness levels are SAE AS4059, Class
6B-F through Class 8B-F, but shall be specified by
the manufacturer."
AcceptedWG to review and clarify requirement
Annex J J.3.4 GeneralBullet d). I don't understand why we include
"and interventions" here.
delete "and interventions" and just say after
repairsAccepted
WG to review and clarify requirement
Annex J J.3>5 General
Title says :Pressure Testing," but first sentence
says, "Leak testing…"
In this case, we are, indeed, describing
PRESSURE testing. As mentioned above, let's
not call a pressure test a leak test.
Change first word of first sentence from "Leak"
to Pressure.
Pressure testing of well barriers or well barrier
elements shall be performed.
Accepted
WG to review and clarify requirement
Annex J J.3.5 Technical
Include "General Testing Considerations"
consistent with API 53, section 6.5.3.8
API 53 6.5.3.8 has 9 subparts. Recommend to
simply copy and past 6.5.3.8.1 - 6.5.3.8.6. These
are safety related topics for high pressure
testing.
Rejected
The requirement is clear and consistent. The WG will
review for revision.
Annex J J.3.5.1 Technical
Since I suggest eliminating J.3.5.1.1 (belwo),
then we should upgrade last sentence in
J.3.5.3.1
or by
:…both flow directions. If well control can be
maintained in the event of test failure of the
barrier being tested, then an inflow test or
negative pressure test may be considered.
Accepted
WG to review and clarify requirement
Annex J J.3.5.1.1 Technical
I'd recommend that the document not suggest
that the hydrostatic barrier is "disabled" in order
to test another barrier. I suggest we remove
this section and just go with the definition given
in J.3.5.1
Delete J.3.5.1.1 and just go with J.3.5.1 only
Accepted
WG to review and clarify requirement
Annex J J.3.5.2 Editorial
Confusing leak test and pressure test. Suggest first sentence read:
"The high-pressure test shall as a minimum…"
And the last sentence read:
"During high-pressure testing, the test pressure
value…"
Accepted
WG to review and clarify
Annex J J.3.5.3 Editorial
Table J-3 uses a good term (deviation). Let's be
consistent and use it instead of leak in the text.
The first paragraph recommends a way to
identify physical leaks, so that is fine. But the
main purpose (as stated in the title to the
section) is PRESSURE test criteria.
First 2 sentences should read:
"The pressure test shall be conducted such that
pressure acceptance can be veried according to
Table J-3 and leaks can be identified. An
acceptable test shall be "no
detectable leak observed and no detectable
pressure deviation, unless specified otherwise."
Rejected
WG to review and clarify to ensure consistency throughout
the document
Annex J J.3.5.3 Editorial
Sentence before table J-3 should be consistent
with the section title and not use "leak."
Sentences should read:
Pressure test acceptance criteria shall be in
accordance with Annex J.3 or in accordance with
national regulations.
Test pressure and test frequency shall be in
accordance with Table J-4.
Accepted
WG to review and clarify
Annex J J-3 EditorialTitle should no read Leak Pressure, only
pressure
Chagne title to:
"Pressure Test Acceptance Criteria"Accepted
WG to review and clarify
Annex J J-3 Editorial
Column 4 (Test Acceptance Criteria) should use
the term "deviation" as described in the
superscripts at the end of the table, not
"leakage."
Note that none of the guidance given at the end
of the table (superscripts) has any description of
what to look for as "leakage." This is fine. We
are doing a "Pressure Integrity Test" and the
parameters are give for such a test.
Change column 4 to read:
"No detectable deviation.
Rejected
Requirement is clear and consistent
Annex J J-3 Technical
Not sure I understand what all the references
are to these "inflow tests."
We have "small volumes" and "large volumes"
but use exactly the same text in columns 2 - 4?
If we are doing an inflow (or negative pressure)
test, then superscript 'c' about a "decreasing
trend" is completely wrong.
In addition, to suggest we only take 150 psi off
the SIWHP as sufficient contradicts the very first
statement of Clause J.3 "to pressure test to the
expected differential pressure in the
direction of flow..."
Just have one entry in column 1 for Inflow /
Negative Pressure Test. Column 2 is "Installed
barrier elements." Column 3 is " Test pressure
shall be to the expected differential pressure in
the direction of flow, or to a differential pressure
as near as practically attainable." With
superscript d. Time is 30 minutes minimum.
Column 4 is "No flow or no pressure buildup"
with superscript c.
Accepted
WG to review and clarify the requirement and table J.3
Annex J J-3 Editorial
Remove reference to Straddle. No need to treat
a single equipment with a specific reference.
Remove the next to last 2 rows about
a"straddle." Accepted
WG to review and clarify the requirement and table J.3
Annex J J-3 Editorial
Remove reference to row for "Inflow test for
final well handover." This is obvious that those
tests are to be done "according to requirements
for wells in operation." Let API 17G focus on the
"temporary equipment" used during the
intervention. Some other guidelines should
cover the permenent equipment left on the
well.
Remove the last row about "final well
handover."
Rejected
Agreed that this may be outside the scope - however WG
considers it to be needed for completeness and clarity.
Annex J J.3.5.1.1 Technical
As a result of my previous comments, I suggest
putting J.3.5.1.1 back in with the title changed to
"Inflow Testing and Negative Pressure Testing"
The guidelines listed below are intended to
provide guidance for the user to develop
detailed procedures for the barrier to be tested.
Inflow and negative test procedures will vary
depending on the barrier being tested and
wellbore conditions. Appropriate risk
assessment shall be completed before finalizing
the test procedure.
Rejected
WG to revise and clarify the requirement
Annex J J-4 Editorial
Clean up some text in the "comments box" at
the end of the table.
Replace leak with pressure. The 3rd sentence
should read:
"...the initial pressure test of the BOP
components…"
The last sentence should use the same language
as previous table:
"In general, test acceptance criteria are "no
detectable deviation...".
accepted
Completed
Annex J J.2.2.2
Well barrier element design, selection, and
construction principles
f) its physical location and integrity status of the
well barrier element is known at all times when
such monitoring
is possible.
Section states "shear any tool that penetrates
the well barrier and seal the wellbore after
having sheared the tool"
This statement is missleading as it implies that a
CWOR system should be of shearing through a
tool which is not possible.
Please revise the statement to distinguish
between BOP and open water systems
Accepted
WG to review and clarify
Annex J J.3.2
Pre-deployment deck test Clarify that para 5, e) refers to the control fluid.
Pervious points discuss procdution bore fluid
which may lead to confusion.
Proposed change - Revise statement as follows:
"Fluid cleanliness checks of control fluid shall be
conducted after adding fluid and at function test
times. Typical cleanliness levels are SAE AS4059,
Class 6B-F through Class 8B-F."
Accepted
WG to revise and clarify the requirement
Annex J J.3.4 Functional testing of well barriers Add additional bullet:
f) as required by the Safety Stragety, 4.13Rejected
WG to revise and clarify the requirement
Annex J J.5.1 Scope Please clarify who the 'responsible party' is Accepted WG to revise and clarify the requirement.
Annex K K Editorial Cross refence in annek K are incorrect Review and revise cross references Accepted All references corrected in redline
Annex K K.1 General
Introduction provides scope of testing covered
in Annex K (i.e. FAT and Qualification) and makes
reference to Subsection 8.9 for SIT. Suggest that
references to applicable sections for in-field
maintenance (10.5) and in-service barrier testing
(Annex J) requirements would be appropriate
here.
After "NOTE System Integration Testing (SIT) is
covered by Subsection 8.9" add further:
"NOTE Field Redress testing is covered by
Subsection 10.5"
and...
"NOTE Operational Testing Requirements are
covered by Annex J"
Accepted
Added to redline
Annex K K.2.5.1 Technical
In table K-1 distinction between requirements
for Safety Function Class and Normal Operation
Class is unclear and/or contradictory
e.g. Size - Section K.2.5.3 says scaling is allowed
for Normal Class but not for Safety Class - table
K-1 states the reverse. Columns appear to be
reversed
Review Table K-1 and reverse contents of Safety
Function and Normal Operation class columns to
be consistent with subsequent sections
referenced therein.
Accepted
Noted in redline
Annex K K.2.5.1 Technical
Table L. 1— Scaling rules for well control devices
Scaling rules mixed up for Normal and Safety
operation class?
Review and revise Table K-1
Accepted
Noted in redline
Annex K K.2.6.1 Technical
Table K-2: Rules for the effects of design change
for SSTTA
Design change rules mixed up for Normal and
Safety operation class? Incorrect references.
Review and revise Table K-2
Accepted
Noted in redline
Annex K K.3.3.2 Technical
Drift test procedure does not permit horizontal
orientation of valves being drifted. For longer
assemblies this may be impractical and limited
by available test facilities.
Change 3.3.2.a) to "Open the valve;"
Change 3.3.2.c) to "The drift shall pass freely
while being passed through the valve in both
directions;"
Rejected
Horizontal drifting requires pusher poles and does not
adequately mimic field conditions. Test facilities for
FAT/qualification should be able to suspend tools in
upright position.
Annex K K.3.3.4 Technical
K.3.3.4.c) implies that it is permissible to apply
close assist pressure during the seat test, at the
manufacturer's discretion. This is contrary to
Section 5 where, for example, 5.8.f) requires
that SSTT valves shall contain pressure from
below without the application of close assist
pressure.
Append K.3.3.4.c) with "NOTE Close assist
pressure may not be applied for upstream seat
tests of valves which are required to contain well
bore pressure without the application of control
line pressure, ref. Subsection 5"
Accepted
Point noted in redline to clarify that this only applies to
valves/directions designated as requiring close-assist
pressure (ie valves which are not used to comply with
section 5.8f)
Annex K K.3.3.5 Technical
K.3.3.5.e) does not prohibit the application of
close assist pressure during seat test on valves
which have a requirement to contain well bore
pressure from below without the application of
close assist pressure.
Append K.3.3.5.e) with "NOTE Close assist
pressure may not be applied for upstream seat
tests of valves which are required to contain well
bore pressure without the application of control
line pressure, ref. Subsection 5"
Accepted
Note added to start of procedure in redline
Annex K K.3.4 Technical
"The SSTT shall be tested with the valve bore
vertically disposed..." does not permit testing in
horizontal orientation. For longer assemblies
this may be impractical and limited by available
test facilities.
Delete K.3.4 paragraph 4
Rejected
Test facilities for FAT/qualification should be able to
suspend tools in upright position. Procedure does not
specify full SSTTA must be tested as one piece, so the
lengths involved are not unreasonable.
Annex K K.3.5.5 Technical
Pressure drop (the lesser of: 5% of test pressure
per hour or 500psi) is stated as an acceptance
criteria for the test. With gas as test medium,
this allows for significant volumetric leakage
within allowable pressure drop.
Table K-3 does not apply to non-room
temperature tests.
Throughout steps reference is made to ""if
leakage rate is greater than acceptance criteria
stated above" but it is not clear what this refers
to.
Likewise, it is stated "if body joint leakage is
detected... the test fails" however with gas as
test medium during a controlled temperature
test it is not practical to monitor for body joint
leakage within environmental chamber.
Clarify whether there are volumetric as well as
pressure based acceptance criteria for controlled
temperature test when gas is the test medium.
Rejected
Table K-3 title has been updated in redline to remove
"room temperature"
Due to difficulty achieving perfectly stable temperature in
large assemblies, and difficulty performing bubble
detection in environmental chambers, the pressure change
criteria for high/low testing are intentionally looser than
room temperature testing.
Likewise for post-shear testing -- the 5% pressure drop per
hour figure is deliberately permissive. The volumetric
leakage criteria of 30 cm3 per inch of valve bore is
mentioned elsewhere in Annex K.
Annex K K.3.5.9 Technical
K.3.5.9.c) it may be impractical to submerge a
valve which has been cooled to very low
temperatures without either freezing the liquid
in the test bath or transferring heat from the
valve assembly to the cooled fluid in the bath
and thus lowering the test temperature. I am
not aware of any test facilities with this
capability.
In K.3.5.9.c) remove: "submerge the valve in a
liquid bath such that detection of gas leakage
from body joints is possible."
Rejected
The design temperature range for SSTTs generally does
not extend below 32F, so an ice bath is suitable for this
purpose. Chilled glycol is available as an alternative for
extending the temperature range if desired.
Annex K K.3.5.11 General
Acceptance criteria are given for gas testing pre-
and post-cutting, however criterion for post-
cutting is pressure based. Should there be a
volumetric criterion also?
Note, point 2) contains "hydrostatic"
erroneously.
Consider inclusion of a volumetric acceptance
criterion for post-cutting tests.
Reword K.3.5.11.2) to remove "hydrostatic". Accepted
Replaced pressure-based criteria with volumetric criteria,
as agreed in 17G sub-committee workshop session
Annex K K.3.5.11 General
What are acceptance criteria for gas leakage
after cutting?
"Acceptance criteria across the cutting device
for gas testing pre- and post-cutting tests are:
1. Pre-Cutting: The equipment shall show no
visible leakage under the test pressure during
the 15-minute
holding period.
2. Post-Cutting: The hydrostatic shall be
acceptable if the pressure change observed on
the pressure
measuring device is less than 5% of the test
pressure or 3,45 MPa (500 psi), whichever is less
during
15-minute pressure-hold period."
Speciy acceptance criteria
Accepted
Replaced pressure-based criteria with volumetric criteria,
as agreed in 17G sub-committee workshop session
Annex K K.3.11 GeneralCutting test record
gas test missing?
Inlcude requirement for gas test recordAccepted
Replaced "liquid" with "gas" in redline
Annex K K3.5.10 TechnicalThese requirements latch/coupler debris testign
should also appy to the THRT / TH inerface
Change scope of section to include both SSTTA
Latch and THRT / TH RejectedTHRT/TH interface is out of scope for 17G. This would fall
under 6A
Annex K K3.5.17 Editorial 2nd paragraph, …well control devise.. change devise to device Accepted Noted in redline
Annex K K3.6b1 TechnicalRetainer valve is part of SSTTA, not SSTT per 17G change SSTT retainer valve to SSTTA retainer
valveAccepted
Noted in redline
Annex K K.2 Editorialmultiple areas of the text do not reference the
correct table. For example, in section K.2.2 Table
8 I could not find.
AcceptedReferenced corrected in redline
Annex K K.2.2.5 Editorial...the safety strategy for the system… reference
to Subsection 4.12 is for safety principle
...the safety principle for the system…Rejected
Reference to 4.12 was incorrect, should have been 4.13
Annex K K-1 Editorial
Is this figure an example or is it manditory
program which has to follow the order exactly?
After Latch & Coupling Test - do you have to
redress?
Rejected
No change specified in comment. The order is planned to
mimic representative field service conditions.
Annex K K.3.3.1 GeneralNeed to add statement that all testing are
performed in ambient temperature (60F - 90F) Rejected"ambient temperature" is to be defined by design load
cases, per section 6
Annex K
K.3.3.3,
K.3.3.4.e,
K3.3.5.d
Technicalneed to spell out how long do you monitor for
leakage.
montior for leakage for 5 minutes.Rejected
No section specified; can't tell what this is in reference to
Annex K K.3.5.4 Technical
5th paragraph of CFD analysis needs to be a
recommendation instead of a "shall" statement
because you call for a physical test to be
performed.
CFD modelling is only as good as the model
assumptions are because too many variables are
present.
A computational fluid dynamics (CFD) analysis
should be performed as a screening tool to assist
with optimization of the design and parameters.
Rejected
Intent is to use physical testing to validate/calibrate the
CFD model. Then the CFD model is used to extrapolate
physical test conditions outside the range of the test
facilities. This is required.
Annex KK.3.5.4
letter Editorial
Letter bullets references to Annexes and tables
are missing references.Accepted
References corrected in redline
Annex K
K.3.5.5.b,K.
3.5.5.d,K.3.
5.5.g,K.3.5.
Technicalneed to spell out how long do you monitor for
leakage.
montior for leakage for 5 minutes.Rejected
No section specified; can't tell what this is in reference to
Annex KK.3.5.9.c,K.
3.5.9.gTechnical
need to spell out how long do you monitor for
leakage.
monitor for leakage for 5 minutes.Rejected
No section specified; can't tell what this is in reference to
Annex K K Technical
Create an Equivilant to Table L.6 within Annex K
which shows the overall composition of tests to
conduct.
Rejected - SSTT
valves have
less diversity
than EDP/LRP
rams and all
have similar
requirements
Moved to WD6 Comments
Ask group? May want to break out cutter modules as
separate from valves
Minimal value added by table for SSTTs
Annex KK,1,5.xx/
ALLTechnical
Check Sand Testing Valve cycles between K & L
to insure valve cycle counts are same. (see
L.3.4.2.2)
correct for entire document
Accepted
check sand testing valve cycles on Annex L and update K
. Cycle counts do not match Annex L.
Corrected to match cycle counts to L.
Annex KAnnex K/
ALLGeneral
reveiw entire annex to remove mention of
applying pressure upstream or down stream of a
valve. Annex is for valves with different primary
seal directions, ie RV only function is to seal
from 'above', where pressure would be applied
from the 'downstream' direction. according to
this annex it would only be tested from the
'upstream' direction.
Replace 'upstream' with 'primary sealling
direction' and 'downstream' with 'secondary seal
direction'
Accepted.
Test
procedures
are often
ambiguous.
Moved to WD6 Comments
Technical writer to work with Paul/Ray to clarify intent of
each instance of upstream/downstream. Possible alternate
method would be uniform "above" or "below" relative to
operating position. EG retainer primary sealing direction is
"from above". What is the primary direction for a
lubricator? Pump-through behavior may complicate things.
Accepted to Change throughout doc and add to
definitions
Added notes that "upstream" refers to primary sealing
direction.
Annex KK.1.5.4 4th
paragraphTechnical
Direct hydraulic control to modest depths of
3000 ft may increase closing times to 30+
seconds. Test facilities may not be able to flow
at these rates that long. Closing a valve on clean
nitrogen in 3 seconds or 30 seconds has little
variance in valve performance.
Delete use of any orifice or state 3, 5 or 10
seconds closing time so test facility has sufficed
flow capacity. Accepted
Moved to WD6 Comments
Orifice plate references not included in latest draft
Annex KK.1.5.6 (l) &
(q)Technical
Failsafe close; Pressure to close & exhaust
pressure should mimic intended control system
design.
Add language to suitRejected -
control system
behavior is not
included in
sand slurry
testing
Moved to WD6 Comments
Purpose of test per WD5 section K.3.6.7 para 2 is to
demonstrate the ability of the valve to "open, close and
seal" -- timed performance with specific control system is
not necessary for qualification.
Referenced section does not exist in latest draft
Annex K K.3.2.3 Technical
Gas Testing text needs to be modified similar to
L.3.2.3
Zero gas leakage when new (FAT), with some
leakage tolerance after debris testing (akin to
API 6A Annex L)Rejected -
necessary info
is captured in
test
procedures
Moved to WD6 Comments
Phrase "unless otherwise noted" and test procedure
instructions capture testing requirement.
Gas test criteria have been clarified in latest draft redline
Annex KAnnex K/
ALLGeneral
reveiw entire annex to remove mention of
applying pressure upstream or down stream of a
valve. Annex is for valves with different primary
seal directions, ie RV only function is to seal
from 'above', where pressure would be applied
from the 'downstream' direction. according to
this annex it would only be tested from the
'upstream' direction.
Replace 'upstream' with 'primary sealling
direction' and 'downstream' with 'secondary seal
direction'
Accepted.
Test
procedures
are often
ambiguous.
Moved to WD6 Comments
Technical writer to work with Paul/Ray to clarify intent of
each instance of upstream/downstream. Possible alternate
method would be uniform "above" or "below" relative to
operating position. EG retainer primary sealing direction is
"from above". What is the primary direction for a
lubricator? Pump-through behavior may complicate things.
Accepted to Change throughout doc and add to
definitions
Notes made to clarify upstream/downstream
Annex K K.3.5 Technical
Figure K.7 requires overhaul to be relevant to
SSTTs (currently copy/paste from Annex L)
References to gate valves and actuator stems
should be struck and replaced with terms
appropriate to ball valves and flapper valves.Accepted
Moved to WD6 Comments
Joe to redo table. Need to define "no detectable leakage"
in main document definitions
Table wording fixed in redline
Annex K K Technical
Create an Equivilant to Table L.6 within Annex K
which shows the overall composition of tests to
conduct.
Rejected - SSTT
valves have
less diversity
than EDP/LRP
rams and all
have similar
requirements
Ask group? May want to break out cutter modules as
separate from valves
Duplicate with above
Annex K K.3.5.4 Editorial
10 seconds is not a resonable closure time and is
not consistent with API STD 53.
Use 30 seconds closure time to be consistent
with RP 53. The sentence after bullet 3 should
read:
"Unless specified otherwise, the maximum
closure time for a single well control device shall
not exceed
30 seconds."
Rejected
SSTT closure sequence timing is specified by end-user in
safety strategy. This has been noted throughout Annex K.
SSTTs must often complete primary well control function
(eg shearing) prior to execution of BOP shear ram closure,
and utilize much smaller operator piston volumes, so the
shorter closure time requirement is appropriate.
Annex K Title Editorial
The title of Annex K is misleading. It needs to
include a verb “Testing” as used in Annex L
Annex K
(normative)
Testing of subsea test tree assemblies and
associated accessories
Accepted
Submitted by Tony on 11/5 - Sent to Tech Writer on 11/5
(RC)
Annex K K.3.5.10 Technical
Need to change verbiage in NOTE, points at
section in Annex I that does not exist.
Correct to be more prescriptive on what tests
within Annex I should be performed.
Change "as-follows";
NOTE: The latch also comes under the
classification “connector” and therefore the
general philosophy of this document shall be
applied with regards to design by analysis (Annex
D) and verify by test (Annex I) for this type of
component. See Annex I for seal/gasket test,
static load test, and cyclic load test.
Accepted
Added to redline in markup
Annex L L.1 General
What is required design "validation" and how to
establish? Verification is OK when the
requirement are known.
Refer to clauses for relevant required design
validation. Also provide a guidance if the given
requirements are not sufficent for suitability for
intended use. Accepted
New definitions for equipment and system verification and
validation will included in the 6th WD. It is not possible to
provide a prescriptive list of validation criteria for all
equipment. A verification and validation basis shall be
established in accordance with clause 4.20. Tables in
Clause L.3.6 and L.3.5 give guidance on verification and
validation for EFAT and SIT.
Annex L L.2.2.1 Editorial Table reference in line 1 incorrect. Change to "Table 6-4" Accepted Already updated in API 17G WD5.2
Annex L L.2.2.2 Editorial Spelling error in line 3 "devises" Change to "devices" Accepted Marked up in API 17G WD5.2
Annex L L.2.2.2 Editorial
Paragraph following Table L-1 not required "For
open-water intervention systems, the
temperature ratings for valve and ram actuators
and non-metallic
sealing materials for ram elements are given in
Annex L.2.2.2."
Delete paragraph
Accepted
Already updated in API 17G WD5.2
Annex L L.2.2.3 Editorialcorrect table reference to 5-1 Nominal bore size and drift class of well control
devices should be selected from Table 5-1 or as
specified by the end user.
AcceptedAlready updated in API 17G WD5.2
Annex L L.3.2.3 Technical
2nd paragraph is in conflct with Table L-4.
States acceptable if no sustained bubbles are
observed, while Table lists "No detectable
leakage".
Refer to API 6A, Annex F.1.6.3 and Table F.1.
Explicity define alowable leakage rates.
Accepted
2nd para to be replaced with ""Gas leakage acceptance
criteria for gas pressure testing at room temperature,
during and on completion of each stage of qualification
testing shall be in accordance with Table L-4." and Table L-
4 shall refrence Clause 8.3.2.3 for accptance criteria.
Annex L L.2.2.3 Editorial Incorrect table reference Change to table 5-1 Accepted Already updated in API 17G WD5.2
Annex L L.2.2.5 EditorialIncorrect Section reference in second last
paragraph
Change from Subsection 4.12 to Subsection 4.13Accepted
Marked up in API 17G WD5.2
Annex L L.2.2.5 Editorial Incorrect Annex reference in last paragraph Change from M.1.2.30 to M.1.2.16 Accepted Marked up in API 17G WD5.2
Annex L L.2.2.7 Editorial
Final list split into "a)" & "b)", should be one
statement "a)"
a) shearing valves or rams in the production bore
of the WCP that allows for running of work-
strings and multiple strings of wireline and coiled
tubing.
Accepted
Marked up in API 17G WD5.2
Annex L L.2.2.7 Technical
Shear valves for annulus access should be
adresses separatly. This is often forgotten in the
industry.
Set requirment for cut and seal. Space-out for
working string should be taken into account. Accepted
Space out is not with the scope og Annex L. This is an
opetational and WCP functional requirement. Item be as
been modfied with "any bore (e.g. annulus and
production)"
Annex L L.2.5.1 Technical
Table L-2 for fluid class normal operating
reference is made to L.2.5.6. This claus is missing
Include clause L.2.5.6
Accepted
Marked up in API 17G WD5.2L.2.4.6
The standard test fluid rating validated by the test product,
shall validate all products of the same product family and
material properties as the test product in accordance with
API 6A:2011 F.1.14.3.4
Annex L L.3.1 EditorialIncorrect subsection referenced in paragraph 1 Change from 4.19 to 4.20
AcceptedMarked up in API 17G WD5.2
Annex L L.3.1 TechnicalRetainer valve is often used as a lubcricator
valve. Dropped object testing should be
required.
Include dropped object test in Figure L-1.Accepted
Annex L L.3.2 TechnicalLeak direction requirments should be defined. Include a table of valves and rams where main
direction of sealing is shown. Some valves have
to seal from above.
RejectedUnidirectional and bidirectional sealing requirements are
specified in te detailed FAT and qualification procedures
Annex L L.3.2.1 EditorialIncorrect subsection referenced in paragraph 1 Change from 8.3.1.1 to 8.3.2.1
AcceptedAlready updated in API 17G WD5.2
Annex L L.3.2.2 EditorialIncorrect subsection referenced in paragraph 1 Change from 8.3.1.2 to 8.3.2.2
AcceptedAlready updated in API 17G WD5.2
Annex L L.3.2.3 EditorialIncorrect subsection referenced in paragraph 1 Change from 8.3.1.3 to 8.3.2.3
AcceptedAlready updated in API 17G WD5.2
Annex L L.3.3.1 Editorial Spelling error in sentence 1 of paragraph 3 Change from assemble to assembled Accepted Marked up in API 17G WD5.2
Annex L L.3.3.2 EditorialIncorrect subsection number Change K.1.1.1 to L.3.3.2.10 and update all later
subsection numbers and references accordingly AcceptedAlready updated in API 17G WD5.2
Annex L L.3.3.2.1 Editorial
Table L-5 has missing references Add references as follows:
Actuator operational test: L.3.3.2.17
Hydraulic circuit pressure test: L.3.3.2.18
Actuator Seal Test: L.3.3.2.16
Hydraulic actuator compensation circuit test:
L.3.3.2.19
Accepted
Marked up in API 17G WD5.2
Annex L L.3.3.2.1 EditorialTable L-5 has missing row Add row for "Actuator hydrostatic body test"
and apply subsection requirements to every
column as L.3.3.2.15
RejectedCross reference is included in Actuator colum
Annex L L.3.3.2.2 EditorialIncorrect subsection referenced in paragraph 1 Change from 5.3 to 5.2
AcceptedMarked up in API 17G WD5.2
Annex L L.3.3.2.6 Editorial Erroneous character (square) in "a), 10" Delete character Accepted Marked up in API 17G WD5.2
Annex L L.3.3.2.9 Editorial Erroneous character (square) in "a), 8" Delete character Accepted Marked up in API 17G WD5.2
Annex L L.3.4.1 Editorial Paragraph 2, ref missing Change to "Annex L" Accepted Marked up in API 17G WD5.2, Annex L.3.4
Annex L L.3.4.1 EditorialFigure numbering incorrect Correct numbering (numbering needs continued
from previous figures)Accepted
Marked up in API 17G WD5.2
Annex L L.3.4.1 EditorialSpelling error in paragraph prior to Table L-6 Change "manufacture" to "manufacturer"
AcceptedMarked up in API 17G WD5.2
Annex L L.3.4.1 EditorialIncorrect subsection reference in table L-6 for
sand slurry testing
In every row for sand slurry, replace L.3.4.6.3
with L.3.4.6.4Accepted
Marked up in API 17G WD5.2
Annex L L.3.4.1 EditorialError in "Figure L-2 Sand Class II and Class III
qualification tests"
Change in "Sand Service Class III Test" flow
diagram wording in first process box from "As
class III test" to "As class II test"
AcceptedNow Figure L-7
Annex L L.3.4.6.1 EditorialTable L-7: Requirements for "Low-pressure seat
test at minimum rated temperature" are
inconsistent with rest of table
delete " at mimimum rated temperature" Marked up in API 17G WD5.2
Annex L L.3.4.6.1 EditorialTable L-7: Subsection reference in "c" at end of
table incorrect
Change from "F.2.2.2.1" to "F.2.2.2.2.1"Accepted
Marked up in API 17G WD5.2
Annex L L.3.4.6.1 EditorialTable L-7: notes at end, lettered list should not
have "d". Content is subset of "c".
Delete lettering "d" whilst retaining content and
format accordinglyAccepted
Marked up in API 17G WD5.2
Annex L L.3.4.6.5 EditorialProcedure step "v)" has incorrect sub-section
reference
Change "L.3.3.2.8" to "L.3.3.2.9"Accepted
Marked up in API 17G WD5.2
Annex L L.3.4.6.6 EditorialProcedure step "v)" has incorrect sub-section
reference
Change "L.3.3.2.8" to "L.3.3.2.9"Accepted
Marked up in API 17G WD5.2
Annex L L.3.4.6.8 Technical
Understand the rationale stated in this section
but the number of cycles seems excessive and
seems to assume no redress/repair within the
certification period. Can the increased
endurance hours be achieved in practice, i.e. is
this practical?
There is no clear instruction on which endurance
cycling is the requirement, with or without
safety factor. The alternative proposal is to
make the non-factored values the standard
minimum value for endurance cycling and to
make the safety-factored values optional. The
rationale for this is that the non-factored values
represent an improvement over 17D therefore
providing a greater level of confidence than
existing values without being overly onerous. It
should be up to the manufacturer or enduser to
decide if the safety factored approach is
necessary, we do agree with having an approach
identified in the standard for this but it should
be clear that this is optional.
Accepted
Safety factor and reference to API 17N has been removed.
Annex L L.3.4.6.8 Technical
Table 25. Normative requirement to life time
(endurance) is not pratical as life time relaibility
modesl are not well estblished and API 17 N
Annex D is an over simplification
Annex L to specify the minimum number of
cycles for temporary applications. Actual life will
depend on the inspection/redress frequency.
Actual cycles should be monitored and
compared with qualification cycles to provide
input for inspection planning.
Accepted
Safety factor and reference to API 17N has been removed.
Annex L Table L-10 TechnicalNumber of cycles required for Pipe rams, pipe
slip rams & slip rams is the same with and
without the safety factor
Change to 700 cycles to include safety factorAccepted
Safety factor and reference to API 17N has been removed.
Annex L Table L-10 Technical
The requirement is not clear regarding safety
factor. Is the minimum requirement with or
without safety factor? Both rows state
"Minimum number of required…" Footnote
states that other confidence levels can be
chosen which will change the SF.
Delete "minimum" in 2nd row. Replace with
"Example: Number of required endurance cycles
with safety factor based on 90% confidence
level". If this was the intent. Manufacturer
needs to know
Accepted
Safety factor and reference to API 17N has been removed.
Annex L L.3.4.6.9 EditorialIncorrect subsection referenced in dynamic fluid
closure test, process step l
Change from 8.3.1.2 to 8.3.2.2Accepted
'Marked up in API 17G WD5.2
Annex L L.3.4.6.9 EditorialIncorrect subsection referenced in dynamic gas
closure test, process step j
Change from 8.3.1.3 to 8.3.2.3Accepted
'Marked up in API 17G WD5.2
Annex L L.3.4.7.5 EditorialSection "a)", reference to Table L-7 incorrect Change to Table L-1
AcceptedAlready updated in API 17G WD5.2
Annex L L.3.4.7.6 Editorial Spelling error in paragraph 1 Change "devises" to "devices" Accepted 'Marked up in API 17G WD5.2
Annex L L.3.4.7.2 EditorialAdd requirement for tensile test properties in
line with test procedure below)
Reword "h)" by inserting ", ultimate tensile
strength" after yield strengthAccepted
'Marked up in API 17G WD5.2
Annex L L.3.4.7.8 EditorialIncorrect subsection reference in last
paragraph/number lst
Change L.3.3.2.7 to L.3.3.2.5Accepted
'Marked up in API 17G WD5.2
Annex L L.3.5.1 EditorialIncorrect sub-section reference in paragraph 2 Change 4.19 to 4.20
Accepted'Marked up in API 17G WD5.2
Annex L L.3.5.2.3 EditorialIncorrect sub-section reference in paragraph 2 Change 5.12.1 to 5.21.1
Accepted'Marked up in API 17G WD5.2
Annex L L.3.5.2.3 Editorial Incorrect Annex reference in paragraph 2 Change D.12 to D.1.2 Accepted 'Marked up in API 17G WD5.2
Annex L L.3.5.2.9 EditorialIncorrect reference in "c)" Delete "c)" which is located at en of first
sentence in "c)"Accepted
'Marked up in API 17G WD5.2
Annex L L.3.5.2.10 Editorial
Correct spelling of Disconnect: Discount testing
with combined bending and tension loads in
accordance with Subsection 5.5.19 k) shall be
performed prior to performing this
disconnect/reconnect test.
Disconnect testing with combined bending and
tension loads in accordance with Subsection
5.5.19 k) shall be performed prior to performing
this disconnect/reconnect test.
Accepted
Marked up in API 17G WD5.2
Annex L L.3.5.2.10 Editorial Incorrect reference in paragraph 2 Change 5.5.19 k) to 5.19 Accepted Marked up in API 17G WD5.2
Annex L L.3.5.2.10 Editorial Spelling error in paragraph 2 Change discount to disconnect Accepted Marked up in API 17G WD5.2
Annex L L.3.5.2.13 Editorial Incorrect API reference Change 17N to 17H Accepted Marked up in API 17G WD5.2
Annex L L.3.6.1 EditorialIncorrect subsection reference in paragraph 3 Change 4.19 to 4.20
AcceptedMarked up in API 17G WD5.2
Annex L L.3.6.2.2 Editorial Incorrect Annex reference in f) Change from M.4.4.3 to M.4.4.2.2 Accepted Marked up in API 17G WD5.2
Annex L L.3.6.2.2 Editorial Incorrect Annex reference in g) Change from M.1.3.11 to M.1.2.16 Accepted Marked up in API 17G WD5.2
Annex L L.3.6.2.2 Editorial Incorrect Annex reference in g) Change from M.1.3.15 to M.1.2.16 Accepted Marked up in API 17G WD5.2
Annex L L.3.6.2.2 Editorial Incorrect Annex reference in h) Change from M.1.2.25 to M.1.3.24 Accepted Marked up in API 17G WD5.2
Annex L L.3.6.2.4 Editorial Incorrect figure referenced Change from Figure 5-15 to Figure 5-5 Accepted Marked up in API 17G WD5.2
Annex L L.3.6.2.5 Editorial Incorrect Annex referenced in NOTE Change from M.1.3.16 to M.1.2.17 Accepted Marked up in API 17G WD5.2
Annex L L.3.6.2.5 EditorialIncorrect Annex referenced in numbered list
item 1) & 2)
Change from M.1.3.15 to M.1.2.16Accepted
Marked up in API 17G WD5.2
Annex L L.3.6.2.5 EditorialIncorrect Annex referenced in numbered list
item 3)
Change from M.1.3.16 to M.1.2.17Accepted
Marked up in API 17G WD5.2
Annex L L.3.6.2.5 EditorialIncorrect Annex referenced in numbered list
item 4)
Change from M.1.3.10 to M.1.2.11Accepted
Marked up in API 17G WD5.2
Annex L L.3.6.2.5 EditorialIncorrect Annex referenced in bullet list on page
610
Change M.1.3.21 to M.1.2.21Accepted
Marked up in API 17G WD5.2
Annex L L.3.6.2.5 EditorialIncorrect Annex referenced in bullet list on page
610
Change M.1.3.22 to M.1.2.22Accepted
Marked up in API 17G WD5.2
Annex L L.3.6.2.5 EditorialIncorrect Annex referenced in bullet list on page
610
Change from M.2.4.2.1 to M.4.4.2.2Accepted
Marked up in API 17G WD5.2
Annex L L.3.6.2.5 EditorialIncorrect Annex referenced in 2nd last
paragraph
Change M.1.3.21 to M.1.2.21Accepted
Marked up in API 17G WD5.2
Annex L L.3.6.2.5 EditorialIncorrect Annex referenced in last paragraph Change from M.1.3.15 to M.1.2.16
AcceptedMarked up in API 17G WD5.2
Annex L L.4.3 Editorialk) is incorrect, it should be continuation of j) not
new item
Correct as requiredAccepted
Annex LL.3.4.6.9
section h)
can't stabilize gas flow due to working with a
finite gas volume
strike "Stabilize the gas flow test rate??"
sentence.Rejected
satbilisation of gas is not specified in WD5.2 of API 17G for
the dydnamic closure test only for liquid part of the
procedure (i.e. stabilisation liquid flow raste not gas)
Annex L L.2.2.3 Editorial Incorrect table reference Change to table 5-1 Accepted Already updated in API 17G WD5.2
Annex L L.3.4.1 EditorialError in "Figure L-2 Sand Class II and Class III
qualification tests"
Change in "Sand Service Class III Test" flow
diagram wording in first process box from "As
class III test" to "As class II test"
Acceptedsame as comment above
Annex L L.3.4.7.8 EditorialIncorrect subsection reference in last
paragraph/number lst
Change L.3.3.2.7 to L.3.3.2.5Accepted
Marked up in API 17G WD5.2
Annex L L.3.5.2.10 Editorial Spelling error in paragraph 2 Change discount to disconnect Accepted Marked up in API 17G WD5.2
Annex L L.3.2.1 Generalcontains a reference to non-existing subsection
8.3.1.1Accepted
Marked up in API 17G WD5.2
Annex M M EditorialMCP is used instead of MCS. Change MCP to MCS.
AcceptedChange all MCP to MCS. Make sure the reference is
appropriate in context
Annex M M.1.1 General
There is also a third system solution to All-
hydraulic and electro-hydraulic which is All-
electric system. This is a system with no
hydraulic in umbilical but with subsea pumps,
reservoir etc located in the subsea stack. This
should also be covered in this chapter. A short
decription of the three is missing and a detailed
decription of the all-electric
Add new section after section 1:
There typical three IWOCS systems solutions:
1. All-hydraulic: All subsea hydraulic functions
direct controlled from topside (Only hydraulic
hoses in umbilical)
2. Electro-hydraulic: Subsea hydraulic functions
mainly controlled by subsea control module
(Hydraulic hoses, power and interface cables in
umbilical)
3. All-Electric: All subsea function controlled
from subsea control module together with
subsea pumps and reservoir (Only power and
communication cables in umbilical)
Selecting the right IWOCS solution depends on
parameters like cost, water depth, system
flexibility and response time.
Rejected
First sentence has been changed to the following with
comments provided.
"Multiple aspects like economics, technical solutions and
system operation dictate whether to choose an all-
hydraulic or electro-hydraulic system. "
Annex MM 1.1
Section 3General
Section 3:
Project economics i not the only one dictating
whether to choose AH or EH system, but also
operational and technical requirements like
responce time, number of function (umbilical
size) water depth etc.. It is not not given that a
DH system always is cheaper.
Section 2 add sheapest in the first sentence:
.... are generally the least complicated, sheapest
and the most reliable subsea ....
Section 3 delete first sentence:
Project economics dictate whether .... Rejected
Agreed with comment however first sentence reworded to
" " as stated in line 443
Annex M M.1.1 Technical
The statement in second paragraph about
reliability is not correct and should be deleted.
Correction:
Direct hydraulic systems are generally the least
complicated subsea control system, but they
have a limited capacity for sequenced and logic
automation of functions.
Rejected
Agreed with comment however first sentence reworded to
" " as stated in line 443
Annex M
M.1.1
Paragraph
3
Technical
The first sentence in paragraph is not correct
and should be corrected.
Correction:
Multiple aspects like economics, technical
solutions and system operation dictate whether
to choose an all-hydraulic or electro-hydraulic
system.
Accepted
"New Text for second paragraph:
""Multiple aspects like economics, technical solutions and
system operation dictate whether to choose an all-
hydraulic, electro-hydraulic or all electric system. All
hydraulic systems typically are relatively slow to respond,
compared to electro-hydraulic or all electric systems, and
have limited capability for providing data telemetry from
the subsea system. Electro-hydraulic or all electric systems
also enables sequencing and logic automation of system
functions such that the operator can focus on operational
aspects more than focusing on detailed system monitoring
and control. The specific needs of each application should
be carefully considered, particularly with respect to data
needs and speed of response."""
Annex M
M.1.1
Paragraph
3
Technical
Add important aspect when choosing EH-
systems.
Add sentence:
... data-telemetry devices. This system design
also enable sequencing and logic automation of
system functions such that the operator can
focus on operational aspect more than focusing
on detailed system monitoring and control.
Electrohydraulic systems are ...
Accepted
"Accept in principle. New paragragh 3 text:
Paragragh 3 to be deleted and this additional changed
added to the second paragrgh. Refer to line 443"
Annex M
M.1.1
Paragraph
8
Technical
Last sentence need to include human error
aspects as an factor when select system
architecture.
Correction:
Based upon a variety of risk factors highlighted
in the Safety Strategy, including how system
design affects the probability for human error,
should prevail when selecting of one system
over the other.
Rejected
Not a Technical Comment. Annex is clear and consistent.
Annex M
M.1.1
Paragraph
10
Technical
Add equipment examples in first sentence after
table.
Correction:
An intervention workover control system can be
direct-hydraulic consisting of a HPU, reeler and
umbilical or a complete electro-hydraulic (E-H)
system, composed of Operator station, HPU,
hydraulic distribution unit, reel, umbilical, and
subsea distribution.Accepted
New text "An intervention workover control system can be
direct-hydraulic consisting of a HPU, reeler and umbilical or
a complete electro-hydraulic (E-H) system, composed of
operator station, HPU, hydraulic distribution unit, reel,
umbilical, and subsea distribution. Regardless of the scale
of the system, the functionality can be broken down into
sub systems which correspond with the structure of this
document and shall be used as a reference for system
design. The major subsystems are as follows:"
Annex MM 1.1
Table M-2General
Add relevant products under Surface Power
Generation.
Add:
- Subsea Power & Communication Unit (SPCU)
- Alternator Rejected
There is no subsection of this name in the document to
add here.
Annex MM 1.1
Table M-2General
Add relevant products under Distribution. Add:
- Hydraulic Distribution Unit (HDU)
- Reel Deck Jumper
RejectedThere is no subsection of this name in the document to
add here.
Annex MM.1.1
Table M-2General
Correct name on sub-system Subsea Power
Accumulation and add relevant product.
Correct:
Correct name to Subsea Power Generation and
add Subsea Electric Systems
RejectedRefer to line 519, tile now ""Subsea Hydraulic Power
Generation and Storage"
Annex MM.1.1
Table M-2General
Add relevant product under Subsea Power
Storage and establish name consistency Subsea
Power Storage vs. Subsea Power Accumulation
throughout the document.
Add:
Subsea Uninterruptible Power SupplyRejected
"Refer to line 519, tile now """"Subsea Hydraulic Power
Generation and Storage""
Subsea Uninterruptible Power Supply is not added as there
is no subsection of this name"
Annex M M.1.1 EditorialDelete text after table M-2 since this duplicates
table and text higher up.
Delete text between table and next section.Accepted
Delete text
Annex M M.1.1.1 Technical
Add clarity to requirement. Correct:
The thru/BOP-riser intervention mode system
shall provide the means to control all functions
on the subsea test tree assembly, tubing hanger
running tool, and completion hardware including
subsea tree system during the following phases
and operations:
Accepted
New text "The thru/BOP-riser intervention mode system
shall provide the means to control all functions on the
subsea test tree assembly, tubing hanger running tool, and
completion hardware including subsea tree system during
the following phases and operations."
Annex M M.1.1.1 Technical
Add clarity to system differences. Add sentence after first paragraph sentence:
Electro-hydraulic control system also enables
predefined functional logic, while direct
hydraulic systems often require the operator to
manually process and execute the same
functional logic.
Rejected
"Paragraph after the bullet should now read:
""Dependent upon the required speed of subsea valve/ram
actuation and risk assessment considerations either a
direct hydraulic control system or electro-hydraulic control
system should be selected as the intervention and
workover control system. An Electro-hydraulic control
system enables predefined functional logic, while direct
hydraulic systems often require the operator to manually
process and execute the same functional logic. This
selection process is clearly defined as part of the Safety
Strategy; clause 4.12."""
Annex M M.1.2.1 TechnicalApply consistency. Correct:
k) PSD/ESD/EQD sequences and timing;Accepted
add "PSD" to k)
Annex M
M.1.2.2
Paragraph
1
Technical
Delete first sentence since this is an open
requirement that adds no value.
Delete first sentence.
Accepted
New Text for 1st Paragraph
"The IWOCS basic system design shall allow for full
functionality of envisioned existing infrastructure and
intervention scenarios. The following elements shall be
considered during system engineering:"
Also add
"l) ROV Interfaces
m) control fluid & process fluids compatibility"
Annex M
M.1.2.2
Paragraph
1
Technical
The term "consider" is used in multiple locations
throughout the document. A requirement to
concider something can be justified regardless
what has been done and is as such an open
requiremement that adds no value to the
document. As a minimum the term should be
followed by a requirement to justify and
document the outcome of a consideration.
Add the following definition of "consider" in
section 3.1
consider
or any gramatical variation of it shall be
understood as a requirement to also justify and
document the outcome of a consideration
or
correct the use of consider throughout the
document.
Accepted
"The changes per word document.
Affects, M1.2.6, M1.2.8, "
Annex M M.1.2.10 TechnicalApply consistency. Add to item b)
... conditions requiring PSD, ESD or EQDs;Accepted
add "PSD" to b)
Annex M M.1.2.12 Technical
Loss of control station can be just as critical as
loss of power.
Add requirement for contingency control, ref.
comment to M.1.2.18.
Correct:
The IWOCS shall be designed to render the well
intervention packages to a fail-safe status upon
loss of power and/or operator control. Upon
restoration of power and operator control, the
fail-safe status shall not be effected or changed.Accepted
WG to revise Annex requirements. Accept in principle
however it does not have to be all electric system to be
affect by loss of electrical.
Next Text:
"The IWOCS shall be designed to render the well
intervention packages to a fail-safe status upon loss of
hydraulic or electrical power and/or operator control.
Upon restoration of power and/or operator control, the
fail-safe status shall not be affected or changed."
Annex M
M.1.2.15
Paragraph
1
Technical
Add more clarity to requirement. Correct:
... push buttons. In the case of interlocks,
justified and documented considerations shall be
given to the possibility of overriding these
interlocks at any time. In general, most
interlocks should be possible to override.
Accepted
New text after ….push Buttons. "In the case of interlocks,
justified and documented considerations shall be given to
the possibility of overriding these interlocks at any time. In
general, most interlocks should be possible to override."
Annex M
M.1.2.16
Paragraph
3
Technical
Add clarity. Correct:
The safe state for each safety function in the
different operational modes shall be determined
and specified in a safety requirements
specification by the end user. Safety-related
functions shall as far as practically possible be
independent to non-safety functions such that a
failure in non-safety systems shall not adversely
affect intended safety functions. A further aim
shall be independence between the different
safety functions. The safety strategy shall govern
and define how much of the safety function's
functional chain that shall be independent, e.g.
independent control valves and upstream
functional elements but common final functional
element like a valve, ram or connector.
Accepted
WG to determine the placement of the proposed change
within 17G. Proposed intent is accepted. WG to revise and
clarify the Annex. Add additional text
Annex M
M.1.2.16
Paragraph
4
Editorial
Correct grammar. Correct:
This can be achieved in the form of safety
integrity levels (SILs).Accepted
New Text "This can be achieved in the form of safety
integrity levels (SILs) or any other equivalent method. "
Annex M M1.2.18 Technical
Delete this section because it is redundant to
section M.1.2.12 Fail-safe philosophy.
Requirement for restoring the system is
proposed added to M.1.2.12.
Delete entire section and included the following
into Clause M.1.2.12 "Upon restoration of
power, the fail-safe status shall not be effected
or changed."
Accepted
This section is for contingency where the system can
establish safe state.
Annex M M.1.2.23 Technical
Add clarity to requirement. Add after last sentence:
If the response time verification is done in
atmospheric pressure (i.e. on land) the test
results shall be verified against
calculation/simulation with atmospheric
pressure as ambient. Based on actual test data a
calibration or update of the
calculation/simulation model shall be done, test
cases shall be re-established and validated
against the project's requirements for response
times.
Accepted
"Agree in Principle. New Text for entire section:
""Response time testing using actual equipment shall be
carried out to ensure that the response time projected for
the control system meets the system objectives. This can
be conducted as part of system integration testing, or
standalone tests. The actual response time shall be
validated against the projected response time in M.1.2.22,
if carried out.
If the response time verification is done in atmospheric
pressure (i.e. on surface) the test results shall be verified
against calculation/simulation with atmospheric pressure
as ambient. Based on actual test data a calibration or
update of the calculation/simulation model shall be done
and validated against the project's requirements for
response times."""
Annex MM.1.3.1
item f)Technical
Avoid technology limiting formulations. Correct:
f) control module; the control module may be
split in two or more physical units where the
method of control typically may be piloted-
hydraulic hydraulic, electro-hydraulic or electric
control system, the control module is the unit
that, upon command from the MCS, directs
hydraulic fluid or any other energy carrier to
operate subsea functions.
Accepted
"Agree in Principle. New Test for f)
""control module; may be split in two or more physical
units where the method of control typically may be piloted-
hydraulic, electro-hydraulic or electric control system, the
control module , upon command from the MCS, directs
hydraulic fluid or other means of energy to operate subsea
functions. In an electro-hydraulic or electric system, the
control module also gathers information and transmits the
information to the topside facility"""
Annex M M.1.1 Technical
The list on page 609 does not match figure M.1
and Table M.2
Update list, figure and table.
Rejected
"Table M.2 should be as per the section titles.
No list on page 609 and Fig M.1 has been marked up on
other comments"
Annex M M.2 General
Design Clause for Surface Software states TBA Update.
Accepted
"Accept in principle, however this should be one section
for all software.
Create new Section M.4 With the information in the
M4.4.1.3 with a title Surafce / Subsea software"
Annex M M.1.3 TechnicalThe list should contain requirements about
uptime and spouriosly EQD
Add: System uptime and spouriosly shut down
requirementsRejected
This is covered in M.1.2.1
Annex M M.1.3.1 General
The meaning of this chapter is unclear. It lists
flexibility areas (as electrical load), operational
optimization (as downhole chemical injection)
but also qualification erquirements (as
robustness, water ingress and material
compability). And there is a lot missing like XT
hydraulic / electric interface, rig interface etc..
Split this chapter into one flexibility and one
optimization chapter, and clearly define what
within this areas that should be considered
during system engineering, and the focus should
be on what gives the operator/costumer
operational flexbility and optimization. OR this
section could be deleted.
Rejected
Refer to As per API 17G WD6 Ballot 10_3_13 line 455. &
API 17G WD6 Ballot 10_14_13 line 173 for comments to
this section.
Annex M M.1.3.11 Technical, this is achieved by bleeding off hydraulic supply
pressure. SSTT close assist need applied
pressure in shutdown.
Change to; this is achieved by bleeding off or
adding supply pressure. RejectedCan not find the comment in WD5.2.
Annex M M.1.3.14 Editorial
It shall only be possible to operate the
equipment from one site at any one point in
time. This line is under a part describing
shutdown panels, but I think it referes to MCP -
RCP.
Clarify.
Accepted
"The text is in securing measures. Site to be changed to
location. Added to ensure if multiple operationg systems
are used then one is the master.
New Text.""With the exception of PSD, ESD, and EQD
functionality, it shall only be possible to operate the
equipment from one location at any one point in time. """
Annex M M.2.3 TechnicalList I missing interface for info received on the
rig PA system.
Update.Rejected
Annex M M.2.4.1.1 Editorial
Top text says: Topside Electronic Module (TEM).
First column says topside electric unit, and next
collum says communication unit. If this is the
same part, it would be good to use the same
name.
Update.
Accepted
New Text" The following electronic module parameters
against the subsea located unit should be monitored by
the MCS.
Annex M M.2.4.1.1 Technical
Add clarity. Correct:
The following communication unit parameters
against the subsea located unit should be
monitored by the MCS:
1. input voltage to subsea located unit(s);
2. input current to subsea located unit(s);
3. applied umbilical voltages/currents;
4. line/wire insulation (optional).
Accepted
"New Text:
The following electronic module parameters against the
subsea located unit should be monitored by the MCS:
1. input voltage to subsea located unit(s);
2. input current to subsea located unit(s);
3. applied umbilical voltages/currents;
4. line/wire insulation (optional).
"
Annex M M 2.4.1.6 f) EditorialMaster Control Panel Change to Master Control Station
AcceptedNew Text "flanged high level switch connected to the
Master Control Station"
Annex MM.2.4.1.6
item f)Technical
Avoid technology limiting formulations. Correct:
f) flanged high level switch connected to the
Master Control Panel
AcceptedNew Text "flanged high level switch connected to the
Master Control Station"
Annex M
M.2.4.2.1
Paragraph
1
Technical
Add clarity. Correct:
The hydraulic power unit shall include redundant
pumps, high and low pressure accumulators,
supply and return tanks, flushing/filtering
facilities, and local control/alarm panel. Accepted
"Flushing/filtering should also be removed for clarity as
clause M.1.2.28 allows this to be a separate unit.
New Text in 1st paragragh ""The hydraulic power unit shall
include redundant pumps, high and low pressure
accumulators, supply and return tanks and local
control/alarm panel. Flushing/filtering facilities shall be as
per M.1.2.28."""
Annex M M 2.4.1.6 f) EditorialMaster Control Panel Change to Master Control Station
AcceptedNew Text "flanged high level switch connected to the
Master Control Station"
Annex M M.2.4.1.2 Technical
Unitended operation of connectors during
running shall not be possible. We need to run
these functions during operation, so an
unintended operation will still be possible.
Unintended operation of connector during
running shall be prevented by adding satety
rated functions such as…Accepted
not sure the revision of document reviewed as current
wording is "Unintended operation of safety critical
functions during running shall not be possible. Safety rated
functions such as unlatch shall be protected by interlocks,
protective covers, or isolation of the dedicated control
lines."
Annex M M.2.4.1.2 Technical
The MCP shall consist of the following sub items:
topside Electronics Module, subsea Power Unit,
subsea Communications Unit. This is unknown
names to me. Is it TEM, UPS and SPCU?
Need to clearify.
Accepted
Communications unit has been removed. Electronics
module is detailed above 2.4.1.2 and the power unit is the
HPU.
Annex M M.2.4.1.4 Technical
Info missing. Add: Failure on one panel shall not influence the
possibility to activate shutdown from the other
panels. Rejected
This is already covered in the existing text "
Disconnect/Failure on one panel shall not influence the
possibility to activate shutdown from the other panels."
Annex M M.2.4.1.6 TechnicalIt is stated that the gass tank shall be gas tight.
On our tanks we have a air filter and gas sensor.
Consider an update.Rejected
This was removed in WD 5, current WD 5.2 has reworded
this per previously submitted comments.
Annex M M.2.4.1.6 Technical
reservoir drain pump connected to the hydraulic
power unit motor starter. We have an air driven
pump that is operated on the dirty drain tank.
This is field proven.
Remove this line.
Rejected
This was removed in WD 5, current WD 5.2 has reworded
this per previously submitted comments.
Annex M M.2.4.1.6 General
After M.2.4.1.6 there is missing a chapter
adressing the topside software.
Update.
Accepted
"Accept in principle, however this should be one section
for all software.
Create new Section M.4 With the information in the
M4.4.1.3 with a title Surafce / Subsea software"
Annex M M.2.4.2.1 Technical
The same type of fittings shall be used for each
pressure class throughout the system. Unclear
what is ment be type. Pressure rating,
manufacturer, threads?
Clarify.
Accepted
"This was removed in WD 5, current WD 5.2 has reworded
this.This was removed in WD 5, current WD 5.2 has
reworded this per previously submitted comments.
Please note type is manufacturer i.e. swagelock, Autoclave
etc as well as connection i.e. MP, HP, NPT etc"
Annex M M.2.4.2.1 Technical
All other monitiring points if equipped should be
controlled by the MCP and should be sent via
dual communication link to the MCP. I find the
text unclear.
Clairfy.
Rejected
This was removed in WD 5, current WD 5.2 has reworded
this per previously submitted comments.
Annex M
M 2.4.2.1
Section: If
the
IWOCS…
Technical
This section asks for a volume of 1 hour. This will
produce discussions. Also it is not clearly stated
that this volume is in addition to the required
closing volume.
Increase the safety factor on the open and close
calculations to 28% or 30%. Delete the 1 hour
part. If 1 hour statement is kept, clearifie that
the 1 hous is an additional volume.
Rejected
The 1 hour is stated such that upon loss hydraulic power
there requires to be enough time to estabish the required
barriers, taking into account any loss of fluid due to system
design
Annex M
M 2.4.2.1
Section: In
the case...
Technical
Unclear: , the HPU shall be able to bleed down
hydraulic power to subsea.
, the subsea hydraulic power supply shall be bled
of at the HPU.Accepted
new Text "In the case of bleeding down hydraulic pressure
as part of a function, the HPU shall be able to bleed down
the subsea hydraulic power supply"
Annex M
M 2.4.2.1
Section:
The
hydraulic
Editorial
The last sentence. connections its lowest point. connections at its lowest point.
Accepted
Missing "at". New Text "The drip pans should include
drainage ports/connections at its lowest point."
Annex M
M 2.4.3.1
Section: If
the
IWOCS…
Technical
a one-hour supply of energized fluid. Increase the safety factor on the open and close
calculations to 28% or 30%. Delete the 1 hour
part. Rejected
The 1 hour is stated such that upon loss hydraulic power
there requires to be enough time to estabish the required
barriers, taking into account any loss of fluid due to system
design
Annex M
M.2.4.2.1
Paragraph
18
Technical
Add clarity. Correct:
The start/stop set points should, within design
boundaries, be able to be changed via the HMI.Accepted
new text "The start/stop set points should within design
boundaries be able to be changed via the HMI."
Annex M
M.2.4.2.1
Paragraph
23
Technical
It is bad workmanship to leave burrs and not
clean tubing properly.
Correct:
... No burrs shall be allowed, and each section of
the tubing shall be blown through and cleaned
before assembly to ensure that no
contamination (debris) enters the system during
manufacturing and assembly.
Accepted
new text "No burrs shall be allowed, and each section of
the tubing shall be blown through and cleaned before
assembly to ensure that no contamination (debris) enters
the system during manufacturing and assembly."
Annex M M.2.4.3.2 Technical
The uninterruptible power supply shall supply
electrical power to the subsea power unit,
topside electronic unit and the MCP. Is the
subsea power unit the SCM and topside
electronic unit the SPCU?
This text should be rewritten so that it defines
what Functions the UPS shall power, not witch
modules.. Accepted
Change first paragragh to "The uninterruptible power
supply is required to ensure safe and reliable electrical
power to the IWOCS."
Annex MTable M-3.
7.2.5.4Technical
It states: IWOCS umbilicals are not required to
comply. Then e) states: may be required.
Delete the first text and add it into e).
Accepted
Delete first sentence and e) now reads "Insulation
materials for IWOCS umbilicals are not required to comply
with the requirements of lEC 60502-1 and IEC 60502-2,
however, depending on voltage rating, insulation material
and thickness, nonmetallic conductor and insulation
screening may be required, as specified in IEC 60502-1 or
IEC 60502-2."
Annex M
Table M-3,
section ref.
API 17E ref
EditorialError in 1st column Change "ISO API 17E Section Reference " to "API
17E Section Reference" Acceptedmake changes per proposed change
Annex M
Table M-3,
section ref.
API 17E ref
6.3.5
Technical
I´m questioning why a VIV analysis is applicable
for a free hanging (clamp-less) umbilical? To be
evaluated.Rejected
API 17E section explains the evaluation
Annex M
Table M-3,
section ref.
API 17E ref
. 7.2.5.3
Technical
Added ...copper and copper + insulation. Added
and impedance for signal.
The minimum nominal cross-sectional copper
area for power and copper + insulation area for
signal conductors in IWOCS umbilicals shall be
selected such that it is suitable tor the system
voltage and current requirements and
impedance for signal requirements.
Accepted
Refer in line 503, not added copper etc as specific
Annex M
Table M-3,
section ref.
API 17E ref
. 7.2.5.4
Technical
This Section seem to be inconsistant with
regards to the IEC 60502-1 referance. The first
paragraph states that this standard is not
applicable for insulation materials, while it is
referenced in item e)??
Accepted
as per line 494
Annex M
Table M-3,
section ref.
API 17E ref.
7.2.6.1
Technical
Nominal to be replaced by calculated For IWOCS umbilicals the direct current
resistance for each conductor shall not exceed
the calculated resistance per unit .....Accepted
new text "For IWOCs umbilicals the direct current
resistance for each conductor shall not exceed the
calculated resistance per unit length for the specified
conductor based upon the conductor dimensions and the
applicable material resistivity."
Annex M
M-3,
section ref.
7.2.9.3 and
7.2.10.4
Editorial
These sections to be merged into one section
(both are about direct current conductor
resistance). Some of the text is replicated. Rejected
They match API 17E references
Annex M
Table M-3,
section ref.
API 17E ref
. 8.2 a)
Technical
For applications where the umbilical is run inside
the marine riser, is is usually required to use an
ultra slim-line termination head due to space
constraints. The terminated SWL for ultra slim-
line terminations is normally less than the
umbilical SWL due to physical limitations.
a) design principle is that the end termination
shall meet the same functional requirements as
the umbilical, except for terminated SWL for
ultra slime-line terminations. Ultra slim-line
terminations may be required due to very
limited space if the umbilical is routed inside the
marine riser.
Accepted
add text in proposed change
Annex MTable M-3.
7.2.6.1Technical
For IWOCS umbilicals the direct current
resistance for each conductor shall not exceed
the nominal resistance per unit length for the
specified conductor based upon the conductor
dimensions and the applicable material
resistivity.
How can I deliver according to this? Clarify.
Rejected
No proposed change. Text has been modified per line 498
Annex M Table M-3 Technical
Add clarity. Correct line 6.3.6:
Only applicable in open-water intervention
mode if the umbilical is in close proximity to
C/WO riser or vessel (e.g., pontoons, moonpool)
without being clamped to the C/WO riser or
pod/guide wire.
Accepted
add text in proposed change
Annex M Table M-3 Technical
At smaller cross sections mechanical strength in
conductors are equaly important.
Correct:
The minimum nominal cross-sectional area for
power and signal conductors in IWOCS umbilicals
shall be selected such that it is suitable for the
system voltage, current and mechanical load
requirements.
Accepted
New Text "The minimum nominal cross-sectional area for
power and signal conductors in IWOCS umbilicals shall be
selected such that it is suitable for the system voltage,
current, impedance for signal requirements and
mechanical load requirements."
Annex M
M.3.3.3
Paragraph
1
Technical
Add clarity. Correct:
The umbilical reel should have drum capacity to
spool up (store) the complete fluid-filled
umbilical length plus a surplus length of 10%.
Accepted
New Text "The umbilical reel shall have drum capacity to
spool up (store) the complete fluid-filled umbilical length
plus a surplus length of 10%."
Annex M
M.3.3.3
Paragraph
7
Technical
Add clarity and avoid technology limiting
formulations.
Correct:
For reels powered by air or hydraulic sufficient
filtering, lubrication, and pressure regulation of
the power supply shall be provided on the reel
to protect the motor and power train from
excessive wear or damage. For reels powered by
electricity equivalent means shall be provided to
ensure that electric supply do not cause
excessive wear or damage.
Accepted
New Text "For reels powered by air or hydraulic pressure,
sufficient filtering, lubrication, and pressure regulation of
the power supply shall be provided on the reel to protect
the motor and power train from excessive wear or
damage. For reels powered by electricity equivalent means
shall be provided to ensure that electric supply do not
cause excessive wear or damage."
Annex M
M.3.3.3
Paragraph
11
Technical
Add clarity. Correct:
Without having the reel's topside deck jumper
connected the reel should have facilities to allow
for selected umbilical lines to be isolated and
pressure-maintained
during deployment and retrieval.
Accepted
New Text "Without having the reel's topside deck jumper
connected, The reel should have facilities to allow for
selected umbilical lines to be isolated and pressure-
maintained during deployment and retrieval. All functions
should be mounted in an isolating/monitoring panel on the
reel. "
Annex M M.3.1 Editorial
The scope of clause M.3 is limited to the use of
umbilicals for the distribution subsystem. Find
the part " use of umbilicals " unclear.
The scope of clause M.3 is limited to umbilicals
for the distribution subsystem, and must fulfill
the following requirements.Rejected
This was added in WD 5, current WD 5.2 has this wording
already as per previously submitted comments.
Annex M M.3.3.2 Editorial
The umbilical termination… The umbilical topside end termination...
Rejected
This was added in WD 5, current WD 5.2 has this wording
already as per previously submitted comments.
Annex M M.3.3.2 Technical
A multi-quick connector function should be
designed for make-up and break-out by hnad if
only topside operation is intended. We need to
use hand tools for make-up.
Change from should to can.
Accepted
New Text "A multi-quick connector function can be
designed for makeup and break-out by hand if only topside
operation is intended. "
Annex M M.3.3.3 Technical
The reel should be equipped with a transverse
reciprocating… We use a diamond screw for our
spooling device.
Change from should to can.
Accepted
"Accept in principle. New Text
""The reel shall be equipped with a guidance system to
evenly spool the umbilical on the drum during re-
spooling."""
Annex M M.3.3.3 Technical
The reel drum diameter shall be designed to the
umbilical minimum STATIC diameter, not
DYNAMIC.
The reel shall have a drum diameter eaqual to or
greater than twice the minimum static bend
radius or as ....Accepted
new text "The reel shall have a drum diameter equal to
twice the minimum static bend radius or as otherwise
agreed with the umbilical supplier."
Annex M M.3.3.3 Technical
The reel shall also have a locking pin system for
securing the reel drum during transport and
when the topside deck jumper is connected.
Remove: and when the topside deck jumper is
connected. The clutch is holding the drum.Accepted
new Text "The reel shall also have a locking pin system for
securing the reel drum during transport. "
Annex M M.3.6 Editorial
couplers extra? Unclear.
Accepted
"New Text for M.3.6
""The umbilical shall be pressure tested, in line with
maintenance schedule periods, after replacement of any
defective connectors and if being operated beyond the
operational limitations."""
Annex M M.3.7 Technical
The reel drive system also include a gear box
which is sitting adjacent to the drum. Please
note, that during deployment and retreieval of
the umbilical, the brake is not engaged. The
umbilical is then protected by the slip clutch.
The clutch shall be directly adjacent to the input
end of the gear box, which again shall be
adjacent to the drum. The brake shall be located
...Accepted
new text for M3.7, 3rd paragraph "The clutch shall be
directly adjacent to the input end of the gear box, which
shall be adjacent to the drum and the brake shall be
located between the motor and the clutch"
Annex M
M.4.3.1.2
paragraph
2
Technical
Because a requirement for independency on
safety functions is system related and not
specific for the WOCM a rephrased version of
this paragraph is moved to M.1.2.16 Safety
functions, while this paragraph is deleted.
Correct:
Safety-related functions in the workover control
module, including ESD and EQD sequences, shall
be independent as defined in the safety strategy.Accepted
new text for M3.7, 3rd paragraph "The clutch shall be
directly adjacent to the input end of the gear box, which
shall be adjacent to the drum and the brake shall be
located between the motor and the clutch"
Annex M
M.4.3.3
Paragraph
2
Technical
Add clarity and consistency. Correct:
Subsea power storage for Thru/BOP – Riser
Intervention Modes the safety functions shall, as
defined by safety strategy, be segregated from
power storage to non-safety functions such that
stored energy for safety functions is available at
any time. Further, independence between the
different safety functions shall be as defined by
the safety strategy.
Accepted
"new text ""Subsea power storage for Thru/BOP – Riser
Intervention Modes the safety functions shall, as defined
by safety strategy, be segregated from power storage to
non-safety functions such that stored energy for safety
functions is available at any time. Further, independence
between the different safety functions shall be as defined
by the safety strategy.
Sufficient capacity for the respective functions for one (1)
close or unlock operation, together with a 10% margin"""
Annex M
M.4.3.3
Paragraph
3
Technical
Add clarity and consistency. Correct:
Subsea power storage for Open Water
Intervention Modes the safety functions shall, as
defined by safety strategy, be segregated from
power storage to non-safety functions such that
stored energy for safety functions is available at
any time. Further, independence between the
different safety functions shall be as defined by
the safety strategy.
Accepted
"new text ""Subsea power storage for Open Water
Intervention Modes the safety functions shall, as defined
by safety strategy, be segregated from power storage to
non-safety functions such that stored energy for safety
functions is available at any time. Further, independence
between the different safety functions shall be as defined
by the safety strategy.
Sufficient capacity for the respective functions for one (1)
close or unlock operation, together with a 25% margin """
Annex MM.4.4.1.3
item i)Technical
Time stamping is required if retreived data shall
be placed in correct timeframe.
Correct:
... This storage and delayed transmission of data
are acceptable only if they are time stamped and
none of the data in question is lost or
overwritten; Accepted
new text "in specific operational modes a large amount of
data might not be possible or appropriate to relay to the
MCS in real time. Temporary storage of this data are
acceptable, provided the stored data are subsequently
relayed to the MCS in a timely manner. This storage and
delayed transmission of data are acceptable only if they
are time stamped and none of the data in question is lost
or overwritten"
Annex M M.4.4.2 Editorial
Correct heading. Correct:
Subsea power generationAccepted
"new title ""Subsea Hydraulic Power Generation and
Storage""
This change also affects figure M.1"
Annex MM.4.4.2.2
item d)Technical
BS 7201-1 is absolite wording is not logic. Correct:
d) design of accumulator shall comply with ASME
Boiler and Pressure Vessel Code, Section VIII,
Division 1, BSI BS EN 14359 + A1, ISO 10945, or
the applicable code or regulation which applies;
Accepted
WG to revise and clarify the requirement. Should state
"with either"
Annex M M.5.3.2 Technical
Avoid technology limiting formulations. Correct:
The IWOCS shall interface with the surface tree,
lubricator valve, SSTTA, BOP spacer joint, tubing
hanger and tubing hanger running tool to
provide the necessary control to function these
equipment.
Accepted
WG to revise and clarify the requirement.
Annex M M.5.3 Technical
Interfac between….shall be defined in Annex F.
Annex F does not address questions concerning
air quality on rig supplied compressor air, or
quality of the el. supply. Do the system need air
drier and alternator?
Consider an update.
Rejected
This is not a comment for Annex M, but should reviewed
by Annex F to determine if valid to add. (Ask James Pate)
Annex M M.7.1 Technical
Seksjon M.7
M.7.1 Safe system design
“…Safety instrumented systems shall be
designed in accordance with the reliability
principles for minimizing the probability of
failure on demand as defined in IEC 61511:::”
3.1.157 safety instrumented system
“instrumentation and controls installed for the
purpose of taking the subsea intervention
system to a safe state
NOTE 1 Safety instrumented systems may
include electrical, electronic, pneumatic,
mechanical, and hydraulic systems.
NOTE 2 Safety instrumented systems do not
include instrumentation and controls installed
for non-emergency shutdowns or routine
(normal) operations”
Comment: M.7.1 warrants SIL requirements as
mandatory to e.g. PSD, ESD and EQD, together
with the definition 3.1.157. This is in conflict
with Section 1.1 and 4.13, where such is
optional for the IWOCS only.
Comment: M.7.1 warrants SIL requirements as
mandatory to e.g. PSD, ESD and EQD, together
with the definition 3.1.157. This is in conflict
with Section 1.1 and 4.13, where such is optional
for the IWOCS only.
Accepted
"Annex M is to be left as is and Section 4.13 to have
""NOTE: A SIL rating number is not a requirement on the
safety instrumented systems, unless specifically stated in
the safety strategy."" added.
Section 1 has also been re-written"
Annex M M.8.2.3 b) Technical
To do a test where you spool of all of the
umbilical, could be 3000m, is a huge process.
The result we get, do not defend the amuont it
will cost us.
Change to 20% of the umb.?
Accepted
"Annex M is to be left as is and Section 4.13 to have
""NOTE: A SIL rating number is not a requirement on the
safety instrumented systems, unless specifically stated in
the safety strategy."" added.
Section 1 has also been re-written"
Annex M M.8.4 Technical
The list of tests is missing EFAT with SCM,
WOCM or RCM.
Consider an update.
Accepted
"Clause 8 needs to be added to take into account SIT and
EFAT. New Text:
""In the case that an IWOCS control system (or subsystems
it consists of) is planned to be used in an application for
which it was not originally designed, then a change in any
one of the following variables shall require that an integrity
assessment and additional testing performed in
accordance with the relevant subsections of Annex M &
Clause 8:"""
Annex M M.9.2 TechnicalThe list of markings on the IWOCS is missing
Weight marking
Update.Rejected
Bullet g) defines weight if applicable
Annex M M.10.1 Technical
Avoid technology limiting formulations. Correct:
Operation and maintenance history, inclusive of
software revisions, shall be available in the
IWOCS control container or easily accessible on
site through a digital system.
Accepted
as per proposed change
Annex M M.10.6 Technical
Avoid technology limiting formulations. Correct:
A detailed log of maintenance, reliability, and
operational history shall follow the IWOCS at all
times.Rejected
"wording is already as proposed however this shall change
to the following new text.
""A detailed log of maintenance, reliability, and
operational history shall be available for the IWOCS at all
times. """
Annex M
M.11.1.1
item b),c),
d)
Technical
When equipment is rented it may not be the
manufactorer/vendor that owns the equipment.
Correct:
b) maintenance documentation shall be
maintained by the system/equipment owner;
c) modifications, upgrades, and repairs
documentation shall be maintained by the
system/equipment owner;
d) condition résumé shall be maintained by the
system/equipment owner.
Accepted
as per proposed change
Annex MM.11.1.1
item j)Technical
Add claity. Correct:
j) software installation procedures for
programmable devices shall be provided to
cover all scenarios of software installation. These
procedures shall not compromise the software
supplier's requirements to revision,
documentation and competency control.
Accepted
as per proposed change
Annex M
M.11.7
paragraph
1
Technical
Correctness of manuals has in general an
improvement potential.
Add to first paragraph:
The manuals should as far as practical possible
be verified through actual use on the system
and its equipment.
Accepted
"New Text to end of 1st Paragraph:
""The manuals shall as far as practical possible be verified
through actual use on the system and its equipment."""
Annex M M.11.2 k) Technicalanalysis. Is this the hydraulic analysis for the
accumulators?
ClarifyRejected
any analysis carried out, accumulors, reponce times etc
Annex M M.11.3 Editorialmanufacture and in should… Update.
Acceptednew text "Design analysis shall be prepared prior to
manufacture and should include as a minimum:"
Annex M M.11.4 EditorialBlank page. Update.
Rejectedno blank page in document
Annex M M.11.7 b) Technical
inspection, maintenance and repair procedures
for each component, including sub components.
This puts on the producer to deliver a
inspection, maintenance and repair procedure
for all items consisting of two parts or more. Do
the produceres commit to this today?
Consider an update.
Rejected
require to provide inspection, maintenance and repair
procedure for all items to ensure equipment is in optimal
condition
Annex M M.8.2.3 b) Technical
spooling on and off the complete umbilical
length
Change to: spooling on and off the usable
umbilical length. Rejected
Changed to 20%, as you still may have to pull out possibly
2500m, however this is only to prove the spooling
mechanism is correctly aligned
Annex M M.1.2.4 Technicaladd reference to where the 15 tons value comes
from to determine "heavy lift operations
offshore"
RejectedWording has been modifed per other comments
Annex M
M.1.3.2,
M.1.3.3,
M.1.3.4
Editorial
will the references section numbers always
remain the same in another API document. For
example, the "API 17F, Section 5.4.2" currently
referenced in this draft could it be changed by
the API 17F committee to another section
number like 7.2 thus voiding the reference.
Rejected
As per Table M.3, these references are required for clarity.
If API 17F is revised then concideration to this document is
required.
Annex M M.2.4.2.1 Technical
Paragraph 17 last sentence states, "The MCS
shall only control the hydraulic power unit
pumps when in automatic mode." - Remove
sentence because HPU can have a CPU to run in
automatic mode and the MCS is read-back only.
When the hydraulic power unit pumps have
automatic mode capability the CPU can be
located at the HPU or MCS.Accepted
new text at end of sentence "When the hydraulic power
unit pumps have automatic mode capability the CPU can
be located at the HPU or MCS."
Annex M M.4.4.2.a Technical
statement conflicts with text in M.4.3.3
accumulator volume capacity margins.
…shall be based on the requirements for subsea
power storage as outlined in Annex M.4.3.3.Accepted
New text "subsea power generation and storage sub-
systems shall be based on the requirements for subsea
power storage as outlined in Annex M.4.3.3.; "
Annex M M.4.4.2.c Technicalfirst sentence which states "shall" conflicts with
the second sentence which allows for variations
to the first sentence.
each hydraulic function line should have dual
redundant pressure transducer… AcceptedNew Text "each hydraulic function line should have dual
redundant pressure transducers"
Annex M M.7.1 Technical
Paragraph 8, first sentence states "design shall
be according to a standard commonly accepted
by the industry." Either change statement to
"should" or call out specifically what standard is
commonly accepted by the industry.
MCS layout and HMI design should be according
to a standard commonly accepted by the
industry.
Accepted
New paragragh 8 text "Master control station layout and
human machine interface design should be according to a
standard commonly accepted by the industry. Layout and
functionality shall be optimized to reduce operational
errors, both during normal operation and during
alarm/emergency operations."
Annex MSection
M.7.1Technical
There is no mention of management of change
for SIL compliance. This should be treated the
same as any design change
Suggest adding a note on verification of SIL
compliance when changes are made to exsisting
certified SIFs. SIL rating is specific to SIF so any
changes/modification tosequence of events,
hardware elements or software code from
original certified SIF may require recertification.
Rejected
This is Management of Change and not just the SIL
compliance. Therefore should not be added to specifically
to this section. There are numerous points within the
standard to highlights that if changes are carried out then
these shall be reviewed to ensure they to don't conflict
against existing documents / qualification
Annex M M.5.3 Technical
Interface between….shall be defined in Annex F.
Annex F does not address questions concerning
air quality on rig supplied compressor air, or
quality of the el. supply. Do the system need air
drier and alternator?
Consider an update.
Rejected
Moved to WD6 Comments
This is not a comment for Annex M, but should reviewed
by Annex F to determine if valid to add. (Ask James Pate)
Annex M M
Acoustic primary control systems -- for
operaiton of the well barriers -- Need to write
into the code the acoustic telemetry as primary
Moved to WD6 Comments
need to add and cross check in the document this issue
Annex M M.1.1
Introduction Para. 3, statement "Project economics dictate
whether to choose an all-hydraulic or electro-
hydraulic system". Economics is only part of the
selection process.
Suggested Change:
Remove "Project economics dictate whether to
choose an all-hydraulic or electro-hydraulic
system"
Rejected
First sentence has been changed to the following with
comments provided.
"Multiple aspects like economics, technical solutions and
system operation dictate whether to choose an all-
hydraulic or electro-hydraulic system. "
Annex M M.1.1.1
Thru/BOP-riser intervention mode system Para. 3, "Typically electro-hydraulic…." is
unnecessary
Proposed changed: Remove paragraph
Accepted
Remove paragragh.
Annex M M.1.2.2
General
The IWOCS shall allow for flexibility and
optimization. The basic system design shall allow
for full functionality of envisioned existing
infrastructure and intervention scenarios. The
following elements shall be considered during
system engineering:
The statement 'flexibility and optimization' adds
no value.
Proposed change:
Remove first sentence
Add the following bullet points:
m) ROV interfaces
n) Material compatibility with process fluids
(NACE / ISO 15156)
Accepted
New Text for 1st Paragraph
"The IWOCS basic system design shall allow for full
functionality of envisioned existing infrastructure and
intervention scenarios. The following elements shall be
considered during system engineering:"
Also add
"l) ROV Interfaces
m) control fluid & process fluids compatibility"
Annex M M.1.2.4
Size and mobility of modules
Consideration shall be taken to avoid heavy lift
operations offshore, which typically imply lifting
loads above 15 tons.
Some units must be larger than 15 tonns, eg
Deep water umbilical reelers. Giving a difinitive
weight may cause confusion.
Proposed change:
Remove statement " which typically implies
lifitng loads above 15 tons"
Accepted
next text for last sentence:
"Heavy lift operations offshore shall be reviewed and
where practical avoided, however if they cannot be
avoided then offshore risk assessments shall be
performed."
Annex M M.1.2.12
Fail-safe philosophy
The IWOCS shall be designed to render the well
intervention packages to a fail-safe status upon
loss of power.
The definition of power need to be clarified.
Does this refer to topside electrical power?
Subsea electrical Power? Hydraulic Power?
Proposed solution:
"The IWOCS shall be designed to render the well
intervention packages to a fail-safe status uppon
loss of hydraulic power or, in an all electric
system, loss of electrical power"
Accepted
Accept in principle however it does not have to be all
electric system to be affect by loss of electrical.
Next Text:
"The IWOCS shall be designed to render the well
intervention packages to a fail-safe status upon loss of
hydraulic or electrical power and/or operator control.
Upon restoration of power and/or operator control, the
fail-safe status shall not be affected or changed."
Annex M M.1.2.13
Consideration shall be given in the design to
early detection of failure, ability to test while in
hole, and redundancy for critical components,
which cannot be designed according to this
principal.
"..ability to test" must be clarified. Please define
what tests are requrired.
Accepted
Text should not be to consider, therefore with the
comments new wording is required.
New Text "An overall objective shall be to design the
system to ensure that no single failure will cause a total
system shutdown or prevent the ability to secure the well
or force the system into an unsafe state. The system shall
have the ability to detect failure or the ability to perform
tests while in hole to determine the cause of failure, and
shall have redundancy for critical components, which
cannot be designed according to this principal."
Annex M M.2.2
General Requirements Add additional statement:
Design shall also consider environemental
conditions such as ambient temeratures, direct
sunlight, saliferous environment, etc
Rejected
This is taken into account to further sections.
Annex M M.2.4.1.2
Master control panel
...All functions related to pressure testing shall
be monitored.
This statement reads as if all system pressure
tests (seal tests, plug tests, etc) need to be
directly monitored by the MCS. Is this the
intent? If so it may be useful to define exactly
what 'pressure tests' are included. Proposed
rewording:
'All functions related to pressure testing shall be
monitored. Relevant pressure tests included ....'
Accepted
New Text:
"All functions controlled by the IWOCS shall be
monitored."
Annex M M.2.4.1.3
Remote control panel
A cable monitoring system shall be included to
notify the operator of cable failures both locally
on the remote panel and on the MCS. In case of
remote control panel cable failure the safety
function(s) shall not be activated and the master
control panel shall automatically be activated.
A potential solution to the Remote control panel
is to have a KVM extendor wherein the RCP is
only a monitor and a mouse (all 'brains' in the
MCS). In this situation, it is not pissible to raise
an alarm locally at the RCP if the comms link is
broke
Proposed solution:
Revise the clause to state that only an alarm
should be raised at the MCS.
Alternatively, if a local alarm is required, and
additional statement should be added stating
that the RCP design should not utilize a KVM
extender.
Rejected
This is a solution not a comment for the standard. The
monitoring system maybe an alarm or othe identification
Annex MM.2.4.1.6
b)
pressure discharge system shall be dimensioned
to avoid over pressure;
The term 'dimensions' is not descriptive enough.
A definitive design standard for the relief system
should be reference.
Proposed solution:
Change text to the following "pressure discharge
system shall designed i.a.w. API 520 parts 1 and
2"
Accepted
No reference required to a design standard as the design
might not be a pressure releving device, Change
dimensioned to designed. New Text
"pressure discharge system shall be designed to avoid over
pressure;"
Annex MM.2.4.1.6
d)
flanged hydrocarbon gas detector connected to
the host facility fire and gas system;
This satement is too perscriptive. The gas
detector will typically be connected to the HPU
PLC which then may be tied back to the host
facility or to the MCS and then onward to the
host facility.
Proposed change:
Revise statement to say
flanged hydrocarbon gas detector connected to
the host facility fire and gas system either
directly or via IWOCS
Accepted
new text "flanged hydrocarbon gas detector connected to
the host facility fire and gas system either directly or via
IWOCS;"
Annex MM.2.4.1.6
e)
welded connections armored glass sight level
gauge for local indication of fluid level;
The statement 'armoured glass' is not descriptive
enough. Specific specification should be
referenced.
Proposed solution: sight level guages for local
indication designed i.a.w. BS 3463, Specification
for observation and gauge glasses for pressure
vessels.
Accepted
new text "sight level gauge(s) for local indication of fluid
level shall be in accordance with BS 3463:1975,
Specification for observation and gauge glasses for
pressure vessels; "
Annex M M.2.4.2.1
If the IWOCS requires hydraulic power to
operate critical functions related to well control,
then the system shall maintain a 1-hour supply
of energized fluid, giving the operator time to
establish well barriers in the event of system
failure. The volume of the 1-hour supply shall be
based upon consumption rates to establish the
required barriers and shall take into
consideration system designed leakage. This
fluid can reside within or be distributed among
the HPU, the Surface Accumulator System,
and/or Subsea Accumulators.
The first paragraph is not descriptive enough,
specificall the statement '...system shall maintain
a 1-hour supply of energized fluid' A '1 hour
supply' is fully dependant on what operation will
be done over that hour.
The clause should be revised such that a
definitive accumulator volume is given.
Suggested proposal:
Remove the paragraphs starting with "If the
IWOCS requires hydraulic power to operate
critical functions ..." and "For last closing
functions, there shall be sufficient pressure
capacity..."
Rejected
The paragraph states "The volume of the one-hour supply
shall be based upon consumption rates to establish the
required barriers and shall take into consideration system
designed leakage" therefore the 1 hour supply allows this
operation to take place at any point.
Annex M M.2.4.2.1
Accumulators shall have sufficient capacity
between the valve actuators and connectors’
maximum and minimum operating pressures
without assistance from the hydraulic pumps,
for the following operations:
a) Lower workover riser package and connectors
through one (1) close and unlock + 25% close
and unlock margin.
b) C/WO riser or landing string high set
lubricator valves through one (1) close + 25%
close margin.
c) Surface tree valves through one (1) close /
open / close sequence + 25% close margin.
d) Lower workover riser package or landing
string valves and connectors through one (1)
close and unlock + 25% close and unlock margin.
e) Downhole package capacity shall be defined
by end user.
Statement should be added:
Quantity of accumulators shall be N+1 where N
is the number of accumulators to meet stored
accumulator volume.
Rejected
Theer is no requirements for 1 extra accumulator, if the set
to the margins stateed.
Annex M M.2.4.2.2
CIU Currently no requirements for integration with
the ESD system
Add statement:
CIU shall integrate with the ESD system as
required by the Safety Strategy; clause 4.13
Rejected
This will be defined in the safety strategy and as such can
be added to the system.
Annex M M.2.4.3.1
Surface accumulator system Please define the specifications that the surface
accumulators must adhere to.
Add statement:
Accumulators shall be designed in accordance
with ASME Boiler and Pressure Vessel Code,
Section VIII, Division 1
Accepted
add the following text
"design of accumulator shall comply with ASME Boiler and
Pressure Vessel Code, Section VIII, Division
1, and BS EN 14359 and ISO 10945, or the applicable code
or regulation which applies."
Annex M M.3.7
Safety Philosophy M3.3.4 states Fsheave,swl >Tumb,break
Equation M.2 states:
Treel,brake >Treel,slip < Fsheave,swl
<Tumb,break
These sections contractict each other.
Proposed solution:
If the philosophy is that the umbilical should
break before the sheave, then ammend equation
M.2 to be: Treel,brake >Treel,slip <Tumb,break <
Fsheave,swl
If the philosophy is that the sheave should break
before the umbilical then update section M.3.3.4
to state Fsheave,swl <Tumb,break
Accepted
ammend equation M.2 to be: Treel,brake >Treel,slip
<Tumb,break < Fsheave,swl
Annex M M.4.4.1.2
Subsea intervention control module design
g) hydraulic supply line flow should and function
line flow can be internally monitored by
flowmeters;
The specification should not have 'can'
statements as the purpose of the document is to
state the requirements not the possibilities.
Proposed change:
Removed '..and function lines flow can be
internally monitored by flowmeters'
Rejected
This is for guidance. New Text however due to error.
"hydraulic supply line flow should and function line flow
can should be internally monitored by flowmeters;"
Annex M M.4.4.2
Subsea power accumulation The section title seems incorrect. Suggested
section title:
'Subsea Hydraulic Power Generation and
Storage'
Accepted
new title "Subsea Hydraulic Power Generation and
Storage"
This change also affects figure M.1
Annex M M.4.4.2.2
Subsea power storage
d) design of accumulator shall comply with
ASME Boiler and Pressure Vessel Code, Section
VIII, Division 1, and BS 7201-1 and ISO 10945, or
the applicable code or regulation which applies;
BS 7201-1 has been superseeded by BSI BS EN
14359 + A1
Accepted
new text "design of accumulator shall comply with ASME
Boiler and Pressure Vessel Code, Section VIII, Division
1, and BS EN 14359 BS 7201-1 and ISO 10945, or the
applicable code or regulation which applies; "
Annex M M.5.3.2
Interface to C/WO riser system – thru/bop riser
intervention mode
The IWOCS shall interface with the surface tree,
lubricator valve, SSTTA, BOP spacer joint, tubing
hanger and tubing hanger running tool to
provide the necessary hydraulic control pressure
to function these equipment.
Revise statement to state 'provide the necessary
hydraulic pressure to function and monitor these
equipment'
Accepted
new text "The IWOCS shall interface with the surface tree,
lubricator valve, SSTTA, BOP spacer joint, tubing hanger
and tubing hanger running tool to provide the necessary
hydraulic control pressure to function and monitor these
equipment."
Annex M M.8.3
Pre-operational testing
A pre-operational test procedure shall be
developed
Please clarify the meaning of 'pre-operational'.
During the review some engineers read this as
test prior to initial operation, i.e. EFAT. Other
read this as a test that must be performed prior
to every operation, i.e before being deployed
subsea.
Accepted
change "Pre-Operational" to System Integration"
Annex M M.9.2
Marking
All major components of the IWOCS that meet
the requirements of this standard shall be
marked with “API 17G.”
Clarification: Can this stamp be self - certified or
do you need a third party to verify? May be
useful to clarify this point within the document. Rejected
Statement has been removed as this wil lbe dicated by the
final ratng of the standard.
New First sentence "All major components to shall be
supplied with permanent marking that includes the
following: " Annex M M.10.2 Inspection and maintenance There is no content in this section Accepted As per line 195, section 10.3 title is an error
Annex M M.10.3 General Section title a repeat Accepted The title should be deleted.
Remove the folllowing sentance as not appliable
to the functionality of a landing joint and API
Colour issue.
"A control umbilical(s) may be used to provide
hydraulic supply and electrical signal/power to
the subsea tree, SSTTA, and tubing hanger
functions. Suitable umbilical clamps shall be
installed to attach the umbilical(s) to the riser
joint at specified intervals."
delete "A control umbilical(s) may be used to
provide hydraulic supply and electrical
signal/power to the subsea tree, SSTTA, and
tubing hanger functions. Suitable umbilical
clamps shall be installed to attach the
umbilical(s) to the riser joint at specified
intervals."
Accepted