result of voting approved - home - mycommittees to review... · dnv rp b401, cathodic protection...

English Title:

Petroleum and natural gas industries -- Design and operation of subsea production systems -- Part 4: Subsea wellhead and tree equipment

French Title:

Industries du pétrole et du gaz naturel -- Conception et fonctionnement des systèmes de production immergés -- Partie 4: Équipements immergés de tête de puits et tête de production

Document reference: ISO/DIS 13628-4 Committee: ISO/TC 67/SC 4 Start date: 2006-09-28 End date: 2007-02-28 Status: Closed Voting stage: Enquiry Vote in parallel with: CEN (ISO lead) Version: 1

Result of voting

P-Members voting: 9 in favour out of 9 = 100% (requirement >= 66.66%) (P-Members having abstained are not counted in this vote.)

Member bodies voting: 0 negative votes out of 13 = 0% (requirement <= 25%) Approved

Country Member Participation Voted Argentina IRAM P Member Approval Brazil ABNT P Member Approval Canada SCC P Member Abstention China SAC O Member Approval France AFNOR P Member Approval with comments Germany DIN P Member Abstention Indonesia BSN P Member Abstention Italy UNI P Member Japan JISC Abstention Korea, Republic of KATS P Member Approval Luxembourg SEE Approval Netherlands NEN P Member Approval with comments Nigeria SON Approval Norway SN P Member Approval with comments Poland PKN P Member Approval Portugal IPQ Abstention Russian Federation GOST R O Member Approval United Kingdom BSI P Member Approval with comments USA ANSI Secretariat Approval with comments ISOCS Comment Only

Template for comments and secretariat observations Date: Document: DIS 13628-4 ISO 3166 two-letter country codes: FR – France, NL – The Netherlands, NO – Norway, US – United States,

GB – United Kingdom, ** - ISO CS

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Clause No./ Subclause No./

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Paragraph/ Figure/Table/N

ote (e.g. Table 1)

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Comment (justification for change) by the MB Proposed change by the MB Secretariat observations on each comment submitted

1 MB = Member body (enter the ISO 3166 two-letter country code, e.g. CN for China; comments from the ISO/CS editing unit are identified by **) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory.

page 1 of 120 ISO electronic balloting commenting template/version 2001-10

FR Title ed "Immergé" is currently used for the translation of "Subsea" in the french version. "Sous marin" is a better translation and should be changed in all standards of WG6.

change : "Industries du pétrole et du gaz naturel — Conception et fonctionnement des systèmes de production immergés — Partie 4: Équipements immergés de tête de puits et tête de production" by: "Industries du pétrole et du gaz naturel — Conception et fonctionnement des systèmes de production sous-marins — Partie 4: Équipements sous-marins de tête de puits et tête de production"

Accepted.

NL Ge Throughout the document when referencing clauses, subclauses and annexes from within this document the phrase "this part of ISO 13628" is constantly used. Quite often this is unnecessary.

Review the usage of this phrase, delete unnecessary usage

Noted. Redundant references were deleted, however, in most cases the deletion was not accepted as it is standard wording in ISO.

NL Ge According to ISO rules it is unnecessary to use the term “subclause”. Review the usage of "subclause" within the

document, delete unnecessary usage

The preferred phraseology is: “in accordance with Clause 3”; “according to 3.1”; “as specified in 3.1 b)”; “details as given in 3.1.1”; “see Annex B”; “the requirements given in B.2”; “see the Note in Table 2”; “see 6.6.3, Example 2”; “see 3.1, Equation (3)”. Also review the use of Annex and Clause throughout document

Accepted, changes were made to reflect this.



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NL Ge When multiple tables are referenced in one sentence, the word “Table” is only used once. Other references could therefore be construed as referring to clauses, figures or formulas at the user’s discretion

Review the document and add the word “Table” to all references to tables. Examples are in:

6.3.2

7.1.2.5.1

7.1.2.5.3

7.10.4.2.1

7.21.2.3.1

7.21.4.2.1

7.21.4.2.3

7.21.8

G.1.3

Noted but not accepted. Plural "tables" is clear in understanding.

NL Contents Ed The contents list is rather long. Amend contents list to include the top two heading levels from the main document but just the top level for the annex.

Accepted. TOC has been updated to reflect this.

NL 2 Ed ASTM D 1414 is referenced normatively within the document but not listed in clause 2 Add the following to the normative references

ASTM D 1414, Standard Test Methods for Rubber O-Rings

Accepted.

NL 2 Ed The listed item is not referenced within this document Either use or remove this reference

ISO 13628-2, Petroleum and natural gas industries

Accepted



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— Design and operation of subsea production systems — Part 2: Flexible pipe systems for subsea and marine applications

NL 2 Ed When referencing a specific clause, figure or table of another document, the reference should always be dated (as per ISO rules)

The following references should be dated

ISO 10423:2003, Petroleum and natural gas industries — Drilling and production equipment —Wellhead and tree equipment

ISO 11960:2004, Petroleum and natural gas industries — Steel pipes for use as casing or tubing for wells

ISO 13628-1:2005, Petroleum and natural gas industries — Design and operation of subsea production systems — Part 1: General requirements and recommendations

TG to decide if they want dated references. TG elects to stay with the logic of the introduction to this section which lists the normative references ; i.e., if a reference is undated, the latest version of that reference is to apply. In the situation where a more specific reference to one of these documents (i.e., a table, figure or subclause), the TG agrees that a date or edition of the document should be cited. The TG requests ISO help in finding specific references such as this and notification when one of the listed references is updated.

NL 2 Ed The listed standards are referenced in a bibliographic manner Move this reference to the bibliography

NACE Standard RP 0176, Corrosion Control of Steel Fixed Offshore Structures Associated with

Not accepted. Standards are normatively referenced in document.



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Petroleum Production

ISA-75.01.01, Flow equations for sizing control valves

NL 2 Ed The listed references are incorrectly titled Correct titles are listed below

ISO 13628-3, Petroleum and natural gas industries — Design and operation of subsea production systems — Part 3: Through flowline (TFL) systems

ISO 15156 (all parts), Petroleum and natural gas industries — Materials for use in H2S-containing environments in oil and gas production

API RP 6HT, Heat Treatment and Testing of Large Cross Section and Critical Section Components

DNV RP B401, Cathodic Protection Design

Accepted.

NL 2 Ed ISA SP75.02, Control Valve Capacity Test Procedures is referenced bibliographically

Remove this reference from clause 2 Not accepted. Standard is normatively referenced.

NL 3 Ed Some definitions are not referenced within this document Either use or remove the listed definitions 3.1.2 3.1.26 3.1.30 3.1.37 3.1.39 3.1.44

TG to decide to keep/delete TG agrees these should be removed but urges the secretariat to capture these terms, as well as those that remain, in a glossary for the subsea industry to use.



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NL 3.1.14 Ed Incorrect format for term abbreviations The abbreviation of a term should be listed below the term, see below 3.1.14 corrosion-resistant alloys

CRA

Also for 3.1.15

3.1.28

3.1.49

Accepted

NL 3.1.59 Ed The term should be "swivel flange" Delete "(type 17SV)"

TG to decide TG agrees to delete ‘(type 17SV)’ from the term. Also, the note to the definition should have ‘17’ added in front of ‘SV’.

NL 3.2 Ed The abbreviations MSS and MIL-STD are not used within this document Remove the abbreviations "MSS" and "MIL-STD"

Accepted

NL 4.1.3 Ed For readability when referencing a element in another document, the convention is to write the reference using the following format document, clause/annex, table/figure/formula

Amend "Table 2 and Annex G.2 of ISO 10423." to "ISO 10423, Table 2 and Annex G.2."

Review the format used for external references throughout document.

e.g. 4.1.4, 5.1.1.3, 5.1.3.5, 5.1.4.1, 5.5.4, e.t.c

Accepted. Note that ISO 10423 will now have to be dated.



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NL 5.1.2.2.1 1st para 1st sentence

Ed typo Change “ranges” to “range”

Accepted

NL 5.1.3.8.1 2nd para Te References to 5.1.3.2 and 5.1.3.5 appear to be incorrect. More appropriate clauses appear to be 5.1.3.3 and 5.1.3.6

Check, amend TG agrees.

NL 5.1.7.7 Table 3 Ed Rows 1 and 3 the font size of the reference to table footnote "e" is too small Increase the font size for "e"

Accepted

NL 5.1.7.7 Table 3 Ed “PMR – per manufacturing rating” is placed below the NOTE. A more suitable place would be as item “g” on the bottom of the table and to add a superscript “g” to PMR entries in the table itself (2x).

Add item “g” on the bottom of the table and to add a superscript “g” to PMR entries in the table itself (2x).

Accepted.

NL 5.4.4 1st sentence Te Annex K is about design, testing and maintenance, not about quality control which would include inspections, NDE, certificates &c that are checked and performed during the manufacturing process

Change “Quality control requirements” to “Testing requirements”

TG elects to modify the first sentence by removing the first two words (‘quality control’) & starting the sentence with ‘Requirements’.

NL 5.4.5.1 2nd para, last sent

Ed "shall not" should not be underlined Remove the underline

See also 5.4.6.2.1 last paragraph and 5.4.6.2.2 last paragraph

Accepted

NL 6.2.9 Figure 3 Ed The figure on the right is faint Make the figure darker

Accepted. Figure will be updated. TG agrees.

NL 6.2.9 Figure 4a Ed The figures are shown within a grid Remove the border from around the figures

Also for the figures in Table 10, Table 12, Table

Not Accepted. Boxes differeniate between examples.



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14, Figure D.3 and Figure D.4 NL 6.2.9 figures 4b

(cont) and figure 5

Ed Layout Centre figure across page

Accepted.

NL 6.2.11 4th sentence Te Reference to figure 1 seems incorrect. Figure 5 appears more appropriate Check, amend

TG agrees.

NL 7.1.1 Table 5 Ed The title of the table references API flanges. In the text reference is made to ISO flanges or ISO (API) flanges Change” API” to “ISO (API)”

Accepted

NL 7.1.1 6th para, 2nd sentence

Te Reference to table 3 seems incorrect. Table 5 appears more appropriate Check, amend

TG agrees & also recommends the quotation marks should be removed from the word standard in the previous line.

NL 7.1.2.1 2nd paragraph 2nd sentence

Te Reference to Table 5 is incorrect Reference should be to Table 6

Amend reference

TG agrees.

NL 7.1.2.2.2.1

Te References to Tables appear to be Incorrect First reference to Table 6 should be to Table 7

Reference to Table 8 should be to Table 9

Reference to Table 9 should be to Table 10

Second reference to Table 6 should be to Table 10

TG agrees.

NL 7.1.2.2.2.4 a) Te Reference Table 8 appears to be incorrect Reference should be to Table 9

TG agrees. Additionally, the subscript ‘L’ should be added to the variable for bore dimesion ; i.e., JL.

NL 7.1.2.2.2.4 b) Te Reference to Figure 9 appears to be incorrect Reference should be to Figure 8

TG agrees.



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NL 7.1.2.4 Table 9 Ed The figure and table notes both reference Table 7 for the dimension of 'Q' but 'Q' is not listed in Table 7 or Table 8 Check/correct reference for 'Q'

The references to ‘Q’ are in table seven. However, TG points out that tables seven, eight and nine need reformatting to make them easier to use.

NL 7.1.2.5.5 Table 14 Ed The whole of this table is on one page and there is no need for the Table 14 continuation title between the figure and the table

Delete the Table 14 continuation title Accepted.

NL 7.4 2nd para, 1st sentence

Te References to 6.2 and 6.3 appear incorrect. Expected are references to 5.2 and 5.3 Check, amend

NL 7.5.5 1st sentence Te Reference to 5.1.3.4 seems incorrect. Check, amend

NL 7.7.2.1 1st bulleted line

Te References to figures 13 and 14 appear incorrect. Expected are references to figures 11 and 12 Check, amend

NL 7.7.2.2 Te Reference to figure 11 appears incorrect. Expected is reference to figure 9 detail a Check, amend

NL 7.8.2.1 Last para Ed There is a reference to Annex L but there is no Annex L within the document Check and correct this reference.

Annex L is also referenced in clauses 7.8.2.2, 7.14.2.2, 7.16.3 and 8.5.4

NL 7.13.1.1 Last sentence

Te Reference is made to 7.20.2.5, whereas 7.20.2.6 is expected Check, amend

NL 7.16.5 Te Reference is made to 6.2, whereas 5.2 is expected Check, amend

NL 7.17.2.7 First bulleted line

Te Reference is made to 7.16.1. This appears incorrect Check, amend

NL 7.21.4.2.1 2nd Te Reference is made to table 24 and table 25. Expected is Check, amend



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sentence a reference to table 25 and table 26

NL 7.21.4.2.3 3rd para Te Reference is made to table 26. Expected is a reference to table 24 Check, amend

NL 7.21.4.2.3 4rd para Te Reference is made to table 24. Expected is a reference to table 25 Check, amend

NL 8.3.2.1 5th bulleted line

Te Reference is made to figure 10 and figure 11. Expected is a reference to figure 11 and figure 12 Check, amend. If amendment is required, prefer to

remove the reference, as it already appears in the first sentence of the clause (including 6th bulleted line)

NL 11.2 1st para Ed Typo "shall designed" should be "shall be designed"

Accepted

NL 11.3.2.2.1 Ed This clause references Figure 16 there is however no Figure 16 within this document. Expected is a reference to figure 14

Check and correct this reference.

Figure 16 is also referenced in clauses 11.3.3 b) and 11.3.4

NL 12.3 Figure 15 Ed The text in this figure is rather small Increase the figure/font size

Accepted. Figure will be updated.

NL 12.5.2 m) 5th row Ed The reference to Figure 15 should be with "PSL level (decision tree)" Place the reference to Figure 15 after "PSL level

(decision tree)"

Accepted

NL Annexes Ge The headings for the subclauses throughout the annexes appear to be indented, they should be left aligned Left align the annex subclause headings

Accepted.

NL E.2.4 Figure E.14 Ed Typo "Figures" should be "Figure"

Accepted.

NL Figure F.1 Ed The typeface used in the figure is almost illegible Change typeface


NL G.2.3 Figure G.1 Ed Typo Insert a space between "Figure" and "G.1"

Accepted.



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The figure on the left is faint Make the left figure darker


NL G.2.8 Table G.6 Ed Table G.6 is not referenced and appears to be a continuation of Table G.5 Table G.5 and Table G.6 cont should be one table

on one page

Accepted.

NL K.2.3.2 Figure K.1 Ed The figure and the figure title are on different pages Keep the figure and figure title on the same page

Accepted.

NL K.2.3.5 Figure K.2 Ed The figure and the figure title are on different pages Keep the figure and figure title on the same page

Accepted.

NL K.3.2 Ed References clause 5.3.1.2 which does not exist within the document Check docurment for correct reference

NL K.3.2 Ed References clause 5.1.3.5 appears to be wrong Check docurment for correct reference

NL Bibliography The listed items are not referenced within this document Either use or remove these references

[1] ISO 2859-1, Sampling procedures for Inspection by attributes — Part 1: Sampling plans indexed by acceptable quality level (AQL) for lot-by-lot inspection

[2] ISO 3183-1, Petroleum and natural gas industries — Steel pipe for pipelines — Technical delivery conditions — Part 1: Pipes of requirement class A

[3] ISO 11961, Petroleum and natural gas industries — Steel pipes for use as drill pipe — Specification

[10] ANSI/ASME B1.1-1989, Unified inch screw threads (UN and UNR thread form)

TG to decide if unreferenced documents should stay in or be deleted from the biblio



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[11] ANSI/ASME B1.2-1983 (R1991), Gages and gauging for unified screw threads

[12] ANSI/ASME B18.2.2-1987 (R1993), Square and hex nuts (inch series)

[15] ANSI/ISA S75.02-1988, Control Valve Capacity Test Procedure

[16] ANSI Y14.5M, Geometric tolerances

[18] ASME Boiler and Pressure Vessel Code, Section V, Non-destructive Examination, Article 5: Examination methods for materials and fabrication, paragraph T522 and T542.

[19] ASME Boiler and Pressure Vessel Code, Section VIII, Pressure Vessels, Division 1

[21] Part UG-101: Proof tests to establish maximum allowable working pressure

[22] Appendix 4: Rounded indication charts acceptance standard for radiographically determined rounded indications in welds.

[23] ASME Boiler and Pressure Vessel Code, Section IX: Welding and Brazing Qualifications

[25] ASTM A 194, Standard specification for Carbon and alloy steel nuts for bolts for high-pressure and high-temperature service



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[26] ASTM A 307, Standard specification for Carbon steel bolts and studs, 60 000 psi tensile strength

[28] ASTM A 370, Standard test methods and definitions for Mechanical testing of steel products

[29] ASTM A 388, Standard practice for Ultrasonic examination of heavy steel forgings

[31] ASTM A 609, Standard practice for Castings, carbon, low-alloy, and martensitic stainless steel, ultrasonic examination thereof

[32] ASTM E 10, Standard test methods for Brinell hardness of metallic materials

[33] ASTM E 18, Standard test methods for Rockwell hardness and Rockwell superficial hardness of metallic materials

[34] ASTM E 92, Standard test method for Vickers hardness of metallic materials

[35] ASTM E 94, Standard guide for Radiographic testing

[36] ASTM E 140, Standard hardness conversion tables for metals

[37] ASTM E 165, Standard test method for Liquid penetrant examination



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[38] ASTM E 187, Redesignated G24

[39] ASTM E 280, Standard reference Radiographics for heavy-walled (4 1/2 to 12 in (114 to 305 mm) steel castings

[40] ASTM E 428, Standard practice for Fabrication and control of steel reference blocks used in ultrasonic inspection

[41] ASTM E 446, Standard reference Radiographs for steel castings up to 2 in (51 mm) in thickness

[42] ASTM E 709, Standard practice for Magnetic particle examination

[43] ASTM E 747, Standard test method for Controlling quality of radiographic examination using wire penetrameters

[44] ISI, Handbook of control valves

[45] MSS SP-55, Quality standard for Steel castings for the valves, flanges and fittings and other piping components (visual method)

[46] MIL-STD 120, Gauge inspection

[50] SNT-TC-1A, Personnel qualification and certification in non-destructive testing

NL Bibliography Ed The listed items are referenced in a normative manner Move these references to clause 2

Accepted



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[4] ISO 8501-1, Preparation of steel substrates before application of paints and related products — Visual assessment of surface cleanliness — Part 1: Rust grades and preparation grades of uncoated steel substrates and of steel substrates after overall removal of previous coatings

[13] ANSI/ASME B31.4, Liquid Transportation Systems for Hydrocarbons, Liquid Petroleum Gas, Anhydrous Ammonia, and Alcohols

[14] ANSI/ASME B31.8, Gas Transmission and Distribution Piping Systems

[48] NACE No. 2, Near-white metal blast cleaning

[49] SSPC-SP-10, Steel Structures Painting Council — Surface Preparation — 10

NL Bibliography Ed Incorrect titles The titles should be as listed below

[5] ISO 13625, Petroleum and natural gas industries — Drilling and production equipment —Marine drilling riser couplings

[24] ASTM A 193, Standard specification for alloy-steel and stainless steel bolting materials for high-temperature service

[27] ASTM A 320, Standard specification for Alloy-steel bolting materials for low-temperature service

[30] ASTM A 453, Standard specification for high-

Accepted in principle. Correct titles based on organization's websites were used to update the incorrect titles



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temperature bolting materials, with expansion coefficients comparable to austenitic steels

NL Bibliography Ed The listed documents are referenced bibliographically within the document but not listed in the bibliography Add the listed items to the bibliography

API TR 6J1:2000, Elastomer Life Estimation Testing Procedures

ASTM D3045, Heat Aging Of Plastics Without Load

ASTM D2990, Tensile, Compressive, And Flexural Creep And Creep Rupture Of Plastics

NORSOK M-CR-710:1994, Qualification of non-metallic sealing materials and manufacturers

Underwriters Laboratories Inc., UL 746B, Standard for Polymeric Materials — Long Term Property Evaluations

Accepted.

NL

NO General Te ISO 13628-7 (Table 2) refer to ISO 13628-4 for EDP connectors, subsea WCT-BOP connectors, TRT connector and surface tree connector. ISO 13628-4 cover also tree connector and wellhead system. For extreme and accidental conditions defined in ISO 13628-7, ISO 13628-4 does not give clear requirements for these conditions. ISO 13628-4 should provide requirements. In response to this, Statoil has included Annex B in technical requirement document TR0034, see attachment.

Consider applicable parts/requirements of section 2.2 (the 2 last paragraphs), 3.3 (4th paragraph and 12th paragraph) and Annex B in TR0034 in ISO 13628-4.

(The Statoil document TR0034 is attached to the submission of these comments)

TG has elected to include the previously proposed Annex L (Performance Verification (Qualification) of Wellhead Connectors) as an informative reference to address this need. This action is taken with full recognition that resolution of comments of this annex’s implications is required ; i.e., TG will have



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to meet to resolve this.

NO General Te Qualification requirements to connectors subjected to external loads, including extreme and accidental conditions are not covered. In response to this Statoil has included qualification requirements in Annex C in TR0034, see attachment. This annex is similar to Annex L provided in a former draft DIS revision.

Include connector qualification requirements in ISO 13628-4 considering section 5.3.9 (last paragraph) and Annex C in TR0034.


See previous observation.

NO General and 5.4.

te Acceptance criteria related to hydrostatic and gas testing for qualification and FAT for equipment covered by ISO 13628-4 is unclear. Some manufactures often refer to ISO 10423 for leak rates. ISO 13628-4 should include clear and unique leak tightness requirements. E.g. what is the leak-tightness criterion for gas testing during qualification of connectors?

Consider to implement the requirements in Section 5.2 TR0034.

Noted.

NO General te No requirements are given to preload for connections, and connectors to preload. Preload is important to be maintained for cyclic loading/pressure to avoid damage which may cause failure with time, e.g. bolt fatigue and seal fretting of metallic seals.

Consider to include a new general design requirement section:

5.1.8 Preload

Connections and connectors subjected to cyclic pressure/temperature/external loading shall be preloaded. Preload shall be maintained for normal operating conditions including hydrostatic test pressure. Pressure end load shall be based on worst-case sealing diameter, i.e. leakage to the largest diameter redundant seal, unless relief is provided.

This requirement should be referred to for all

See previous observation.



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relevant connectors and components, e.g. tree connector, EDP connector, LRP connectors, bolted flanged connections. tubing hanger lockdown mechanism, tree cap, etc.

See also Tr0034 Section 2.2 ( 23rd paragraph) NO 5.1.1.1 2nd parag te It is stated that product capability is defined by

performance verification testing. The fundamental principle is the analysis/calculations shall be performed to determine capabilities (structural capacity, dimensional tolerances, etc.). The capabilities are confirmed by performance verification testing.

Qualification of capabilities shall be performed by analysis/calculations confirmed by necessary performance verification testing, see Statoil TR0034 , section 5.1( 5th paragraph, 1st sentence) and Annex C, section C.2 (1st paragraph).

TG recognizes that 5.1.1.1 requires clarification. This will be accomplished by : 1) changing the title of the section to ‘Product Capability’ ; 2) changing the first sentence to ‘Product capability is defined by the manufacturer based on analysis and testing ; more specifically :’

NO 5.1.1.2 2nd parag te Accidental load case mentioned. No design criterion is given for accidental pressure load case. Include design criterion for accidental pressure

load case.

Rejected. Clause 5 is Common System Requirements. Specific load case criteria are provided in clauses 7 through 11. Additionally, clause 12 provides a means for the purchaser to further define specific requirements. Additionally, the TG has elected to remove the word ‘accidental’ from the



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second paragraph.

NO 5.1.1.4 Product designs shall be capable of functioning with appropriate material class selected from Table 1. Material requirements a As defined in ISO 10423. In compliance with ISO 15156 b In compliance with ISO 15156. c CRA required on retained fluid wetted surfaces only; CRA cladding of low alloy or stainless steel is permitted d CRA as

te

Question: Should SDSS be used in heavy sections such as tree blocks? If this is acceptable, what are the WT limits?

Make definition consistent with ISO 10423 clause 3.1.30 and remove footnotes from Table 1.

Make clear in ISO 13628-1 clause 6 that Duplex SS are stainless steels and not CRA

Comment rejected. Definition is consistent with ISO 10423.



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defined in clause 3 of this part of ISO 13628. ISO 15156 definition of CRA does not apply General remark

te

A suitable recommendation is needed in clause 6 of ISO 13628-1.

Recommend to use HIP (?) NO 5.1.1.5 te See first general comment.

See TG response to first general comment (annex L to be included in



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document).

NO 5.1.1.5 te Leakage criteria It is noted that clause for leakage criteria (i.e. previously 5.1.1.5) has been deleted. This is not recommended Leakage criteria to environment, across a closure device and to the control system (i.e. if hydraulic) should be specified. Criteria for leakage to the environment should be a function of loading condition (i.e. normal, extreme, accidental) and operating phase (FAT, well completion, well intervention and production). Leakage criteria for closure devices may be function dependant (i.e. barrier element or flow control device).

Criteria for leakage to the environment as per attached proposal.

Leakage rates as per ISO 13628-7:2005 6.4.11.5

Comment rejected. Clause five is for common requirements of wellhead and tree systems. The clause was removed from clause five because it did not belong in that section. Leakage criteria are included clauses seven through eleven.

NO 5.1.1.5 2nd para. te Load capability Revise the 2nd para. in 5.1.5 and 1st para in

5.1.3.1

Comment rejected. Clause five is for common requirements of wellhead and tree system. Load capacities are included clauses seven through eleven.

NO 5.1.2.1.3 te The basis for the additional pressure of 17,2 MPa (2 500 psi) is unknown. Is it independent of pressure rating? Include a note giving the background for this

pressure.

Comment rejected. The option is provided to allow higher control line pressures for SCSSVs.

NO 5.1.2.2 te What temperature ratings should be specified in this

standard. Aren’t toughness requirements equal to those of other standards, so why specify them here?

Propose to specify ‘U’ as default rating

Add reference to ISO 10423 clause 4.2.2.3.

Put general toughness requirements in ISO

Comment rejected. The default temperature rating will remain ‘V’.



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13628-1 clause 6? NO 5.1.3.1 te Remove the reference to ASME for fatigue calculation.

Use the following: ISO 13628-7 and/or DnV RPC203 should be used when calculating fatigue.

Comment rejected. ASME code is not required to be used. It is cited as one that may be used.

NO 5.1.3.1 te See first general comment regarding design methods and design criteria.

Comment rejected due to lack of clarity.

NO 5.1.3.1 1st para. te ISO 13628-4 is a component standard and therefore cannot account for overall system requirements. Determination of operating limits for drilling and completion operations is therefore not possible within the scope this standard. There needs to be a distinction between components subject to riser loads and components subject normal production conditions. Primary load bearing components/structures subjected to riser loads should be designed, qualified and documented in accordance with limit state design methodology. Components subjected to normal production condition should be designed and qualified in accordance with existing requirements of ISO 13628-4

Relevant sections of the attached "proposal for primary load bearing components/structures subject to riser loads" should be included in this standard to ensure that the applicable components/structures are designed, manufactures, qualified and documented ensure the overall system requirements specified in ISO 13628-1:2005 5.4, 5.6.2.2 and 5.7.3.5.

Comment rejected. Specific requirements for installation and operating loads are defined in other clauses of the document.

NO 5.1.3.5 4th parag te Include bolting requirements given in ISO 13628-1. Replace 1st sentence with: Closure bolting shall comply with ISO 13628-1 6.4 and 6.6.1.

Comment rejected. The clause contains specific requirements regarding bolting and the desire is to follow the guidance in 10423.

NO 5.1.3.5 General te Requirements to bolting certification should be given. Include the following:

Comment rejected. Component certification is customer and application



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Bolts classified as main pressure bearing and primary structural components shall be delivered with certification to EN 10204 Type 3.1.

specific.

NO 5.1.3.5 te HRC should be consistent with other standards that

specify bolt hardness. Make consistent. Specify in ISO 13628-1 clause 6 and refer to it in the product standards.

Comment rejected. The clause contains specific requirements regarding bolting and the desire is to follow the guidance in 10423.

NO 5.1.3.6 General te Studs with rolled thread have improved fatigue life compared to bolting with cut threads. This is important for cyclic loaded bolted connections. See C.3.4 in ISO 13628-7.

Include the following:

Rolled threads should be used for bolting in cyclic loaded bolted connections.

Noted.

NO 5.1.3.7 2nd para. te Primary structural components The scope of ISO 13628-7 does not include structures. This para. should be deleted.

Delete the 2nd para.

Relevant sections of the attached "proposal for primary load bearing components/structures subject to riser loads" should be included in this standard.

Comment rejected. The guidance is that the design (safety) factors in 13628-7 should be used without regard to whether a structural component is involved.

NO 5.1.4.7 te Whole clause is superfluous and is not required

Refer to ISO 13828-1 clause 6. Comment rejected. TG considers coatings necessary for product design.


Refer to ISO 13828-1 clause 6. Comment rejected. TG considers cathodic protection necessary for product design.



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NO 5.1.7.1 Last sent te Annex M in a previous draft version of ISO/DIS 13628-4 is not found in this version.

Include Annex M. The guidance provided in Annex M is very important when planning performance verification testing.

Noted. Annex M has been moved to API RP 17N.

NO 5.1.7.2 1st sent

te For PVT to be representative to the produced items it is necessary for the PVT to be carried out under worst case dimensional tolerance case as specified in design. Otherwise the dimensional tolerances used in PVT must instruct the allowable tolerances in production.

Consider requirement from Statoil TR0034 section 5.1 (4th last paragraph)

“The product tolerances shall be in accordance with ISO 10423 F.1.4.3. The worst-case conditions for dimensional tolerances shall be tested.”

Comment accepted in principle. TG will add the following from ISO 10423 F.1.4.3 : ‘The actual dimensions of equpiment subjected to validation testing shall be within the allowable tolerance range for dimensions specified for normal production equipment. Worst-case conditions for dimensional tolerances should be addressed by the manufacturer, giving consideration to concerns such as sealing and mechanical functioning.

NO 5.1.7.3 2nd parag te It is stated that manufacturers can substitute gas for some of the verification testing. Remove the 1st sentence in 2nd paragraph.

Comment rejected. TG considers that option to be useful.

NO 5.1.7.7 Table 3 ed The footnote in the table should re-labelled due to the deletion annex L (i.e. footnote c has been deleted). Re-label a), b), c) d)

Accepted.

NO 5.1.7.7 Table 3 te If annex L is reinstated it is recommend that the extent of qualification for flow line connectors is limited to "normal" operating conditions only. Flow line connectors are not subject to extreme and accidental loads. Full compliance with annex L will inflict unnecessary qualification costs.

"Flowline connectors shall be qualified in accordance with Annex L for normal operating conditions only"

Noted.



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NO 5.2.1 te Reference to material requirements in ISO 13628-1 and ISO 13628-7 is missing. Include these references. First sentence:

Material and corrosion protection shall confirm to ISO 13628-1, ISO 13628-7 and ISO 10423.

Comment rejected. Material requirements are outlined as complying with those in ISO 10423.

NO 5.2.2 2nd parag te For pressure containing and primary load bearing components mechanical test samples shall represent the final delivery performance of the material. This is normally done by extracting test samples from prolongations. Experience has shown that QTC's do not provide reliable properties, hence, remove acceptance of QTP's for these components.

Include:

"Material testing shall be performed by integral test specimens from a prolongation of the actual material, a sacrificial component, or equivalent subject to the same heat treatment and deformation, and shall represent the material properties after final forming and heat treatment. Separate test coupons are only permitted when component shape makes the prolongation un-representative of the component/test location, and when full traceability is ensured. Test specimens shall in general be taken ¼ thicknesses from the original heat treated surface in the principal (main) stress distribution direction. All mechanical testing specimens shall be machined from the same test material."

This should be updated for all section referring to QTC's for pressure containing and primary load bearing components, e.g. 7.2, 7.4, 7.8.3.9, 7.10.2.1.4, 7.10.3, 7.11.2.3, 7.13.4, 7.22.3 and 9.3.

Comment rejected. However, the current wording in the 2nd paragraph will be changed to ‘For pressure containing and high load bearing forged material, forging practices, heat treatment and test coupon (QTC or prolongation) requirements should be in accordance with API RP 6HT. In addition, the test coupon shall accompany the material it qualifies through all thermal processing.’

NO 5.2.2 te Whole clause is superfluous and is not required

Refer to ISO 13828-1 clause 6. Note: discuss QTC requirements to be put in clause 6.

Comment rejected (see above).



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Refer to ISO 13828-1 clause 6. Comment rejected. However, TG votes to add the following to 5.2.1 : ‘Refer to ISO 13628-1, Clause 6 for further guidance on material usage in subsea environments.’

NO 5.3.1 te It is stated “PSL2 and PSL3”

Should PSL2 be excluded completely? This should be “PSL2 or PSL3”.

Comment rejected.

NO 5.3.2 te Need to define “critical welds”.

Add to definitions Comment rejected. The term is used in a consistent fashion only in this section & Annex K (Design & Testing of Equipment for Lifting).

NO 5.4.2 te Is the reference to ISO 11960-2 correct?

Look up 11960-2 11960-2 not referenced Comment rejected. Secretariat is correct ; the document is not referenced.

NO 5.4.3 te “Critical welds” shall meet PSL3 requirements except for

volumetric NDE. Clarify volumetric NDE on “critical welds” TG will add ‘with the exception of volumetric NDE.’

NO 5.4.8 te Whole clause is superfluous and is not required

Refer to ISO 13828-1 clause 6. Comment rejected.

NO 5.6.2 te Whole clause is superfluous and belongs in ISO 13628-1

clause 6. Refer to ISO 13828-1 clause 6. Comment rejected.



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NO 6.0 General ed It is noted that this section has been become a separate clause compared with previous revisions. This change is detracts from the Design requirements specified in 5.1 and 5.1.3. It is stated in 6.1.1.1 that this subclause is applicable for subsea tree equipment specified in Clause 7, i.e. it is not applicable to wellhead, clause 8.0. Therefore all items in clause 6.0 should be included together with clause 7.0 as per previous revisions

It is recommended that of this clause is incorporated into the clause for "Specific requirements- Subsea tree related equipment and sub-assemblies" as per previous revisions of this standard.

TG notes the comment. Furthermore, the TG recognizes the title of the clause (‘Design’) is misleading and voted to change it to ‘General Design Requirements for Subsea Trees and Tubing Hangers.’ Additionally, the TG voted to change the first sentence in 6.1.1 to ‘Clause 6 provides specific requirements for the equipment covered in clauses 7 and 9. Also, the TG agreed that ‘subclause’ at the end of the third sentence be changed to ‘clause 6’. Finally, the TG agreed that clause 6.1.2 (‘Requirements’) & its first sentence should be deleted while the second sentence of the existing 6.1.2 should be modified as follows and added to clause 6.1.1 (‘Equipment used in the assembly of the subsea tree which is not covered in clause 6, 7 and 9 shall comply with



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the purchaser's/manufacturer's written specifications.’). The document needs repaginating to reflect these changes and the TG leaves that to the secretariat.

NO 6.1.7 General Ed Safe job analysis should be performed before any pressure testing and load testing is performed. Safe job analysis should be performed before any

pressure and load testing are performed.

TG accepts the change and asks that the secretariat add it as the first item on the list in 6.1.7.

NO 7.5 te This clause and its sub-clauses 7.5.1, 7.5. and 7.5.3

belong in ISO 13628-1 clause 6 Refer to ISO 13828-1 clause 6. Comment rejected. The TG also notes that this guidance is not included in 13628-1.

NO 7.6.3.1 te Whole clause is superfluous and belongs in ISO 13628-1

clause 6. Refer to ISO 13828-1 clause 6. Noted.

NO 7.8.3.4 Te The self-locking requirement is general for all pressure containing and primary load bearing connector and locking mechanism. E.g. TH locking mechanism, tree cap, tree running tool, Collett (finger) type connectors, etc. Plugs? Instead of repeating this requirement, include reference to general requirements for each applicable connector/locking mechanism.

Include new general section, e.g.

5.1.8 Self locking requirements

Connectors and locking mechanism shall be designed to prevent release due to loss of hydraulic locking pressure. This may be achieved by the connector self-locking mechanism (such as flat-to-flat locking segment design) or backed up using a mechanical locking device or other means. The mechanical locking device design shall ensure lock with zero friction and unfavourable dimensional tolerances of the locking mechanism.

TG does not agree with moving the guidance contained in this section. However, the TG does want to add this modification of member’s last sentence to the end of clause 7.8.3.4 ‘The connector and mechanical locking device design shall ensure lock with worst-case dimensional tolerances of the locking mechanism.’ Additionally, the TG voted



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Update each applicable section, e.g. 7.8.3.4, 7.13.3,.7, 7.21.5.2

Se also Statoil TR0034, section 3.4.1 (5th paragraph), section 3.4.2 (5th paragraph), 3.5.6 item 11 and annex C, section C.4 (1st paragraph).

to change the word ‘may’ in the second sentence to ‘shall’.

NO 7.20.2.6 1st par Te Leaking small bore tubing not part of the well barrier envelope will have an adversely effect on the XT`s ability to continue production. It is therefore important to impose requirements to all small bore piping that ensures that the XT reliability in production is as high as possible. Focus should be placed on all connections and connections of small bore piping.

Consider including requirements from Statoil TR0034 section 2.2 ( paragraph 31)

“Fittings with metal-to-metal seals shall be used for all types of control lines. Welded joints are the only acceptable method of connection between two or more lines. I.e. no intermediate fitting shall be used. For bulkhead connections and connections to components where welding is not feasible, fittings with anti-vibration gland shall be used.”

Noted.

NO 9.2.6 General te No details for qualifications of Tubing Hanger plugs (crown plugs in table 4b) is provided. This is a crucial well barrier element during production from a HXT and a variety of qualification approaches/methods has been used historically. Statoil has over the years harmonised and detailed out requirements for design and qualification of these plugs. This method has been in use since 2002.

Include requirements from Statoil document TR0034, section 3.4.3, 3.4.3.1, 5.1, 5.2, 5.2.1, 5.2.2 and 5.3.11


TG voted to accomodate this comment with the actions listed below. First, change the wording at the end of this clause from ‘table 4’ to ‘tables 3 and 4’. Second, add the following new clause :



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‘ 7.13.5.2 Performance Verification Testing - Performance verification testing of the tree cap shall comply with subclause 5.1.7. In addition, the tree cap lockdown shall be tested to a minimum of 1,5 × RWP from below and from above to 1,0 × RWP. Where access devices (e.g. poppet, shuttle, sliding sleeve, etc.) and chemical injection stab barriers are incorporated into the design, these shall meet the design performance qualification requirements as shown in Table 3.’ Also, the following should be added to ‘Subsea Tubing Hanger’ in the ‘Component’ column of Table 3: , HXT internal tree caps and crown plugs.’ Note that the document will require repaginating.

NO Annex G G.1.3 te For flanges located in the primary load bearing components subject to riser loads, these requirements are not considered to be sufficient. For dynamic applications there shall be sufficient flange preload to resist flange separation and bolt fatigue.

It is recommended to include the following.

For flanges located in the primary load bearing components subject to riser loads, bolt preload should comply with ISO 13628-7:2005 Annex G

Comment rejected. This issue is addressed in clauses 5.1.3.5 & 5.1.3.6.



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US Entire document

Technical

There are 70 uses of the word "should" in the document. Often informational statements and recommendations ("should") are intermixed with technical requirements ("shall"). This makes the standard very difficult to use. It is not clear what is a technical requirement and what is a suggestion or information only. A "should" statement bracketed by two "shall" statements implies that all three are requirements. This will also make the standard very difficult to audit to when used by API as a product specification. If this is published in it's present form, the subcommittee and task group will receive a large volume of requests for clarification or interpretation, which should be avoided and can be avoided with a little more work.

Return the document to the work group for additional work, with instruction to:

(a) put informational data and recommendations into informational annexes as much as possible.

(b) determine whether recommended practices ("shoulds") are now or should be included in 13628-1, which is a informational document/recommended practice.

(c) consider color-coding the standard for auditability prior to balloting as an FDIS.

Noted.

US 5.1.2.1.6: Hydraulically controlled components

Technical

Clause 5.1.2.1.6 implies that excursions to 1.1 X RWP are part of the design criteria for hydraulically controlled components. ISO 13628-6 has determined that the relief valves shall be adjusted to the system Design Pressure DP. This could cause topside relief valves to open under occasional pressure increases, as described in ISO 13628-4.

To align ISO 13628-6, section 5.4.22.1 “Pressure Ratings – General” with ISO 13628-4 DIS it should be stated that the Design Pressure DP (ISO 13628-6), where the topside HPU relief valves will be activated, is equal to 1.1 x Rated Working Pressure RWP (ISO 13628-4). This is necessary to stop the topside relief valves to open under occasional pressure increases, as indicated in ISO 13628-4.

Noted. This issue will be referred to the 17/13628 leadership for resolution of the design vs. working pressure debate.

US 7.20.2.7: Electrical Connectors

Technical

7.20.2.7 states:“…The retrievable half of conductive type electrical connectors should contain seals, primary compensation chambers, penetrators, springs, etc. The design of the non-retrievable half shall consider the effect of corrosion, calcareous growth, cathodic protection etc. …” For standard designs, if the seals and penetrators are in the retrieveable half, the pins are left in the non-retrieveable half.

The standard should not dictate this type of design detail for electrical connectors. This sentence should be deleted, leaving the design and protection of the connector components to the experts and allowing for different designs and technology evolution.

Comment rejected. With the exception of a requirement preventing water ingress, the clause is not prescriptive.



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Connector suppliers ODI and Tronic do not recommend this approach because if the pins of the mating connector are left exposed subsea, they will be destroyed in a very short time. Even if unpowered, the cumulative seawater exposure life of the pins is only a few hours. In all cases the male parts need to be protected against ambient influences by means of protective covers. The male connector itself will not be able to protect it self under the current available main designs on the market.

US 7.20.6: Connector plate marking

Technical

7.20.6 states: “… Its PN and the PN of the other half to be stated on the plates… … E.g. PN1 TO MATE WITH PN2 …”. 7.20.6 states: “… Rated operating pressure for each path passing through the connector plate assembly E.g. 6 x 20.7 MPa (3000 PSI) – Path 1through 6 …” This amount of marking on the connector plate is unreasonable and unfeasible and will be neither visible or used in service.

This information should not be provided on the plate itself but in the related documentation only.

Comment accepted. TG voted to replace the current wording with the following. Each connector plate shall be permanently marked with the following minimum information. a) Its part number; and,

b) Path designation numbers or letters identifying each path/connector.

All part numbers, path designations, operating pressures of each path and other pertinent information should be included in the design



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documentation.

US 1.2.a) Technical

"- control module pod running, retrieval and testing tools" is listed in the Scope, but is not covered in the document. Annex H covers only wellhead running and test tools.

Delete last line of page 1: "- control module pod running, retrieval and testing tools"

US 1.2.f) Technical

"- intervention equipment" is listed in the Scope, but there is only one line in the document, in 7.19.1.5, which refers to ISO 13628 Parts 8 and 9. So invention equipment is NOT in the scope of DIS 13628-4.

Delete "- intervention equipment" from clause 1.2.f) and delete and Clause 7.19.1.5.

US 1.3 Technical

Clause 1.3 is "Equipment which is beyond the scope of this part of ISO 13628..." The last item in 1.3, page 3, says, "equipment not mentioned by specific definition or requirementss shall be governed with regard to pressure testing by the passage or zone where iti s located and the balance of the requirements by manufacturer's specifications. This is absurd. This statement in effect attempts to give requirements for equipment which is, by definition in the clause, outside the scope of the standard. It certainly is not necessary for this document to state what is required of manufacturers of equipment that is stated to be outside the scope of the document. EIther the equipment is in the scope of this part of 13628 or it isn't, it can't be made both with a statement like this. Pressure testing requirements cannot be imposed on undefined equipment unilaterally.

Delete the last line of 1.3.

US 2: Normative references

Technical

API RP 6HT is listed as a normative reference. This Recommended Practice may be of some value to designers and manufacturers of subsea tree equipment who do not know how to address metallurgical properties and heat treatment response of materials, but it is unnecessarily restrictive for companies that do have the

Delete API RP 6HT as a normative reference and include it only in the Bibliography.



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technical expertise to competently design and manufacture large cross section equipment.

US 3.1.2 , 3.1.37, 3.1.39, 3.1.44, 3.1.52

Technical

We could not find any use of the terms "Backlash (mechanical hystersis)," "other padeyes," "Maximum design torque," "overstepping," or "reverse flow" in the document.

Delete 3.1.2, 3.1.37, 3.1.39, 3.1.44, and 3.1.52.

US 3.1.10 Editorial

Defined term is "choke assembly," but only term used in document is "choke." Delete "assembly."

US 3.2 Editorial

the abbreviations, "MIL-STD" and "MSS" are not used in the standard, only in the Bibliography. As organization names not used for referenced standards, including these in 3.2 is unnecessary.

Delete "MIL-STD" and "MSS" Accepted.

US 4.1.3, etc. Editorial

Clause 4.1.3 references "Annex G or ISO 10423." It is unwise to reference a specific annex, clause, figure, or table in a referenced standard, as that will likely change in future revisions of the referenced standard, creating a constant process of catch-up revisions of 13628-4. There are many other such references to 10423 in the DIS, and this comment applies to all.

Change the last sentence of 4.1.2 to say only, "Classifications are listed in Table 2 and ISO 10423." Make similar changes to other references to 10423 throughout the document.

US 5.1.1.4: Materials, Table 1 - Materials requiremen

Technical

Table 1, footnote (b) cannot be complied with for the latest edition of ISO 15156. "Compliance with ISO 15156" now depends on fluid conditions as well as alloy choice and metallurgical treatment and properties. Annex O of API 6A 19th edition attempts to address this problem with changes to this table and additional text. ISO 10423 is under revision to consider similar changes.

Either add the revisions from API 6A Annex O or change footnote (b) in Table 1 to read: "in compliance with ISO 15156 at specified service conditions."

US 5.1.5 Design documentation

Editorial

The third line of 5.1.5 states: "Design verification requirements shall include, but not be limited to,...ISO standard requirements, and other pertinent requirements upon which the design is to be based." (1)There are ISO standards, which must be referenced by

Delete "ISO standard requirements, and other pertinent requirements upon which the design is to be based."



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number, and there are requirements in ISO standards, but the phrase, "ISO standard requirements," either has no meaning or means every design requirement in every ISO standard published. Either way, this won't work. (2)The phrase "include, but not be limited to," and the phrase "other pertinent requirements" are completely redundant.

US 5.2.2 Technical

5.2.2 uses the undefined term, "high load bearing." Delete "high load bearing" or come up with a technical definition, such as xx% of minimum yield or tensile or compressive strength.

US 5.3.2: Structural components

Technical

Clause 5.3.2 requires treating weld locations where the weld exceeds 50% of weld or base material yield strength the same as pressure containing welds, which could include padeye welds. Pressure containing welds must be full penetration welds. Not all padeye welds can be designed as full penetration welds. PSL 3 welding requirements in ISO 10423 are not written for structural welds and the quality requirements and weld qualification requirements of ISO 10423 PSL 3 are not always applicable to structural welds, whether "critical" or not.

Return document to work group with instruction to rework 5.3.2 with realistic requirements tailored to structural welds, not pressure containing welds.

US 5.3.3 and 7.8.3.5

Technical

(1) 5.3.3 and 7.8.3.5 refer to corrosion-resistant inlay of seal surface and require compliance with ISO 10423. ISO 10423 does not address inlay of seal surfaces except for API 6A ring grooves. (2) 7.8.3.5 states "Inlays are not required if the base metal is compatible with well fluids, seawater, etc. if the material is a corrosion resistant alloy." There is either one too many "ifs" in this sentence or some words or punctuation or missing.

(1) Return the document to the work group with instructions to decide whether inlays/overlays of seal surfaces other than ring grooves are to be treated as "weld metal overlays" in ISO 10423 or as "CRA weld metal overlays" in ISO 10423, or treated in some other manner.

(2) revise the sentence to read, "...with well fluids, seawater, etc., i.e., if the material is a CRA."



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US 7.10.4.2.3.b Editorial

FROM:

…that the seals were not damaged buy the high pressure test.

TO:

…that the seals were not damaged by the high pressure test.

Accepted.

US 5.1.2.3.2 Other states it is the purchasers responsibility to specify materials to be used in construction this cannot be right as it is the vendor who is responsible for supplying goods fit for purpose I believe this should be covered as follows ,the purchaser to supply the vendor with full details of produced fluids etc,the vendor to appraise this info and recommend to purchaser the material considered fit for purpose, the customer reviews vendor recommendation and ammends or concurs selection in clarification meetings

US 5.4.7 Other wording should have "or less" after 0.9 and not after RWP

US 6.4 Other Marking on block OK but may not be readily accessible when in assembly. Recommend markings should be repeated somewhere on outer frame where they are easily accessed

US 7.18.2.2.3 Other under functional requirements add tree can be removed and replaced without damage to critical mating components e.g. flowbase

US 8.3.3 Other If I was using an orientable PGB I would want to interface it with the housing to ensure fit and function



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US 8.5.2.2 Other Top connection should be as specified by the purchaser not the vendor

US 9.4.22 Editorial

Each bore should be tested individually to prove there is no intercommunication between bores

US 1.1 Editorial

Horizontal subsea trees are practically the standard for current subsea developments. Should the requirements for these trees not be addressed in a more formal way in this document?

Remove statement that horizontal trees are included as an informative reference only, and update the entire document where necessary to provide correct technical guidance.

US 1.2.a Editorial

Should this be “Tree connectors and tubing heads”, as per 7.8 of the document? Tubing hangers are covered in 1.2.e.

Remove tubing hangers from first line of 1.2.a. and replace with tubing heads, as per 7.8

US 3.1.17 Editorial

The definition of “downstream” should be relative to it’s pressure source, which may not necessarily be an oil/gas reservoir, as is suggested by the word choice. Downstream would imply something different for a water injection system.

Consider replacing “reservoir” with “pressure source” to avoid confusion.

US 3.1.48 Other As in 3.1.47, provide examples of pressure controlling parts to eliminate confusion / provide clarity. Provide examples of pressure controlling parts.

US 3.1.54 Editorial

Is there a strong need to define BOP for subsea use, already included in the abbreviations of 3.2 Strike reference to subsea BOP.

Not Accepted. Subsea BOP is different than BOP.

US 3.1.66 Editorial

The definition of “upstream” is very unclear here, and should also be used to describe position or flow relative to a pressure source, not the “reservoir” reference.

Consider replacing “reservoir” with “pressure source”. Also, description is unclear. Does it describe flow, or a relative position, such as “upstream” side of a gate valve vs. “downstream” side?

US All Technical

All comments identified are included in the ISO template supplied with the DIS fact attachemnt. Comment template has been e-mailed to Jonathan Jordan 2/14/07, same



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date as this ballot's filling.

US Editorial

A table (e-mailed separately) highlights current wording and proposed wording with specific editorial word changes are in bold font. These changes address one or more of the following concerns: 1. NORSOK M-710 needs to be listed the same way as is found in the 13628-1 amendment 2. Several references to “tubing spools” need to be renamed as “tubing heads” to be consistent with other sections of 13628-4 3. The text in subclause 6.2.9 is inconsistent with figures 4a and 4b. The text needs to be reworded to match the figures 4. Tables 17a, 17b, and 17c are slightly inconsistent with the current wording in 10423; specifically in the area of hydrostatic blow down tests for the valve gate/seat mechanism. The requirement is missing from 17a and 17b; and is listed as three times in 17c, which should read two times. 5. Since Annex L and M were removed just before publishing the DIS, there are several references to the two annexes which need to be reworded or removed from the text 6. FMC would like to reinstate Annex L for qualification testing of subsea connectors Again, the table with proposed changes will be forwarded to API by separate e-mail to be attached to the API “yes with comments” balloting process.

the table with proposed changes will be forwarded to jonathan jordan and andy radford of API by separate e-mail to be attached to the API “yes with comments” balloting process.



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US Entire Document

Other Comment register sent to Andy Radford on 1-13-2006 Review comments.

US Editorial

As per discussions in the SC17 meetings, rules for design, testing and marking of padeyes and lifting equipment should only be present if there are requirements over and above those outlined in API RP 17A.

Add references to 17A only. If 17A does not adequately address padeyes and lifting, then perhaps 17A should be ammended instead of placing this information into 17D.

As mentioned, this has been brought up in the SC17 meetings so, as long as the TG chair and group address this to their satisfaction, we would abide by whatever course of action is chosen.

US Technical

Vetco Comments are consolidated onto the API Comments Word document template. This file will be sent today (12 Feb 2007) to Shail Ghaey at API. Vetco comments ISO 13628-4.doc

US Entire Document

Technical

Several comments from AWHEM are being provided separately in the ISO member body comment template directly to Jonathan Jordan and Andy Radford.

US 3.1.36 Technical

Additional term and definition needed for a jumper which could also be connected to the tree for which a change requested for clause 7.18.1 has been submitted.

Add term and definition after clause 3.1.36

Jumper which extends between two subsea components such as the tree and manifold, tree and flowline end termination of a flowline, etc. and is connected to the two components using subsea connectors with metal-to-metal seals for piping connections.

US 3.1.38 Techn Additional term and definition needed for a manifold Add term and definition after clause 3.1.38



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ical Separate structural framework including piping, valves, fittings, instruments, controls, tubing, etc. used to collect production from multiple subsea wells and can direct the flow from individual wells to different flowlines connected to this framework.

US Section 4.1.4, Table 3 and 2nd sentence in 4.1.4

Technical

13628-4 Table 1 reflects content of table 3 in the regional annex O of API 6A not table 3 of main body. Text of 4.1.4 references "as defined in Table 3 ISO 10423". There is a difference in the notes of the tables (last two notes). Additionally 5.1.2.3.2 refers to Table 1 in 13628-4 instead of back to 10423.

Recommend removing reference to "Table 3 IS0 10423" and replacing it with "Table 1".

US Section 4.1.4, Proposed new section

Technical

Equipment is required to identify the allowable level of H2S. No guidance is provided on how marking should be done as 13638-4 does not refer back to annex O in API 6A. There is potential for confusion since API units are PSI and ISO units are MPa.

Add Section 4.2.3.2 from annex O in API 6A as a new section 4.1.3.1 "Sour Service Designation and Marking"

Note annex O marking is for psia where as standard units for ISO are MPa. This will need to be addressed to avoid confusion.

US Section 4.2, paragraph 2/Sentence 3

Editorial

Word "assemly" is incorrectly spelled Correct spelling is "assembly"

Accepted.

US Section 5.1.1.3, Paragraph 1

Technical

Temperature rating classification/rating information needs to reword to clarify as follows. In general equipment/components can not have both a "temperature" class and "temperature rating" Sub clause 4.1.3 should contain information for "temperature classification" Clause should be modified to remove need to use terms for class and rating. Currently temperature class and temperature rating are defined differently in the document. For consistency with the rest of the document temperature class is based on

Change clauses to read as follows:

4.1.3 Temperature classifications

Temperature classifications (ratings) indicate temperature ranges, from minimum to maximum temperatures, expressed in degrees Celsius (°C) with equivalent degrees Fahrenheit (°F) given in parentheses, for which equipment or components



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service temperatures not ambient/well fluid temperature. Sub Clause 5.1.1.3 should contain information on validation of the temperature classifications. Remove distinction between temperature class and temperature rating. This needs to be done because it is to confusing to describe how to design, mark, test and manufacture equipment that has both a temperature class and temperature rating. Sub clause 5.1.2.2.1 should contain requirements for equipment design in relation to temperature classes (rating). Change clause to allow different temperature classes with in an assembly. If the isolated components with in an assembly are exposed to temperatures more extreme than the assembly as a whole then these components must be designed, tested and marked for the appropriate temperature class. Remove text related to "Transitional low temperature J-T effects. There is not sufficient guidance provided on how to evaluate, design and manufacture the options. The user is responsible for evaluating and specifying requirements if exposed to transitional temperatures outside of the temperature class. Charpy requirements should be included on a) and c). 7.21.2.2.4 Temperature Rating (Chokes) second sentence appears to be in conflict with the rest of the clause and sub clause 5.1.2.2. For consistency choke ratings should be based on the same methodology as other equipment. This methodology is stated in 5.1.1.3 and 5.1.2.2.

will experience in service. Classifications are listed in Table 2 and Annex G.2 of ISO 10423.

5.1.1.3 Thermal integrity

Product designs shall be capable of functioning throughout the temperature class for which the product is rated. Product designs shall be rated and qualified for the maximum and minimum operating temperatures that they will experience in service. Operating temperatures are not necessarily the maximum or minimum wellbore fluid temperature.

5.1.2.2 Temperature ratings

5.1.2.2.1 Standard operating temperature rating

Equipment and components covered by this part of ISO 13628 shall be designed and rated to operate throughout a temperature class in accordance with Table 2 and Annex G.2 of ISO 10423. The minimum classification for and the subsea system as described by ISO 13268-4 shall be temperature classification V 2 °C to 121 °C (35 °F to 250 °F). When impact toughness is required of materials (PSL3 and PSL 3G), the minimum classification for pressure-containing and pressure-controlling materials should be temperature classification U -18 °C to 121 ° (0 °F to 250 °F).



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US Section

5.1.1.3 (Cont.), Paragraph 1

Technical

Clause 5.1.2.2, 5.1.2.2.1, 5.1.2.2.2, 5.1.2.2.4, 6.1.1.6, 6.3, 7.1.7, 7.21.2.2.2, 7.21.2.2.4, 7.21.3.2.1, 7.21.3.2.4, 7.21.3.2.5, Table 25, Table 26, Table 27, 10.1.2.6, 12.3. These clauses refer to the term "temperature rating" rather than "temperature class" Editorially changes should be made to reflect Temperature class where appropriate, such as marking.

Equipment component s may have temperature class exceeding the temperature class of the assembly. When specified for isolated operating conditions, equipment components shall be specified with appropriate temperature class. Effects such as seawater cooling, Joule-Thompson (J-T) cooling effects, imposed flowline heating, or heat retention (insulation) effects must be considered. Thermal analysis can be used to establish component temperature operating requirements. Annex G of ISO 10423 provides guidelines for design and rating of equipment for use at elevated temperatures.

Consideration should be given to equipment operation due to transitional low temperature effects on choke bodies and associated downstream components when subject to J-T cooling effects due to extreme gas pressure differentials.

Transitional low temperature effects associated with J-T cooling and well start up conditions may be addressed by the user in one or more of the following alternate methods.

a) Component performance verification to the required minimum temperature as specified in subclause 5.1.7. combined with material Charpy V-notch qualification at or below the minimum transitional operating temperature in accordance



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with the requirements in subclause 4.2

b) Component performance verification to the standard operating temperature range combined with material Charpy V-notch qualification at or below the minimum transitional operating temperature in accordance with the requirements in subclause 4.2.

US Section 5.1.1.3 (Cont.), paragraph 1

Technical

c) Component performance verification to the standard operating temperature range combined with supporting material documentation supporting suitability for operation at the transitional temperature range. Material Charpy V-notch qualification is at or below the minimum transitional operating temperature in accordance with the requirements in subclause 4.2

5.1.2.2.2 Standard operating temperature rating adjusted for seawater cooling

If the manufacturer shows through analysis or testing that certain equipment on subsea wellhead, mudline suspension, and tree assemblies, such as valve and choke actuators, will not exceed 66 °C (35 °F to 150 °F) when operated subsea with a retained fluid at least 121 °C (250 °F), then this equipment may be designed and rated to operate throughout a temperature range of 2 °C to 66 °C (35 °F to 150 °F).

Conversely, subsea components and equipment



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which are thermally shielded from sea water by insulating materials must demonstrate that they operate within temperature range of the designated temperature classification.

5.1.2.2.3 Temperature design considerations

The design should take into account the effects of temperature gradients and cycles on the metallic and non-metallic parts of the equipment.

US Section 5.1.1.3 (Cont.), paragraph 1

Technical

5.1.2.2.4 Test/storage temperature considerations

Pre-deployment testing at the surface may be conducted at lower environmental temperatures than the system rating as specified by the manufacturer. Product qualification does not need to be performed at the pre-deployment testing temperature.

If subsea equipment is to be stored or tested on the surface at temperatures outside of its temperature rating, then the manufacturer should be contacted to determine if special storage or surface testing procedures are recommended. Manufacturers shall document any such special storage or surface testing considerations.

7.21.2.2.4 Temperature rating

Subsea chokes shall be designed for the temperature class specified in subclause 5.1.1.3 and 5.1.2.2.



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Clause 5.1.2.2, 5.1.2.2.1, 5.1.2.2.2, 5.1.2.2.4, 6.1.1.6, 6.3, 7.1.7, 7.21.2.2.2, 7.21.2.2.4, 7.21.3.2.1, 7.21.3.2.4, 7.21.3.2.5, Table 25, Table 26, Table 27, 10.1.2.6, 12.3. Change temperature rating to temperature class where appropriate."

US Section 5.1.1.2 & 5.1.5, Paragraph 2

Technical

Clause 5.1.1.2 defines hydraulic leaks as an accidental load but does on define what the design and performance criteria are for the equipment. It is unclear what the technical basis for allowing hydraulic leaks (i.e. SCSSV passages through the tubing hanger) to exceed the rating of the other equipment. In 1st ed of 17D tubing hanger spools (907.1b) and valve blocks (908.2a) required that the equipment rating shall be equal or grater than the rating of the SCSSV. In the current document tubing heads, stabs and valve blocks pressure ratings may be less than the SCSSV line rating if relief is provided. Operationally even if relief is provided the RWP of the equipment could still be exceeded. For concentric vertical trees the AMV or tubing head annulus valve may be exposed to the SCSSV pressure but is not addressed in the document. It is recommended that the when relief is provided the first barrier to the hydraulic leak / accidental load shall be designed the stress criteria of clause 5. Additionally, seals and valves designs shall be validated according to clause 5.17.

Change 5.1.1.2 Pressure integrity from"

"Product designs shall be capable of withstanding rated working pressure at rated temperature without deformation to the extent that any other performance requirement is not met, providing stress criteria are not exceeded.

Product designs shall consider a hydraulic leak as an accidental load case if the leak has the potential to be trapped in an enclosed space."

To

Product designs shall be capable of withstanding rated working pressure at rated temperature without deformation to the extent that any other performance requirement is not met, providing stress criteria are not exceeded.

Product designs shall consider a hydraulic leak as an accidental load case if the leak has the potential to be trapped in an enclosed space and a means is provided to monitor and relieve the cavity. Products exposed to the accidental load



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case shall meet the stress criteria of clause 5. Designs where the accidental load case affects a products design stress level or deflections the products design shall be verified (qualified) per clause 5.

US Section 5.1.2.1.3, paragraph 1/sentence 3

Technical

It is not clear if 2500 psi above the RWP is the maximum allowable for flow conduit passages or if more pressure through these passages are acceptable.

Change sentence from

"Also, the tubing hanger may contain flow passages that could be rated at 1,0 x MRWP of the tubing hanger assembly plus 17,2 MPa (2 500 psi)."

To

"Also, the tubing hanger may contain flow passages that shall not exceed 1,0 x MRWP of the tubing hanger assembly plus 17,2 MPa (2 500 psi)."

US Section 5.1.2.1.3, 2nd sentence

Technical

Section 5.1.2.1.3 is in conflict with 9.2.7 because the pressure rating of tubing hangers is not affected by the tubing connection per 9.2.7.

Recommend replacing

"The tubing connection may affect the pressure rating of the flow conduit"

with

" The production or annulus tubing connection may have a lower pressure rating than the tubing hangers RWP"

US Section 5.1.2.1.7, 1st sentence

Editorial

Use of terminology. Screw threads are not used elsewhere Change "screw threads" to "threaded connection"



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US Section 5.1.2.1.7, last sentence

Technical

Pressure ratings of table 2 apply to downhole ports in all hangers but do not apply to the threaded end connections in tubing hangers. Table 2 would apply to the rating of casing hangers in mudline suspension systems and wellheads. Effect on rating of hangers is described in 9.2.7 and 10.1.2.2 and 11.4.2.5 b)

Remove "and casing" from last sentence to avoid confusion.

US Section 5.1.2.1.7

Technical

There are no fittings listed for 15,000 psi are not included in table but are referenced in 5.1.4.5.2. Recommend adding Type I, II and III fittings from ISO 10423.

Add Type I, II and III fittings from ISO 10423 to Table 2

US Section 5.1.3.8.1, last paragraph

Other Reference to 5.1.3.2 and 5.1.3.5 appear to be incorrect

US Section 5.1.4.2, b)

Editorial

Conversion error 0,38mm to (0,15in) Change as follows: 0,38mm to (0,015in)

US Section 5.1.4.5.2, title and 1st sentence

Editorial

Clause 5.1.4.5 included vent and injection connection but subclause applies to only test and gauge ports 5.1.4.5.2. (text copied from as 10423) . OEM fittings should also be allowed if qualified.

Change

Test and gauge connection ports

Test and gauge connection ports for 69 MPa (10 000 psi) working pressure and below shall be internally threaded in conformance with methods specified in ISO 10423 and shall not be less than 12,7 mm (1/2 in) nominal line pipe thread. High-pressure connections as described for 103,5 MPa (15 000 psi) equipment may also be used. Test and gauge connections for 103,5 MPa (15 000 psi) working pressure shall be in accordance with ISO 10423.



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To

Connection port design

Connection ports for 69 MPa (10 000 psi) working pressure and below shall be internally threaded in conformance with methods specified in ISO 10423 and shall not be less than 12,7 mm (1/2 in) nominal line pipe thread. High-pressure connections as described for 103,5 MPa (15 000 psi) equipment may also be used. Connections for 103,5 MPa (15 000 psi) working pressure shall be in accordance with ISO 10423. Other designs shall be validated per Table 3.

Add to table 3 as new row.

Connection ports/fittings

Pressure/Load: 200

Temperature cycling: 3

Endurance cycling: 600

Hyperbaric: 200 US Section

5.1.7.2 Techn

ical Thermal chemical performance of non-metallic seals should be required along with proper identification of elastomer materials validated. This would align ISO 10423 requirements with ISO 12628-4 validation requirements. Note additional guidance is given in ISO 13628-4 Annex J for specific well conditions.

Add after last paragraph. Validation on non-metallic materials shall be according to ISO 10423 annex F.1.13. and documented according to F.1.15



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US Section 5.1.7.2, last paragraph

Technical

It is unclear what is meant by the last paragraph, that for items with primary and secondary independent seal mechanisms the seal mechanism shall be independently verified. With this statement we do not know if each seal mechanism can be separately and independently verified and than installed in a component and no further verification is needed or if after separate independent verification of each seal the seals must be tested in the arrangement used in the final component using the same method to install it in base component.

We propose the following paragraph replace the existing paragraph, "For items with primary and secondary independent seal mechanisms the seal mechanisms shall be separately and independently verified and must be separately and independently verified in the arrangement used in the final component using the same field installation tool and method to install them in base component."

US Section 5.1.7.2

Technical

Equipment should be qualified with minimal lubricants unless it is replenished in service or in a sealed chamber. Example - seals and valves should be assembled with only sufficient lubrication to assemble. Oil not grease should be used. Grease may improve performance of seals and valves reducing the validation of the test. Additionally, clause 7.3 prohibits grease fittings on master valves and sometimes on the swab, ASV, crossover and 1st wing valve. Since greasing would not be possible on these valves then qualification would need to be preformed without grease.

Add to last paragraph. "Light oil may be applied to fluid wetted seal surfaces. Grease shall not be applied that could affect sealing performance if it could not be replenished in service as part of the equipments maintenance plan."

US Section 5.1.7.3

Technical

Conflict between first and second paragraph. First paragraphs states gas testing is mandatory while the second paragraph allows substitution of hydro testing. Logically PSL 3G equipment should be validated with gas.

Recommend removing first paragraph and changing second paragraph from:

"Manufactures may at their option substitute gas test for some or all for the required performance verification pressure test. Performance verification test procedures and acceptance criteria shall meet requirements set forth in subclause 5.4."

to



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"Manufactures may at their option substitute gas test for some or all for the required performance verification pressure test. PSL 3G equipment shall be validated using gas for all pressure hold periods (leak tests). Performance verification test procedures and acceptance criteria shall meet requirements set forth in subclause 5.4."

US Section 5.1.7.6

Technical

Bi directional seals should be tested from both directions. Elastomer seals are especially prone to leakage when pressure is reversed at cold temperatures as the material must shift. For metal to metal seals contact stresses are reduced (temporarily or permanently) when pressured in the reverse direction.

Add as last sentence in second paragraph. Bi directional seals shall be tested from both directions at each temperature extreme per ISO 10423 Annex F Figure F.5.

US Section 5.1.7.6

Technical

1) Pressure drop acceptance for verification testing of equipment using a gas medium is a poor predictor of performance. Equipment intended for gas service should be capable of gas tight service to avoid formation of hydrates. Equipment is regularly tested using bubble lines to capture and measure leakage. It is recognized that a zero leakage may be difficult to achieve due to temperature changes in the monitor cavity. A 20 ml/hr acceptance criteria has been easily achieved with properly functioning equipment. 2) It is stated that no leakage beyond annex F of 10423 is allowed. It should be clarified that this is for performance verification testing, FAT and system tests. E.g. PR2 ISO 10423 testing of valves allows for some gas leakage; see Table F.1 in ISO 10423. However, no observable visual leakage is used for FAT in ISO 13628-4. Hence, a qualified valve may not pass the FAT. 3) Hydrate formation often occurs when valves or seals leak at low pressure. Deep water and secondary

Change

"During temperature cycling, rated working pressure shall be applied to the equipment at the temperature extremes with no leaks beyond the acceptance criteria established in Annex F of ISO 10423."

To

"During temperature cycling, rated working pressure shall be applied to the equipment at the temperature extremes with no leaks beyond the acceptance criteria established in Annex F of ISO 10423 for hydrostatic tests and 20 ml/hr for hold periods during gas tests." Additional low pressure hold periods shall be applied prior to application of full test pressure in steps of l) and n) of ISO 10423 Annex F1.11.3.



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recovery operations necessitate the need for equipment with high integrity. The current temperature cycling tests addresses one aspect of start up/shut down conditions i.e. rated working pressure at the temperature extremes. The temperature cycling test should include low pressure testing at the temperature extremes as it is an important part of start up and shut down conditions. Low pressure test at temperature extremes is required for the

US Section 5.1.7.7, Table 3

Technical

Endurance cycling test, all items requiring PMR, (Per Manufacturers Recommendation) should be assessed to determine what each manufacturer does and is it acceptable prior to agreeing to this in the ISO. If some are doing only the minimum is this acceptable to the industry

Survey the manufacturers and determine what endurance cycling testing is being done and the number of cycles is being done be each manufacturer. Establish the minimum done by the manufacturing community, establish this minimum as the new endurance cycling test cycles and poll the members to determine if this minimum is acceptable and replace PMR with this number.


Technical

Valves and actuators endurance cycling testing appears to assume that based on a 20 yr life that the valve/actuator combination will be operated once every twelve days. Section 7.10.2.2.4 h) indicates that the actuator fail safe mechanism shall be designed and verified to provide a minimum spring life of 5000 cycles. This appears to be inconsistent with Table 3 which indicates that 600 cycles are required. It appears that if the actuator is good for 5000 cycles than the valve should also be good for 5000 cycles which will allow valve actuation onec every 1.5 days. Additionally this should be extended to chokes and their actuators if they are hydraulic.

Recommend that the endurance cycling test duration for the valve, valve actuator, choke and choke actuator be increased to 5000 cycles.


Editorial

Notes skip "c" Change notes in table: "d" to "c" , "e" to "d" and "f" to "e"

Accepted in principle. Footnotes were updated.



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US Section 5.1.7.8

Technical

This section allows scaling which allow a piece of equipment to be supplied without product verification or qualification. This may be acceptable on the surface where it is relatively inexpensive to replace or repair that piece of equipment but it is unacceptable subsea, in remote locations or in countries with internal problems where the replacement of this equipment is extremely expensive and difficult.

Recommend that this section be deleted completely.

US Section 5.4.6.2.2, 2nd paragraph

Technical

Pending API 6A Ballot on 3G gas testing If ballot proposal passes for API 6A PSL 3G revisions the allowable reduction of or pressure during a low pressure gas test should be 0.2 MPa (30 psi) as long as there are no visible bubbles in the water bath.

US Section 5.1.7.8, sentence 4

Editorial

"Lesser" may be taken to mean lower temperature class. Testing at a higher temperature would not qualify equipment to a lower temperature class.

Change "or lesser temperature classification" to "and all included temperature classes"

US Section 5.2.2, 1st paragraph

Technical

Add reference to API 6A718 as these requirements may be applicable to some applications. Add as last sentence in paragraph. "The user

may identify additional requirements such as API 6A718 when applicable.

US Section 5.3.2, 1st sentence

Technical

Riser loads are identified as either operating loads or extreme event. The 50% of yield criteria should be identified as an operating load rather than an extreme event load case.

Change "the load stresses exceeds 50% of the weld or base material yield strength"

to

"the operational load stresses exceeds 50% of the weld or base material yield strength, including stress concentration factors, "

US Section 5.6.6 Technical

Equipment should not be shipped with pressure in hydraulic systems. There may be some instances where this not possible. In these cases user may need to make

Add as 3ed sentence. "All pressure shall be bled from equipment unless agreed upon by the user."



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the additional arrangements.


Check valves per EN ISO 13628-1 Annex J Section J.3 classifies SCSSVs, tree valves, manifold valves and check valves as active barriers. However, these barriers appear to require different testing/qualification requirements and it is not clear if each has or should have the same minimum performance verification test requirements. Therefore t he check valves sealing capability as well as its ability to seal over time is different and calls into question the ability of the check valve to perform as required when needed. Further, check valves closures by design donot remain stationary during all operations like a gate and ball valve or SCSSV which is artificially held open or closed with a spring or hydraulic pressure. This makes the check valve more susceptible to failure do to more useage and in our opinion less likely to provide the barrier needed. Standard check valves are back flow prevention devices and fulfil this role well since a bubble tight seal is not required. Thus we feel that check valves should not be used as a barrier unless they are design to meet the same requirements as the SCSSV.

Add the following sentence to the end of the paragraph," Check valves shall not be used as the primary barrier between the production fluid and environment unless they are designed and tested to meet the same minimum performance verification test requirements as the SCSSV."

US Section 6.1.3, 2nd paragraph

Technical

Equipment that uses an substantial amount of materials of different densities (example insulation) may be balanced on surface but become unbalanced when submerged due to the buoyant effects of water.

Add as second sentence "Additional considerations for buoyant materials retrieval configurations or removed equipment should be addressed."

US Section 6.1.7, first intended paragraph

Editorial

Following portion of the first sentence in paragraph " ...a component or assembly is pressure tested protective barriers should be utilized,...

Change wording to "... a component or assembly is pressure tested to provide protective barriers, ....

US Section 6.2.4, 1st sentence

Editorial

Sentence implies that only one wing valve may be used on a horizontal tree. Change "will have a wing valve" to "will have one

or more wing valves"



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US Figure 1 - 4 Editorial

Consider adding a legend identifying valves, actuators, hub connectors, flange/OEC/welded connections, stabs, pressure gauges and connections where threaded connections are allowed.

Add legend

US Figure 2 Editorial

Consistency with other figures Remove "cap" above tubing head in left figure

US Figure 3, left figure

Editorial

Consistency with other figures Add horizontal line above ASV to indicate connection.

US Figure 4a, all Editorial

"CIT options" should be removed as figures also show pressure gauges and could be used for other purposes such as gas lift.

Remove "CIT Options" from figures

US Section 6.2.9, Figure 4a top left, middle right, b

Technical

3 of Figure 4a configurations violate 1st sentence / 1st paragraph of 6.2.9. Penetrations are below the first master valve. Additional figures would be beneficial that show production bore penetration above the lower swab barrier/valve. For HXT rules could be interpreted to mean the penetration would be required to have two actuated barriers. This is excessive as the swab barrier is in place. For VXT the rule is addressed in 6.2.12 3 of Figure 4b configurations violate 1st sentence / 1st paragraph of 6.2.9. Penetrations are below the first master valve.

Delete top left, middle right and bottom right figures that violate the first sentence of the first paragraph of clause

6.2.9. Add new figures that show penetrations above the swab closure for HXT with two barriers and in vertical trees with one barrier.

Delete top left, top right and middle left figures in Figure 4b that violate the first sentence of the first paragraph of clause 6.2.9.

Add to end of second paragraph "Penetrations above the first swab closure on horizontal trees shall have two pressure closures and vertical trees



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shall have one pressure closure. US Section 6.2.9,

Figure 4a Techn

ical Sketch top right with a penetration above a single PMV, following concerns exist: • During normal operations only one barrier (closure) is provided • The check valve as a barrier is questionable due to unknown reliability • Also in the event of a line break with only a check valve on some well you would actually be flowing water into the well during normal operations and would have to shut the well in due to flow assurance issues Sketch middle left with a penetration above two PMVs - Same concern as Sketch top right Sketch bottom left with a penetration above two PMVs - - Same concern as Sketch top right

Delete the use of check valves in all options shown in Sketch 4a

Delete option to use a single check valve only for penetrations barrier

Replace all check valve used in conjunction with another valve with a manual or hydraulic operated valve.

Replace all single barrier (closure valve) on penetrations with dual barriers (closures valves)

US Section 6.2.9, Figure 4b

Technical

Sketch top middle with a penetration above the AMV, the use of a check valve as a barrier is questionable due to unknown reliability. Sketch middle right with a penetration above the AMV, and a manual valve the use of a check valve as a barrier is questionable due to unknown reliability.

Delete the use of check valves in all options shown in Sketch 4b

Delete option to use a single check valve only for penetrations barrier

Replace all single barrier (closure valve) on penetrations with dual barriers (closures valves)

US Section 6.2.9, Figure 5

Technical

Sketch shows a penetration with no AMV and no valves below the penetration, the following concern exist: • the use of a check valve as a barrier is questionable due to unknown reliability and not testable.

Replace all check valve used in conjunction with another valve providing the recommended barriers with a manual or hydraulic operated valve.


6.2.10 appears to be in conflict with 9.2.9. 9.2.9 allows check valves in SCSSV lines for HXT but not VXT. If Change



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check valves were not allowed there would be no way of running SCSSV unless a hold open device was used in the SCSSV.

" Check valves shall not be used anywhere in the SCSSV circuit if there closure could prevent venting down of the control pressure.

To

"The use of check valves in SCSSV circuits shall meet requirements of 9.2.9"

US Section 6.2.10, 1st paragraph, 1st sentence

Technical

No mention of how many barriers are needed out of the top of a horizontal tree tubing hanger with SCSSV control lines through the tubing hanger for control during completion and workover operations than isolated during normal operations.

Delete 1st sentence and replace with the following:

At least one pressure-closing closure shall be used at all SCSSV control line penetrations that pass through either the tree, top of the tubing hanger or tubing spool.

US Section 6.2.11, second sentence

Technical

The use of a check valve as a barrier is questionable due to known operational reliability and not testable. Replace all check valve used in conjunction with

another valve providing the recommended barriers with a manual or hydraulic operated valve.

US Section 6.2.11, 1st paragraph, 1st sentence

Technical

No mention of how many barriers are needed out of the top of a horizontal tree tubing hanger with downhole chemical injection lines through the tubing hanger for injection during completion and workover operations than isolated during normal operations.

Add after first sentence:

At least two pressure-closing closures shall be used at all injection line penetrations that pass through the top of the tubing hanger used in a horizontal tree.

US Section 6.2.14, 4th paragrapgh, last sentence

Technical

Intelligent well functions should also be vented separately from the SCSSV. Add "and SCSSV" after "other control functions on

the tree" on the last sentence of the fourth paragraph.

US Section 6.2.14, first

Techn We do not know what an intelligent well completion could look like in terms of how it is connected to the control Change sentence to read as follows, " At least two



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paragraph ical tubing and how it could potentially provide a pathway for production back to the surface through the intelligent completion equipment downhole below the SCSSV is a concern. Therefore, we feel that this potential connection to the well bore should be treated the same as the downhole chemical injection line and SCSSV control lines and one pressure-controlling closure is not adequate.

pressure-controlling closures ......"

US Section 6.2.14, fifth paragraph

Technical

In the statement, "Intelligent well control line circuits should be designed to have a RWP that is greater than the well shut in pressure", does not indicate how much greater or what criteria is used to establish this.

Change

Intelligent well control line circuits should be designed to have a RWP that is greater than the well shut in pressure."

To

Intelligent well control lines below the SCSSV shall at a minimum be designed for a pressure of a least that of the bottomhole pressure of the well but must not exceed the RWP of the hanger plus a of maximum 2500psi through the control line flow passages in the tree and the hanger. If the control lines design pressure resulting from the bottomhole pressure of the well is greater than the RWP of the hanger plus 2500 psi than the RWP shall be increased to next API equipment rating (i.e. 5000 to 10,000psi).

US Table 4b Editorial

The word "tes" at the end of Note "a" at the bottom of the table is incorrectly spelled Correct the spelling of "tes" to "test"

Accepted

US Section 5.3.1, 1st paragraph

Technical

Cladding of ports has been done with "inserts" using partial penetration welds. Similarly, partial penetration welding and plug welding should be addressed. These types of welds are not are not inspectable per

Add to end of paragraph. "Partial penetration welds, welded "insert" techniques, plug welds for cladding shall not be used for pressure containing



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specification when used as pressure containing welds. Recommend limiting use similar to that of threaded connections and small bore connections of 7.20.2.6. Requirements for joint design are defined, by reference to ISO 10423 (6.3.2.1 i.e. per manufacture), by clause 5.3.1 and 5.1.3.3 in ISO 13628-4.

welds and weld overlay down stream of the second closure or seal barrier."

US Section 7.3, 2nd paragraph

Technical

Isolation valves upstream of the wing are required to be attached with bolted or flanged connection. HXT penetrators often have welded connections between the tree and isolation valve. Welded designs allowed and discussed in 7.20.2.6.

Change "bolted flange or a clamp hub connection" to " bolted flange, clamp hub or welded connections defined in 7.20.2.6 "

US Section 7.9.1.2, last sentence in paragraph

Editorial

Wrong word used in sentence Replace the end of the sentence as follow, ..... gallery test shall be at (Changed from "a") working pressure rating of the interface.

Accepted

US Table 16 Technical

Valve design shall consider effect of leaking seal sub and SCSSV line Add as new item in table 16 between 5 and 6.

"Effect of leaking seal sub or SCSSV" include "a" note

US Section 7.10.2.2.4, h)

Technical

A minimum mean actuator spring life of 5000 cycles would imply that 2500 springs will fail before 5000 cycles are reached. The stated requirement does not put boundaries on the distribution of failures. It would be more useful to provide a requirement where no failures will occur. The Reliability term "Intrinsically reliable" is appropriate for describing designs where the design is not expected to fail under the specified loading conditions. Alternatively, a reliability value could be specified for the number of cycles. Remove "spring" as the fail safe mechanism may be bore pressure or spring reference clause 7.10.2.3.1

Change

The actuator fail safe mechanism shall be designed and verified to provided a mean spring life of 5 000 cycles"

To

"The actuators fail safe mechanism shall be



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designed and verified to provide a minimum intrinsic reliability of 5000 cycles."


Technical

If actuator is designed to prevent a stem packing leak from acting on the piston and compensation chamber is a "relief mechanism" necessary? If well pressure acts on the piston/compensation chamber the actuator has failed. Recommend that the actuator be designed to prevent a well bore pressure from acting on actuator piston or compensation chamber. An additional relief mechanism could reduce the reliability of actuators. Additionally, guidance for leak/flow rate and relief pressure to ensure working pressure is not exceeded.

Change "Means shall be provided to prevent over pressure of the actuator and compensation chambers, in the event that well bore pressure leaks in to the actuator."

To

"Means shall be provided to prevent well bore pressure leaks from acting on the actuator piston and compensation chambers"

US Section 7.10.4.2.4, second paragraph/last sentence

Technical

The last sentence of the second paragraph contradicts the first paragraph of the section which says the valve and actuator must be tested as an assembly while the second paragraph indicates that if the valve and actuator have been tested separately they don' t have to be tested as an assembly. The assembler that builds the valve/actuator does not need to be the same assembler that tests the valve/actuator. However, the assembler should be qualified, similar to clause G 2.1.

Delete last sentence of the second paragraph

Change first paragraph to read:

"After final assembly, each valve/actuator assembly (including override if fitted) shall be subjected to a functional and pressure test to demonstrate proper assembly and operation in accordance with the manufacturer's written specification. Equipment assembled entirely with hydrostatically tested equipment need only be tested to rated working pressure. The tests shall be performed by a qualified subsea valve/actuator assembler. All test data shall be recorded on a data sheet and shall be maintained by the subsea valve/actuator assembler for at least 5 years. The



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test data sheet shall be signed and dated by the person(s) performing the functional test(s)."

US Section 7.15.1, last sentence

Editorial

The acronym "CBG apears to be incorrect. Change "CBG" to "CGB"

Accepted

US Section 7.17.1, 1st paragraph, last sentence

Editorial

Comma missing Change "water gas" to "water , gas"

Accepted

US Section 7.17.2.7, second bullet

Technical

Testing requirements for outboard piping is in conflict with 7.17.2.1. 7.17.2.1 requires testing to 1.5 RWP according to design code while 7.17.2.7 design code requires testing to 1.25 *RWP.

Change "Testing: all testing for inboard piping shall conform to the requirements per sub clause 5.4. Outboard piping shall be in accordance with specified piping code."

To

"Testing: all testing for piping shall conform to the requirements per sub clause 5.4 regardless of design code."

US Section 7.18, title

Technical

This section in intended to cover all connector systems, however it is felt that this section covers mainly flowline connection to subsea trees and does not address well jumper connection to manifold adequately.

Change Title from "Flowline connector systems to Flowline and jumper connector systems"

US Section 7.18.1, paragraph 1

Other Types and uses of connection systems in this section appear to reference only those associated with the subsea tree directly connected to a flowline while in real life other configurations are also used and should be referenced. These other configurations include the connection of the subsea tree to a flowline end termination or manifold through a jumper. Further the connection of umbilicals directly to the subsea tree is only

Change following paragraph,

"This sub clause covers the tree-mounted flowline connector systems which are used to connect subsea flowlines/umbilicals to the subsea trees.



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one configuration used. Other connection configuration may include the installation of an umbilical with a umbilical termination assembly on the end which is connected to a subsea distribution system through flying leads with all other subsea components supplied hydraulic fluid chemicals and electrical through flying leads. The connection systems to this configuration are described in clause 7.20 when addressing the tree. Therefore we recommend that changes be made to reflect these other configurations.

To, "This sub clause covers the tree-mounted connection systems which are used to directly connect a subsea flowline directly to a subsea tree, connect a flowline end termination of a flowline to the subsea tree through a jumper and connect a subsea tree to a manifold through a jumper. The connection of an umbilical directly to a subsea tree is also covered in this sub clause while all other connections concerning the umbilical to the subsea tree are covered in clause 7.20

US Section 7.18.1, paragraph 2

Technical

Types and uses of connection systems in this section appear to reference the installation of only those associated with the subsea tree directly connected to a flowline while in real life other configurations are also used and should be referenced. The installation of these other configurations includes the connection of the subsea tree to a flowline end termination or manifold through a jumper.

Change following paragraph

"The flowline connector system may utilise various installation methods such as first end and second end connection methods as described in ISO 13628-1. Flowline connectors may be either diverless or diver-assisted and may utilize guidelines/guideposts to provide guidance and alignment of the equipment during installation."

To

"The subsea tree connection systems (to flowline or to subsea component ) will utilize various installation methods as described in ISO 13628-1. The connection can be diver-assisted or diverless. The connectors can be mechanically (non-integral through running tools) or hydraulically (integral) operated.



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US Section

7.18.2, title Techn

ical This section in intended to cover the support frame for all connector systems, however it is felt that this section covers mainly the flowline connection support frame located on the wellhead and does not address well jumper connection to manifold adequately.

Change Title from "Flowline/jumper connector support frame to Connector support frame"

US Section 7.18.2.1

Technical

This section in intended to cover the support frame for all connector systems, however it is felt that this section covers mainly the flowline connection support frame located on the wellhead and does not address well jumper connection to manifold adequately.


The flowline connector support frame shall provide an attachment point to the subsea tree and/or subsea wellhead of the flowline connector mechanism. The support frame shall be attached to the subsea wellhead housing, the PGB, GRA or CGB, the tree and/or tree frame, the template frame (if applicable), or other structural member suitable for accommodating all expected loading conditions.

To

The connector system shall be supported by an appropriately designed support frame which shall be attached to the subsea tree and/or subsea wellhead. The support frame shall be attached to the subsea wellhead housing, the PGB, GRA or CGB, the tree and/or tree frame, the template frame (if applicable), or other structural member suitable for accommodating all expected loading conditions.



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Technical

This clause identifies all of the loads required to design the connector frame for a flowline connection and does not cover all of the load which should be considered for a connection using a jumper between the subsea tree and manifold or other equipment

Please add the following to the end of the paragragh,

- jumper loads, when appropriate

- tree/wellhead deflection during a workover when a rig has a lost a mooring line and the wind and current are maximum anticipated wind the direction the mooring line is lost


Technical

Modification needed to reflect not only a flowline connection frame but also a connection frame on the tree for a jumper connection configuration.


The flowline connector support frame shall be designed to avoid interfering with the BOP stack when on the wellhead housing after the flowline connector support frame is installed.

To

The connector support frame shall be designed to avoid interfering with the BOP stack when on the wellhead housing /or subsea tree after the connector support frame is installed.


Technical

Modification needed to reflect not only a flowline connection frame but also a connection frame on the tree for a jumper connection configuration.


The flowline connector support frame shall react all loads imparted by the flowline and umbilical into a structural member to ensure that:



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-tree valves and/or tree piping are protected from flowline/umbilical loads which could damage these components;

-alignment of critical mating components is provided and maintained during installation;

-tree can be removed and replaced without damage to critical mating components

To

The connector support frame shall react all loads imparted by a flowline, jumper and/or umbilical into a structural member of the subsea tree or wellhead housing to ensure that:

-tree valves and/or tree piping are protected from flowline/jumper/umbilical loads which could damage these components;

-alignment of critical mating components is provided and maintained during installation;

-tree can be removed and replaced without damage to critical mating components



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US Section 7.18.3, title

Technical

The title should cover both flowline and jumper connectors. Change Title from "Flowline connectors to Flowline

and jumper connectors"

US Section 7.18.3.1

Technical

Modification needed to reflect not only connectors for flowline connectors but also for a connector on the tree for a jumper connection configuration.


The flowline connector and its associated running tools provide the means for joining the subsea flowline(s) and/or umbilical(s) to the subsea tree. In some cases, the flowline connector also provides means for disconnecting and removing the tree without retrieving the subsea flowline/umbilical to the surface.

Flowline connectors generally fall into three categories:

-......."

To

The connector and its associated running tools provide the means for joining the subsea flowline(s), subsea manifold and/or umbilical(s) to the subsea tree. In some cases, the flowline connector also provides means for disconnecting and removing the tree without retrieving the subsea flowline/umbilical to the surface.



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Connectors generally fall into three categories:

-......." US Section

7.18.3.2 Techn

ical Modification needed to reflect not only design of connectors for flowline connectors but also for a connector on the tree for a jumper connection configuration.

Remove the word "flowline" from all locations in the section.

US Section 7.18.3.3, first sentence

Technical

Modification needed to reflect not only loads for connectors for flowline connectors but also for a connector on the tree for a jumper connection configuration.

Remove the word "flowline" from the sentence

US Section 7.18.3.3, 4th bullet

Technical

Loads should reference both flowline and well jumper connectors and not just flowline connectors Remove the word "flowline" from the sentence

US Section 7.18.3.3, 3rd bullet

Technical

Connector design loads should include wellhead deflection Add

-jumper loads, when appropriate

- tree/wellhead deflection during a workover when a rig has a lost a mooring line and the wind and current are maximum anticipated wind the direction the mooring line is lost " after "thermal expansion/contraction"

US Section 7.18.3.3, 2nd paragraph

Technical

Modify to reflect all connectors and not just flowline connectors Remove the word "flowline" from the sentence

US Section 7.18.3.3, 3rd paragraph

Technical




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US Section 7.18.3.4, 1st paragraph

Technical

Modify to reflect all connectors and not just flowline connectors Change following paragraph

The dimensions of the flowline connectors flow passages should be compatible with the drift diameters of the flowlines.

To

The dimensions of the flowline or well jumper connectors flow passages should be compatible with the drift diameters of the flowlines or the well jumpers.

US Section 7.18.3.4, 4th paragraph

Technical



Technical

Modify to reflect all connectors and not just flowline connectors Change following sentence:

The termination interface between the flowline connector and the flowline shall conform to the requirements of subclause 7.1 through 7.4 at the flowline connector side, and to the requirements of the specified piping code on the flowline side.

To

The termination interface between the connector and the flowline or jumper shall conform to the requirements of subclause 7.1 through 7.4 at the



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flowline or jumper connector side, and to the requirements of the specified piping code on the flowline side.

US Section 7.18.3.5, 1st paragraph, 1st sentence

Technical


US Section 7.18.3.5, 1st paragraph, last sentence

Technical


Seals and sealing surfaces should be protected during flowline installation operations.

To

Seals and sealing surfaces should be protected during flowline or jumper installation operations.

US Section 7.18.3.5, 2nd paragraph, 1st sentence

Technical


Primary seals on flowline connectors shall be metal-to-material.

To

Primary seals on the connectors shall be metal-to-metal

US Section 7.18.3.5, 4th

Technical




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paragraph The flowline connection system shall provide means for pressure testing the flowline and/or umbilical connections following installation and hook-up.

To

The connection system shall provide a means for pressure testing the connections following installation and hook-up.

US Section 7.18.3.5, 5th paragraph, 1st sentence

Technical

Modify to reflect all connectors and not just flowline connectors Change "The flowline connector....... to The

connector........"

US Section 7.18.3.5, 5th paragraph, end

Technical

Modify to reflect all connectors and not just flowline connectors Design of flowline and running tools must not prevent installation of BOP stack.

Add the following sentences to end of the paragraph,

However, the connector shall also be designed such that if a jumper is used it shall be removed prior to the removal or replacement of a tree. The connection system shall not prevent installation of the BOP.


Technical

Modify to reflect all connectors and not just flowline connectors Remove the word "flowline" from the paragraph

US Section 7.18.3.5, 7th

Techn Modify to reflect all connectors and not just flowline Remove the word "flowline" from the paragraph



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paragraph ical connectors


Technical


US Section 7.18.4.1

Technical


US Section 7.18.4.2, 1st paragraph, 1st sentence

Technical


US Section 7.18.4.2

Technical

Additional qualification test needed Add after last bullet:

- connection qualification test including torsion, bending, pressure and temperature shall be performed for each connector of different size. These tests shall be performed and completed before final design review or any FAT started.

US Section 7.18.4.3 b), 2nd paragraph

Technical


US Section 7.20.2.9, 1st sentence

Technical

7.20.2.9 appears to be in conflict with 9.2.9. 9.2.9 allows check valves in SCSSV lines for HXT tubing hangers. Add to end of first sentence "except where allowed

in clause 9.2.9."

US Section 7.20.2.9, first paragraph/first sentence

Technical

Don't think the following sentence can be achieved, " As a minimum, control line stabs for the SCSSV, production master valve (s), production wing valve, annulus valve and work over valve shall be designed so as not to trap pressure when the control stabs are separated". If the valves mentioned above are closed prior to control stab

Delete first sentence of first paragraph

"As a minimum, control line stabs for the SCSSV, production master valve (s), production wing valve, annulus valve and workover valve shall be



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separation than trapped pressure would not be a problem. If this is an emergency situation and the valves are not shut prior to separation and check valves are included in the stabs that would trap pressure in the line. If a vendor has a design which could achieve the intent of this sentence it would probably let more water into the system and violate the intent of the second sentence in the paragraph. This sentence tries to minimize the ingress of water when the stabs are separated. Further, very concerned that if this is a part of the standard we have eliminated some vendors or worse eliminated all but one and now this vendor controls the market and affects our cost and schedules in a negative (non competitive) way.

designed so as not to trap pressure when the control stabs are separated."

Suggested rewording:

"Control line stabs for the SCSSV, production master valve (s), production wing valve, annulus valve and workover valve should be considered in designs so as not to trap pressure when the control stabs are separated. Additionally, control stab designs should consider bending hydraulic tubing to provide a fluid trap to minimize seawater ingress when connected / disconnected. "

US Section 7.22.3, 2nd paragraph

Technical

Test stands and stumps do not required additional requirements of API 6HT Remove second paragraph


Emergency seal design should be validated to address typical causes of failures, Add to end of paragraph. "Additionally emergency

annulus seal assemblies designs should address causes of seal failures. Validation testing should characterize tolerance to seal area damage and debris tolerance."

US Section 8.8.1, 4th paragraph

Technical

For well control reasons the lock down bushing must be retrievable through the BOP Change: The lock down bushing may be

configured to run through the drill riser and BOP or it may be installed in open water using diver/ROV/ROT assistance."

To

The lock down bushing may be configured to run in open water and/or through the drill riser and



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BOP. The lockdown bushing shall be designed to be retrievable through the drilling riser and subsea BOP.

US Section 9.1, first paragraph/third sentence

Technical

Sentence does not make any reference to the tubing annulus seal between a tubing hanger and horizontal tree.

Replace sentence with following sentence, "A tubing annulus seal is effected between the tubing hanger and casing hanger, tubing hanger and spool or tubing hanger and horizontal tree, and the hanger is locked in place."

US Section 9.1, first paragraph/fifth sentence

Editorial

Needed for clarity Add the word downhole between the word other and devices for clarity.

US Section 9.1, first paragraph/fifith sentence

Editorial

Misspelled word See sentence "Refer to Annex D for representative illustrations of these tubing hangar (Change to 'hanger") types

Accepted

US Section 9.1,second paragraph

Technical

No reference to orientation involving the tree which is a possibility Add the word "/tree" to the end of the last two

sentences in the paragraph

US Section 9.2.1, third paragraph/last sentence

Technical

The use of a check valve as a barrier is questionable due to known unreliability and not being testable. Delete the following from the last sentence " "by

the use of a check valve".

US Section 9.2.7, second paragraph/second sentence

Editorial

Misspelled word "Amd" is misspelled change to "and"

Accepted

US Section 10.1.3.2, 1st sentence

Technical

Use of Non NACE materials should be agreed upon by the user and manufacture for external latch rings and load shoulders. If the annulus could be exposed to sour

Add after 1st sentence. Use of non-NACE components on sour service hangers shall be



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conditions the specific latch/load shoulder design and well design must be evaluated.

agreed upon buy manufacture and user.

US Section 10.4.2.2

Technical

Manufacture should document allowable flow rate through wash ports on running tool to prevent wash out of ports and need for high viscosity pills.

Add as last sentence, "Manufacture shall document maximum flow rate through washout ports."

US New section 10.1.2.7

Technical

Manufacture should document allowable misalignment for conductor and riser for proper operation of the mud line system.

Add as clause:

10.1.2.7 Misalignment

"Manufacture shall document allowable conductor installation angle and riser angle for mudline suspension system."


Abandonment caps should be designed such that the riser is capable well control when the abandonment cap is removed. Removing an abandonment cap before landing the hangers tie back could prevent killing the well.

Add as second paragraph: "Abandonment cap designs shall allow clean-out and tie-back tools to be run without retrieving next inner string abandonment cap"

US Table 34, first and second row

Technical

Test pressures should be 1.5 * RWP to be consistent with the rest of the specification (i.e. 5.4.5.1.) Change

Row 1

"69.0 MPa" to 51.8 MPa"

"10,000 psi" to 7,500 psi"

Row 2

"103.5 MPa" to "77.57 MPa"

"15,000 psi" to "11,250 psi"



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Note: this change may affect allowable stress discussion in Annex E

US Section 11.5.2.2

Technical

Clause should be consistent with clause 8.7.2.2 for sub sea wellhead casing hangers. Add as last sentence. "The manufacture shall

specify the rated working pressure from below if it is different than the rated working pressure from above.

US Section 11.5.2.5, last sentence

Editorial

Incorrect reference Change 11.6.2" to "11.5.2"

US Section 11.5.2.5

Technical

Emergency seal design should be validated to address typical causes of failures, Add to end of paragraph. "Additionally emergency

annulus seal assembly designs should address causes of seal failures. Validation testing should characterize tolerance to seal area damage and debris tolerance."

US Section 12.5.1 c)

Editorial

Misspelled word "cusomter" is misspelled change to "customer"

Accepted

US Section 12.5.2 e), Wellhead Interface

Technical

Add requirements to address sea bed hydrates Seabed hydrates Anticipated Yes No

US Section 12.5.2 e), Wellhead Interface

Technical

Add requirements for valves on cement return outlets for low pressure housing Valves required on Low Pressure outlets Yes

No

US Section 12.5.3 f) Subsea Tree Data Sheet

Technical

Add supplier and model no. to the data sheet



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US Section 12.5.3 a), Subsea Tree Data Sheet

Technical

Add information indicating what type of wells required. Add in the description section following categories Inj. ,Prod., Interchangeable

US Annex B, 3rd paragraph, last sentence

Technical

Debris caps may not always provide a back up locking mechanism Change ",and features a debris cap that also

serves as a back up locking mechanism for the tubing hanger."

To

",and features a debris cap that may also serve as a back up locking mechanism for the tubing hanger."

US Annex B, fifth paragraph

Technical

Added wording for clarity Please add to the end to the paragraph, -"In this configuration the diameter of the tree bore protector and tubing hanger orientation system has to drift the casing hanger and seal assembly."

US Section H.2.3, 1st sentence

Technical

Bores should have appropriate internal ID transitions for passage of tools. Change "sufficient ID to allow passage of tools"

To

"sufficient ID and internal transitions to allow passage of tools"

US Section H.2.5 Technical

If combined loading affects capacity of tool, the reduced capacities must be provided. And new sentence. Tool ratings shall be provide

with and without combined loads (i.e. pressure and tension)

US Section J.2.1.2.1 b)

Technical

“Neat-“ it is not clear if two tests are required or only one. If Neat, this is the concentration received from the chemical supplier. If in “concentration to be used for

Change to: “Concentration of test media: Test solution shall be in the concentration to be used in



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project,” then this is a test in which the chemical is likely in ppm. Which is being proposed here?—or is it both?

the project. Volume shall be maintained to provide a 25:1 minimum ratio of fluid volume to seal volume.”

US Section J.2.1.2.1 d)

Technical

O2 should be excluded. Testing should be done under a low pressure inert gas such as N2 to exclude any role of O2 in the tests.

Change to: “Testing should be performed under a low pressure inert gas such as N2 to exclude any role of O2 in the tests.”

US Section J.2.1.2.1 f)

Editorial

Typos: In line 2, 20C +/- 1 C and 68F +/- 2F In line 2, 20C +/- 1 C and 68F +/- 2F

US Section J.2.1.2.1 f)

Technical

Hardness measurements may not be possible if elastomer is swollen. Change to: “Record the weight change, hardness

change (if possible) and % volume change within 3 hr. after removal from the oven.”

US Section J.2.1.2.1 g)

Editorial

Replace “at” with “with.” Change to: The vessel shall be rated for use with the test chemicals……………..”

US Section J.2.1.2.2, after d)

Technical

Add paragraphs e), f) and g) with mechanical test acceptance ctiteria. Change to: e) % Tensile Strength change: +50% /

-50%

f) % Change in the % Elongation: +50% / -50%

g) %Change in the 50% Modulus: +50% / -50%

US Section J.2.1.3

Editorial

Add a Reference to metal coupon testing, such as NACE TM0169-2000. Better information about testing metal coupons is shown in that document than this one.

Add: NACE TM0169-2000

US Section J.2.1.3.1 b)

Technical

Same as J.2.1.2.1b above. Change to: “Concentration of test media: Test solution shall be in the concentration to be used in the project. Volume shall be maintained to provide a 25:1 minimum ratio of fluid volume to seal volume.”



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US Section J.2.1.3.1 g)

Technical

Replace “at” with “with.” Change to: The vessel shall be rated for use with the test chemicals……………..”

See above.

US Section J.2.1.3.2 after b)

Technical

Add “Weight Change.” Add: “c) Weight Change”

US Section J.3.1.1, title

Editorial

This heading should either drop the word “plastics” or include information on plastic testing. Alternatively, write a separate section on testing of plastics. There are many international standards available for plastics testing. Everything in this section generally pertains to elastomers.

Change to: “J.3.1.1 Elastomers”

US Section J.3.1.1 b)

Technical

Same as J.2.1.2.1b Change to: “Concentration of test media: Test solution shall be in the concentration to be used in the project. Volume shall be maintained to provide a 25:1 minimum ratio of fluid volume to seal volume.”

US Section J.3.1.1 c)

Technical

Test temperature should more realistically reflect the service temperature. Change to: “Temperature: 60C or any temperature

agreed to with end user. Test temperature should reflect service temperature.”

US Section J.3.1.1 d)

Technical

If this is “Confined” testing (see J.3.1), then the Pressure should be 100 bar or similar high pressure. Change to: “Pressure: 100 bar or any pressure

agreed to with end user. Test pressure should reflect service pressure.”

US Section J.3.1.1 f)

Technical

Hardness measurements may not be possible if elastomer is swollen. …. Change to: “Record the weight change,

hardness change (if possible) and % volume change within 3 hr. after removal from the oven.”

US Section J.3.1.1 g)

Technical

Tests with the vessel shown in API TR 6J1 Fig.2 are intricate, lengthy and expensive. While tests with such a vessel could be performed, it is often far simpler to use a

Add “Alternatively, a test fixture that duplicates the critical elements of the equipment o-ring groove,



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test fixture that duplicates the geometry of the equipment o-ring housing.

squeeze and groove fill may be used. The fixture(s) shall be tested in a pressure vessel under a pressure and atmosphere simulating service conditions.”

US Section J.3.1.2, title

Editorial

Even with some of the plastic acceptance criteria in this section taken from NORSOK M-710, most everything is about elastomers. Change the title of J.3.1.2 as shown next, and write a separate section on plastics.

Change to: “Acceptance Criteria for Elastomer Compatibility.”

US Section J.3.1.2 after g)

Technical

Compression Set is an important property that affects seal performance. Add: “h) Compression Set: 25% maximum.”

US Section J.4.1, paragraph

Editorial

Note that in the list of References provided, the NORSOK document is actually “NORSOK M-710” and not as shown. This should be corrected in several places in all of J.4.1.

Change to: “NORSOK M-710, Rev. 2, ” in several places.

US Section J.4.1, paragraph 6

Technical

In last sentence of next-to-last paragraph, note that NORSOK M-710 requires a No.325 O-ring, not a -214 (erroneously written as -241).

Change to: “Specimen size shall not be less than 100 cm3 (6 in3) in volume and should be similar to the -214 cross section as defined in Level 1 and Level 2. Note, however, that NORSOK M-710 requires a No. 325 O-ring.”


Technical

In last paragraph, second sentence has incorrect references. Change to: “Reporting should be accordance with

Section 8.2.2 and Annex C of NORSOK M-710.”


Technical

In last paragraph, delete last sentence because it applies to elastomers. This paragraph is about thermoplastics. Delete last sentence of this paragraph. (Specimen

size shall not be less than 100 cm3 (6 in3) in volume……..”)

US Section J.4.2 Technical

The most valid results from Rapid Gas Decompresson testing are obtained when an O-ring of size No. 325 or larger are used. Delete the entire section and rewrite as shown:

Change to; “Rapid gas decompression tests shall be performed in accordance with Section 7.3 and Annex B of NORSOK M-710 or other acceptable standards. Reporting shall be in accordance with



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Sections 6 and 7.3.2 of NORSOK M-710. The thickness of the cross section tested shall equal or exceed that of a No. 325 O-ring (5.33 mm). As shown in Table B.2, ratings of 4 or 5 are not acceptable.”

US 4.1.3 Ed Classification table should be that as listed in the Annex O, API Regional Annex Table 2 of ISO10423.

See above.

4.1.4 Ed Remove second sentence and replace with “Material classes AA-HH as defined in Table 1 of this standard shall be used to indicate the material of those equipment components.”

US 5.1.3.5 Para. 4 Te Published literature indicates that the recommended limit for cathodically protected carbon and low alloy steels exposed to sea water is 34 HRC maximum.

Revise paragraph 4 to read as follows:

“Closure bolting manufactured from carbon or alloy steel when used in submerged service shall be limited to 319 HBN (34 HRC) maximum due to concerns with hydrogen embrittlement when connected to cathodic protection. Closure bolting for material classes AA-HH that is covered by insulation shall be treated as exposed bolting per ISO 15156.”

US 5.1.2.2.1 1st Para ed Incorrect ref to Annex in ISO 10423, Existing states:- in accordance with Table 2 and Annex G.2 of ISO 10423 In accordance with Annex O, API Regional Annex

Table 2 of ISO 10423.

US 5.1.2.2.1 Sub section b)

ed Wrong sub clause ref, Existing states:- 4.2 4.1.3.

US 5.1.3.8.1 2nd para ed Wrong ref to sub clauses, Existing states:- designed per clause 5.1.3.2 or 5.1.3.5 as applicable Designed per Annex H.

US 5.1.7.3 1st para Te Text implies all hold testing is with gas. This should only be applicable to bore wetted components. Hydraulic Gas shall be used for pressure hold periods for

pressure containing and controlling equipment.

See above.



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equipment not exposed to bore can be tested with water. Other equipment may be hydro tested.

US 5.1.7.5 2nd para ed Wrong ref to sub clauses, Existing states:- 5.1.3.2 and 5.1.3.5 5.1.3.4 and 5.1.3.6 respectively.

US 5.1.7.7 Table 3 ed Missing Note:- There is no note c explanation at the foot of the table relating to Tree Cap & Flowline Connectors, which may effect full comment to these products.

Add Note c. See above.

US Table 3 Te Workover / Intervention Connectors are includes. Is this supplemental to requirements in ISO 13628-7? Suggest this component is removed form the

table.

US 5.2.2 Para. 2 Te API RP 6HT Section 6.3.1.9 states, “Heat treatment shall be performed by suppliers who are qualified and approved by the manufacturer.” This does not represent current industry practice. The equipment manufacturer’s do not typically “qualify” the heat treat facilities at forge shops or the various sub-contract heat treat facilities used by the forge shops. This places an unnecessary burden on manufacturers. Furthermore, the wording in the ballot, “all thermal processing” could be interpreted by some to include weld stress relieving and / or post weld heat treatment. This is not practical, so the true meaning of the requirement needs to be clarified.

Revise to read:

“For pressure containing and high load bearing forged material, forging practices, heat treatment and test coupon (QTC or prolongation) requirements should be in accordance with API RP 6HT, with the following clarifications. The test coupon shall accompany the material it qualifies through all heat treatment steps, excluding weld stress relieving or post weld heat treatment. Also, API RP 6HT clause 6.3.1.9 shall be treated as a recommended practice only.”

US 5.5.2 6th para te Examples of ton call offs are not comprehensive and clear. Existing states:-for example, ‘tons refers to a “short ton” or 2000 lb. ‘M Ton’ refers to a metric ton (1000 kg or 2200 lb)

For example, ‘TONS’ refers to an imperial ton (2240lb), ‘S TON’ refers to short ton (2000lb), ‘TONNE’ refers to a metric tonne (1000 kg or 2204 lb)

US 5.5.4 ed Incorrect ref to Annex in ISO 10423, Existing states:- in accordance with Table 2 and Annex G.2 of ISO 10423 In accordance with Annex O, API Regional Annex

Table 2 of ISO 10423.

See above.

US 6.2.9 1st sentence Ed Clarify 1st sentence on production (injection) bore It would benefit from two separate sentences for a



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penetrations. production and injection tree, particularly if upstream and downstream terms are used to describe the position of penetrations in the bore.

US 6.2.9 Figure 4(a) Ed No legend is included at this figure to enable understanding of the CIT options available. Include legend to all diagrammatic layouts in this

section, 6.2. Tree Valving.

US 6.2.12 2nd paragraph

Te Rated working pressures Clarification required

GB 6.3.2 Table 4b ge Below installed Tubing Hanger, Lockdown Retention Test Pressure is 1.5 x RWP. In Table 4a the Lockdown Retention Test Pressure is 1.1 x RWP.

Make Lockdown Retention Pressure consistent at 1.1 x RWP. Same applies to Table 4c.

GB 6.3.2 Table 4b ge Below Internal Tree Cap, Lockdown Retention Test Pressure is 1.5 x RWP. Make Lockdown Retention Pressure consistent at

1.1 x RWP.

GB 6.3.2 Table 4b ge Pressure below a Crown Plug is 1.5 x RWP. Pressure above a Crown Plug is 1.0 x RWP. When testing between an upper and lower plug pressure across the lower plug has to be equalised.

Make Lockdown Retention Pressure consistent at 1.1 x RWP, thereby between the plugs only one test pressure is required without pressure equalising the lower plug. Same applies to Table 4c.

GB 6.3.2 Table 4b footnote

ge Last line of sentence, “tes” should read “test”. Correct spelling mistake.

Accepted, above.

US 7.1.1 Table 5 ed Wrong ref’s to sizes, Existing states: – Under type 17SV for 10K, 46 to 279 mm (1 11/16 to 11) Under type 6BX for 10K & 15K inch size is 1 11/16

46 to 346 mm (1 13/16 to 13 5/8).

1 13/16.

US 7.1.1 2nd para ed Wrong mm size, Existing states:- 51 mm (2 in) 52 mm (2 in).

US 7.1.1 6th para ed Wrong ref to Table, Existing states:- Table 3 Table 11.

US 7.1.2.1 2nd para ed Wrong ref to Table, Existing states:- Table 5 Table 6.



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US 7.12.2.1 1st & 2nd Para

ed Wrong size, Existing states:- (2 in) (2 1/16 in).

US 7.1.2 Table 6 ed Wrong in size for SBX 151, Existing states:- (1 11/16) (1 13/16).

US 7.1.2.2.2.1 ed Wrong refs to Tables, Existing states:- 17SS integral flanges shall conform to Table 6 17SS weld neck flanges shall conform to Table 8 Table 9

Table 7.

Table 9.

Table 10.

US 7.1.2.2.2.4 ed Wrong refs to Table and Figures, Existing states:- Table 8 Figure 9

Table 9.

Figure 8.

See above.

US 7.1.2.2.3 ed Wrong ref to Table, Existing states:- Table 9 Table 10.

US 7.1.2 Table 7 ed Incorrect sizes based on existing API 17D sizes, OD = 396, Diameter of bolt holes = 50, length of stud bolts = 306

395, 51.

305

US 7.1.2 Table 9, 2nd NOTE

ed Additional Table ref not needed, existing states:- Table 7 or 8 Either remove ref to Table 8 or add details into

table 9 for ¾” and 1” sizes.

US 7.1.2 Figure 6 Te No ref to overall thickness of blind flange Add dimension ref to figure 6 & respective table (s)

US 7.1.2.5.5 1st para te Other sections such as 7.2 & 7.4 refer to corrosion-resistant materials not corrosion-resistant alloy



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Corrosion-resistant alloy Inlay alloy Corrosion-resistant materials.

Inlay materials. US 7.1.2 Table 11 ed Incorrect sizes based on existing API 17D sizes,

OD = 5.081, (5.78ss), 9.880 Large diameter of neck = 98, 4.988

5.031, 5.781, 9.380.

93, 4.938.

US 7.1.2 Table 12 ed Incorrect nominal size, Existing states:- (2 1/8) Incorrect sizes based on existing API 17D sizes, ROD = 245, 488, 595, (28.00)

(3 1/8).

246, 483, 585, (23.00).

US 7.1.2 Table 13 ed Incorrect sizes based on existing API 17D sizes, Large diameter of neck = (8.885) Length of neck = (3.996)

(8.335)

(3.666)

US 7.1.2 Table 14 ge Out of line text:- For tolerance R the + 3 mm (0.125 in) is not in line with the sizes 7 1/16 thru 11 Put an extra line in to re-align test to tolerance

sizes.

Accepted.

US 7.2 Para. 3 Te API RP 6HT Section 6.3.1.9 states, “Heat treatment shall be performed by suppliers who are qualified and approved by the manufacturer.” This does not represent current industry practice. The equipment manufacturer’s do not typically “qualify” the heat treat facilities at forge shops or the various sub-contract heat treat facilities used by the forge shops. This places an unnecessary burden on manufacturers. Furthermore, the wording in the ballot, “all thermal processing” could be interpreted by some to include weld stress relieving and / or post weld heat treatment. This is not practical, so the true meaning of the requirement needs to be clarified.

Revise to read:

“Forging practices, heat treatment and test coupon (QTC or prolongation) requirements should be in accordance with API RP 6HT, with the following clarifications. The test coupon shall accompany the material it qualifies through all heat treatment steps, excluding weld stress relieving or post weld heat treatment. Also, API RP 6HT clause 6.3.1.9 shall be treated as a recommended practice only.”



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US 7.4 Para. 3 Te API RP 6HT Section 6.3.1.9 states, “Heat treatment shall be performed by suppliers who are qualified and approved by the manufacturer.” This does not represent current industry practice. The equipment manufacturer’s do not typically “qualify” the heat treat facilities at forge shops or the various sub-contract heat treat facilities used by the forge shops. This places an unnecessary burden on manufacturers. Furthermore, the wording in the ballot, “all thermal processing” could be interpreted by some to include weld stress relieving and / or post weld heat treatment. This is not practical, so the true meaning of the requirement needs to be clarified.

Revise to read:


US 7.5.1 2nd para ed Wrong ref sub clause, Existing states:- Refer to 5.1.3.4 Refer to 5.1.3.5.

See above.

US 7.5.5 1st para ed Wrong ref sub clause, Existing states:- Refer to 5.1.3.4 Refer to 5.1.3.5.

See Above.

US 7.7 7.7 Te There are no specific requirements within the Completion Guidebase Section for guidance on Material selection. Include section to offer guidance on Material

selection or refer to Common System Requirements for Structural Materials at section 5.2.5.

US 7.7 7.7 Te There are no specific requirements within the Completion Guidebase Section for guidance on Testing of the equipment.

Include section to offer guidance on testing or refer to section 8.3.3.

US 7.7.2.1 Figure 13 Ge Terminology used within Figure 13 does not include Completion Guidebase. Include where necessary, “Completion

Guidebase”.

US 7.7.2.1 7.7.2.1 Te Statement of referral to sub-clause 7.18.2.2 is not relevant to the Completion Guidebase. Remove referral to sub-clause 7.18.2.2.

US 7.8.3.9 Para. 2 Te API RP 6HT Section 6.3.1.9 states, “Heat treatment shall be performed by suppliers who are qualified and Revise to read:



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approved by the manufacturer.” This does not represent current industry practice. The equipment manufacturer’s do not typically “qualify” the heat treat facilities at forge shops or the various sub-contract heat treat facilities used by the forge shops. This places an unnecessary burden on manufacturers. Furthermore, the wording in the ballot, “all thermal processing” could be interpreted by some to include weld stress relieving and / or post weld heat treatment. This is not practical, so the true meaning of the requirement needs to be clarified.


US 7.10.2.1.4 Para. 2 Te API RP 6HT Section 6.3.1.9 states, “Heat treatment shall be performed by suppliers who are qualified and approved by the manufacturer.” This does not represent current industry practice. The equipment manufacturer’s do not typically “qualify” the heat treat facilities at forge shops or the various sub-contract heat treat facilities used by the forge shops. This places an unnecessary burden on manufacturers. Furthermore, the wording in the ballot, “all thermal processing” could be interpreted by some to include weld stress relieving and / or post weld heat treatment. This is not practical, so the true meaning of the requirement needs to be clarified.

Revise to read:


US 7.10.3 Para. 2 Te API RP 6HT Section 6.3.1.9 states, “Heat treatment shall be performed by suppliers who are qualified and approved by the manufacturer.” This does not represent current industry practice. The equipment manufacturer’s do not typically “qualify” the heat treat facilities at forge shops or the various sub-contract heat treat facilities used by the forge shops. This places an unnecessary burden on manufacturers.

Revise to read:

“Forging practices, heat treatment and test coupon (QTC or prolongation) requirements should be in accordance with API RP 6HT, with the following clarifications. The test coupon shall accompany the material it qualifies through all heat treatment steps, excluding weld stress relieving or post weld



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Furthermore, the wording in the ballot, “all thermal processing” could be interpreted by some to include weld stress relieving and / or post weld heat treatment. This is not practical, so the true meaning of the requirement needs to be clarified.

heat treatment. Also, API RP 6HT clause 6.3.1.9 shall be treated as a recommended practice only.”

US 7.10.4.2.3 Section (b) Ed Spelling mistake. Change should be “by” not “buy.”

Accepted above.

US 7.10.4.2.3 Section (b) Ed Spelling mistake. Change should be “by” not “buy.”

Accepted above.

US 7.10.4.2.3 Para (c) Te 0.2 * hydraulic RWP instead of 0.15 to 0.25 as stated previously. FAT undertake testing at 600psi.

US 7.10.5.1 Table 19 Ed Marking for Subsea Valves – Table 19 does not include PSL rating Table should include PSL rating for the valve as it

sees produced fluid. PSL level recorded on name plate.

US 7.11.2.3 Para. 2 Te API RP 6HT Section 6.3.1.9 states, “Heat treatment shall be performed by suppliers who are qualified and approved by the manufacturer.” This does not represent current industry practice. The equipment manufacturer’s do not typically “qualify” the heat treat facilities at forge shops or the various sub-contract heat treat facilities used by the forge shops. This places an unnecessary burden on manufacturers. Furthermore, the wording in the ballot, “all thermal processing” could be interpreted by some to include weld stress relieving and / or post weld heat treatment. This is not practical, so the true meaning of the requirement needs to be clarified.

Revise to read:


US 7.12.1.1 Introduction Ed Subclause 7.20.2.5 is referred to here as in the previous revision. However, the appropriate information in keeping with the previous revision is now included in subclause 7.20.2.6.

7.12.1.1 should be revised to refer to subclause 7.20.2.6.



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US 7.13.1.1 Introduction Ed Subclause 7.20.2.5 is referred to here as in the previous revision. However, the appropriate information in keeping with the previous revision is now included in subclause 7.20.2.6.

7.12.1.1 should be revised to refer to subclause 7.20.2.6.

US Annex L (Figure) Ed Subclause 7.14.2.2 refers to load chart formats as illustrated in Annex L (previous 1999 revision refers to Figure 8, bore pressure v bending moment). Annex L has been omitted from the document.

Annex L, depicting load chart information previously included in Figure 8 at the 1999 revision, should be included.

US 7.13.4 Para. 2 Te API RP 6HT Section 6.3.1.9 states, “Heat treatment shall be performed by suppliers who are qualified and approved by the manufacturer.” This does not represent current industry practice. The equipment manufacturer’s do not typically “qualify” the heat treat facilities at forge shops or the various sub-contract heat treat facilities used by the forge shops. This places an unnecessary burden on manufacturers. Furthermore, the wording in the ballot, “all thermal processing” could be interpreted by some to include weld stress relieving and / or post weld heat treatment. This is not practical, so the true meaning of the requirement needs to be clarified.

Revise to read:


GB 7.15.1 Para. 1 te The term ‘CGB’ has no definition in Section 3.2 Add a definition for the abbreviation ‘CGB’ to Section 3.2

Accepted.

Para. 2 ed The term ‘CBG’ is quoted in paragraph Amend term to read ‘CGB’

Accepted, above.

GB 7.15.2.1 Para. 1 te Wall thickness of 10 ¾ in pipe quoted as 0,5. Amend ‘10 ¾ in OD x 0,5 wall’ to read ‘10 ¾ IN OD x .5 IN’ or ‘½ IN’.

Decimal dimensions of less than one inch don’t have a zero prior to the decimal point. Ref ANSI



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Y14.5M

Note also, inch dimensions should be identified by IN and not in, whereas metric dimensions are mm.

ge Does the term ‘spatial orientation’ mean ‘angular orientation’? clarify

Para. 2 ge Does a ‘diagonal cone’ have a linear profile, as opposed to a curved profile? clarify

ed ‘outer most’ should be one word Amend text to read ‘outermost’

te The last part of the last sentence is only applicable to funnel-up scenarios and then only if the wellhead is vertical

Amend ‘and subsequently assist in righting the captured component to the vertical.’ To read ‘and subsequently assist in aligning the captured component with the wellhead or tubing head.’

ed Orientation pin minimum diameter of 101,6mm (4,0 in) Amend 4,0 in to read 4.00 in.

GB 7.15.3 Para. 1 te 1,829 m (6,0 ft) Amend to read 1.829 m (6 FT)

GB Detail a te Converted dimensions are inaccurate and post centres are over dimensioned. The linear post centre dimensions should be

reference and the metric dimensions quoted to one decimal place (2586,3 mm) as the inch dimensions are to two decimal places. The ‘TYP.’ Is unnecessary at the 90 deg dimension and the geometric tolerance box for positional tolerance of the posts. The 6 FT radius should be 1828,8 mm, which then tallies with the 2586,3 mm post centre dimensions. Note 3 dimension H, 8 FT converts to 2438,4 mm

US 7.16.5 Ed Replace 6.2 with 5.2



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US 7.18.3.5 Ed Replace “metal to material” with metal to metal

US 5.2 5.2.2 API RP 6HT was written and accepted as a Recommended Practice for Heat Treatment of pressure vessels…we should follow this practice without any other added requirements.

Remove “plus the additional requirement that the test coupon shall accompany the materials it qualifies through all thermal processing.

US 6.1.2 6.1.2.12 Non-tapered threads with metal to metal seal connections have been field proven and should be allowed Change “ Thread connections going directly into

the tree block shall have non-tapered thread with metal to metal seal if located inboard to the closure device”

US 7.1.2.2.2 7.1.2.2.2.1 line 1

Wrong Table callouts Change Table 6 to Table 7

See above

US 7.1.2.2.2 7.1.2.2.2.1 Line 2


See Above

US 7.1.2.2.2 7.1.2.2.2.1 line 3


See above

US 7.1.2.2.3 Line 1 Wrong Table callouts Change Table 9 to Table 10

See above.

US 7.1.2.5.5 Paragraph 1 “corrosion resistant alloy” excludes SS Change “corrosion resistant alloy” to CRM

US 7.1.2.5.5 Table 11 Callouts of imperial units incorrect Remove the “-“ and add (),IE: change “2 1/6” to (2 1/16)

Accepted in principle. "-"s deleted,.

US 7.3 Paragraph 1 States can use 25.4 mm (1.00”) threaded connections without any comment to pressure restrictions. Add comment that can use up to 25.4 mm (1.00”)

threaded connections in pressure ratings as allowed by ISO 10423

US 7.3 Paragraph 1, last sentence

Does not state which seal area is to be made of CRM Change”…and the sealing area…” to “…and the primary sealing area…”



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US 7.5.1 Last sentence

Wrong callout 5.1.3.4 should be 5.1.3.5

See above

US 7.5.5 First sentence

Wrong Callout 5.1.3.4 should be 5.1.3.5

See above

US 7.6.2.1 First sentence

Wrong Callout 10243 should be 10423

Accepted.

US 7.10.2.3.3 Sentence a Implied pressure Change “0,10 Mpa” to “0,10 Mpa absolute

US 7.2 API RP 6HT was written and accepted as a Recommended Practice for Heat Treatment of pressure vessels…we should follow this practice without any other added requirements.




US 7.10 7.10.2.1.4 API RP 6HT was written and accepted as a Recommended Practice for Heat Treatment of pressure vessels…we should follow this practice without any other added requirements.


US 7.10.4 Table 17 Section “B”

Add “Number of turns to open/close the valve”



US 7.11 7.11.2.3 API RP 6HT was written and accepted as a Recommended Practice for Heat Treatment of pressure vessels…we should follow this practice without any other

Remove “plus the additional requirement that the test coupon shall accompany the materials it



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added requirements. qualifies through all thermal processing.



US 8.8.1 Para. 4 Add (“A” Annulus) by sealing inside the uppermost casing hanger



US 9.4 9.4.1 Typo Change “RQP to RWP”

US Annex K As directed in June ’06 Standardization Conference, Annex K material specific to 17D to remain in 17D, and all else to go to 17A

There appears to be nothing in Annex K that is specific to 17D; all information in annex, very good information, could and should exist in 17A as it pertains to other SC 17 documents as well.

US Contents Annex J ed Spelling – (informatie) (informative)

Accepted.

US 4.2 Para 2, line 6 line 8

ed Spelling – assemly FAT not in symbols

assembly

Put FAT in symbols clause 4

Accepted. Accepted in principle. In 3.2

US 5.1.1.1 para 1 bullet 1

ed ...performance verification testing... is not in alignment with ISO TS29001 or API Q1 Change "verification testing" to "validation testing"

US 5.1.1.6 para 1 line 4 ed ...performance verification testing... is not in alignment with ISO TS29001 or API Q1 Change "verification testing" to "validation testing"



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US 5.1.1.8 title ed Venting only refers to stored energy due to pressure; other designs may have springs, etc. Change title to Stored Energy and add reference

to springs in text below.

US 5.1.2.1.8 para 1 ed ...shall comply with purchaser's/manufacturer's specifications. It is unclear who's specification if both exist will be used.

change to remove purchaser's specification. Include section in Clause 5 that adds a responsibility on the purchaser to provide appropriate information to the manufacturer.

US 5.1.2.2.1 para 1 line 4 ed temp ranges next to temp class V and U are confusing as written Add brackets [ ] around temp ranges to separate

from the text.

Accepted.

US 5.1.3.6 para 1 line 6 ed ...design verification load test... is not in alignment with ISO TS29001 or API Q1 Change "verification test" to "validation test"

US 5.1.4.2 b) te 0,38 (0,15in) is incorrect conversion 0,38 (0,015in)

US 5.1.4.7.2 para 1 ed manufacturer's documentation describing coating is insufficient to insure proper procurement change describing to specifying

US 5.1.7 title ed ...performance verification testing... is not in alignment with ISO TS29001 or API Q1 Change "verification testing" to "validation testing"

US 5.1.7 para 1 ed ...performance verification testing... is not in alignment with ISO TS29001 or API Q1 change verification to validation

US 5.1.7.2 para 1 ed ...performance verification procedures... is not in alignment with ISO TS29001 or API Q1 change verification to validation

US 5.1.7.2 para 1, line 7 ed "substantive change" is defined in the paragraph Move definition to clause 3

US 5.1.7.3 para 1 te Requirement stated to use gas for all pressure hold periods. This should only be done after a hydrostatic test using liquid has confirmed the item is safe to pressure up with gas.

Elaborate on safe testing procedures.



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US 5.1.7.3 para 1, line 2, para 2 line 1 and 2

ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 change verification to validation

US 5.1.7.5 Para 2 ed 5.1.3.2 and 5.1.3.5 are incorrect references Should be 5.1.3.3 and 5.1.3.6 respectively

See above.

US 5.1.7.6 para 1 ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 change verification to validation

US 5.1.7.7 Table 3 ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 Footnote c is left out ; footnote “e” in Table is smaller than others

change verification to validation

Add wording for footnote c

Enlarge “e” for visibility

See above.

US 5.1.7.8 para 1, line 2 ed definition stated in text for product family move definition to Clause 3

US 5.1.7.9 para 1 ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 change verification to validation

US 5.4.1 and 6.1.2

para 2 ed ...shall comply with purchaser's/manufacturer's specifications. It is unclear who's specification if both exist will be used.

change to remove purchaser's specification. Include section in Clause 5 that adds a responsibility on the purchaser to provide appropriate information to the manufacturer.

US 5.4.6.2.1 Para 1, line 1

ed Need period at end of “…testing For PSL…” “...testing. For PSL…”

Accepted.

US 6.2.1 6.2.2 6.2.3

para 1 ed definitions stated in opening sentence of requirements move definitions to clause 3

US 6.2.8 para 3; Figure 1, 2, 3 headings

ed reference to figures needs to include "flow path" change text to read: "A schematic for a typical

vertical dual bore subsea tree flow path is



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symbology used in flow path figures is not defined multiple figures in Figure 2 and 3 have no callouts

illustrated in Figure 1. Figure 2 illustrates flow paths for vertical trees with tubing heads. Figure 3 illustrates flow paths for horizontal subsea trees."

Add reference where flow path symbols can be found.

Add callouts to separate illustrations US 6.2.9 Figure 4b ed Lower L/H figure has text that is chopped off

Restore text Acceptd. Figure will be updated.

US 6.2.11 Line 4 ed Figure 1 appears to be incorrect reference Should be Figure 5

US 6.3.1 title & para ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 change verification to validation

US 6.3.2 Table 4b, 4c ed Spelling - Footnote a – “…tes.”. and Title: Tabel 4c “…test.” Table 4c

Accepted above.

US 6.5 para 1 te Reference “No part or equipment on an assembled tree shall be removed or replaced during storage or shipping unless the tree is successfully retested and then retagged.” Comment: As written, this is impossible to comply with as Trees and WH sections are tested in the largest assembly feasible, but that is seldom a practical configuration for shipping or storage. Some gaskets and end connection parts will necessarily be replaced for installation of the WH and tree. It is common accepted practice for the manufacturer and customer to agree on the assembly configurations for testing and for shipping, as this is affected by physical facilities owned by both parties. Products should not be “retagged” in the field after shipment.

Either remove this sentence altogether or change to read: “Removal or replacement of parts or equipment after testing for shipping or storage shall be as agreed with the purchaser.”

US 7.1.1 Para 6, line 3

ed Table 3 appears to be incorrect reference Should be Table 5



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US 7.1.2.1 Para 2, line 3

ed Table 5 is incorrect reference Should be Table 6

US 7.1.2.2.1 Table 6 (and other places)

ed Table 6 begins with a figure; Tolerances given in figure text have decimals Remove figures from Tables

change decimals to commas

Not accepted, figure is part of table. Accepted. Figure will be updated.

US 7.1.2.2.1 Table 6 ed Row 1 has underlined dimensions and two dimensions in one box remove underlines and/or clarify why two

dimensions are given.

US 7.1.2.2.2.1 Para 1 Para 2 Para 4, line 1

ed Table 6 is incorrect reference Table 8 is incorrect reference Table 9 is incorrect reference

Should be Tables 7 and 8

Should be Table 9

Should be Table 10

See above.

US 7.1.2.2.2.4 Para 2 ed Figure 9 is incorrect reference Should be Figure 8

See above

US 7.1.2.2.3 Line 1 ed Table 9 reference is incorrect for inlaid ring grooves Should be Table 6

See above

US 7.1.2.4 Table 7 (and other tables)

ed Size column for inches has dimension broken over two lines due to width of column increase column width to accommodate inch

measurement on one line

Accepted.

US 7.1.2.4 Table 9 ed two columns have heading of HL. Move designation of HL one row above and put Size and Tolerance on row underneath merged headings.

US 7.1.2.4 Figure 6 ed unclear where dimensions for blind flanges come from Add note to establish correct table reference

US 7.1.2.4 Figure 7 ed dimensions have decimals change decimals to commas


US 7.1.2.5.2 Line 3 ed Cites Table 9 for 17SV integral hub weld prep, but Table ?



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9 describes 17SS weldneck flanges

US 7.1.2.5.3 Table 11 ed Table shows retainer ring groove radius as “RG”, but on the figure above, it is called out as “GR” OD of 65 mm hub has 5,78ss

Needs to be “RG” on figure like tables 11 and 14

change to (5,78)

US 7.5.4 para 1 ed statement reads "which are be" correct statement

US 7.5.5 para 2 ed statement reads "fasteners using charts, similar to the one in Annex G." Annex G contains Tables change charts to tables.

Accepted.

US 7.6.1 para 2 ed statement reads "gaskets type BX gaskets" correct statement

US 7.6.3.2 para 1, line 2 ed ...should be avoided... is inconsistent with 7.5.4 which reads "shall not" correct inconsistency between the two sections

US 7.7.2.1 Line 2 ed Figures 13 and 14 seem to be the wrong reference Should be Figures 11 and 12?

US 7.8.1.2 Table 15 ed Table Headings – system designation and Bop stack… Should be System designation and BOP stack…

Accepted

US 7.8.2.1 last para (and other places in document)

ed refers to non-existent Annex L Correct references

See above

US 7.9.1.2 para 1 line 12

ed reads "shall be a the working pressure"... Correct sentence by removing a

Accepted in principle. See change above.

US 7.10.2.1.2 Table 16 ed table lists design and operating parameters move table to text like the rest of the document when design parameters are given

US 7.10.2.2.2 para b) ed SIT is not defined add SIT to symbols clause 4

Accepted. Will be updated in 3.2

US 7.10.4.1.1 para 1 ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 change verification to validation



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US 7.10.4.2.2 Tables 17a, b, c

ed footnote uses * to reference change to a

US 7.10.4.2.3 para b) line 5

ed text reads "not damaged buy" change to "not damaged by"

Accepted above

US 7.10.5.1 Table 19 ed row numbers go from 3 to 7 change row numbers

Accepted.

US 7.15.2.3 Para 8 ed No closing parenthesis at end of deflection; Add closing parenthesis at end of deflection);

Accepted.

US 7.15.3 Figure 9 ed Figure 9a) on L/H side shows 1830 mm R vs. 1,829 m in subclause 7.15.3 text, line 2 Make text and Figure 9a) agree – change Figure

to 1829 mm (which is consistent with 2586 mm)

US 7.17.2.5 para 1 ed statement reads .."manufacturer shall document" change to say "manufacturer shall verify"

US 7.18.4.2 title ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 change verification to validation

change verify to validate

US 7.21.2.1.4 para 2, line 4 ed guide lines is stated as two words change to guidelines

Accepted.

US 7.21.3.2.5 Lines 23 & 24

ed Use of “if any” and “-– n/a” is redundant Remove “—n/a”

US 7.21.3.3 Para b) last line

ed Subclause 7.22.4.2 does not exist – wrong reference Reference should be subclause 7.21.4.2

US 7.21.4.2.3 Para 3, Line 3 Para 4, Line 2

ed Table 26 is marking, not performance data Table 24 refers to hydraulic actuators, not manual

Should it be Table 25?

Change to Table 23 which refers to manual

US 7.22 title and following

ed These paragraphs are separated from the rest by Tables 26 through 29. move to following Tables 26 through 29 so it aligns

Not accepted.



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clause with text following

US 7.22.1 para 1, line 2 ed text reads: "This identifies requirements for some common tools". add reference to clause.

US 8.2.2.1 last para ed sentence does not end with period add period

accepted

US 8.2.2.2 Para e) te 2 m3 is not (75 ft3) 75 ft3 should be 70.6 ft3

US 8.2.3 para 1 ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 subclause 5.1.7.5 is referenced


should the reference be to 5.1.3.6?

US 8.3.2.1 Line 7 ed Figure 10 refers to chokes Should be Figure 12

US 8.3.3. para 1 ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 subclause 5.1.7.5 is referenced



US 8.4.1 Para 3 ed etc needs punctuation Should be “ …hydrates, etc. may…”

Accepted.

US 8.4.2.2 Line 4 ed 950 mm is not 37,38 in Should be 37,40 in

US 8.4.4 para 1 ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 subclause 5.1.7.5 is referenced



US 8.5.3 para b) ed refers to Figure 13 Should be Figure 14

US 8.5.4 Line 1 ed refers to Figure 13 Cannot find Annex L Should be Figure 14

US 8.6.3.1 title & para 1 ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 change verification to validation



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subclause 5.1.7. is referenced should the reference be to 5.1.3.6?

US 8.7 entire section

ed no reference made to testing annulus seals add reference to performance validation testing

US 8.8.3.1 para 1 ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 subclause 5.1.7 is referenced



US 9.1 clause c) line 2 ed hanger is spelled hangar change hangar to hanger

Accepted above

US 9.4.1 title & para 1 line 1 Line 2

ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 RQP is not recognized


Should be RWP

See above.

US 10.1.2.2 Table 33 ed table lists definitions for different stresses in the table just above the acceptable values NOTE 1 and 2 are requirements and not information

Add column to table for definitions of stresses to the left of the values columns

Move NOTES to paragraph of requirements

US 10.1.3.1 NOTE 2 ed NOTE 2 is a requirement move NOTE 2 to paragraph of requirements

US 10.1.4.1 para 1 ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 subclause 5.1 is referenced



US 1.3.2.3 para 1 te maximum particle size has no meaning without specifying when particle size is important change text to read: "Maximum particle size during

periods of flowby shall be ....


ed no reference made to testing casing hangers add reference to performance validation testing


ed no reference made to testing casing hanger running tools add reference to performance validation testing



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US 11.3.3 Para b) ed Figure 16 not correct reference Should be Figure 14

US 11.4.3.1 para 1 ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 subclause 5.1.7 is referenced



See above.

US 11.4.3.2 Line 3 ed Table 36 is not correct reference Should be Table 35

US 12.1 para 1 ed guide lines is stated as two words change to guidelines

Accepted

US 12.3 Figure 15 ed Second box on upper R/H shows 69,0 M{a? Should be 69,0 Mpa

Accepted

US 12.5 entire clause ed entire clause are recommended means of gathering design data from user Move to informative Annex to get out of

requirements part of specification.

US 12.5.2 Para b) Para e) Para e)

ed FWHP and SIWP use bar instead of Mpa Wellhead working pressure rating use bar instead of Mpa Distance from mudline to top… show metric values

Use Mpa for consistency with rest of document


Should be “3-4.6 m (10-15 feet)”

US 12.5.3 Para b) Para c) Para c) Para f) Para f) Para g) Para m) Para r) & s) Para z)

ed FWHP and SWIP use bar instead of Mpa Reservoir pressure uses bar instead of Mpa H2S and CO2 use bar pp instead of Mpa pp Wellhead working pressure rating uses bar not Mpa Distance from mudline to top… show metric values Separator pressure uses bar instead of Mpa Working pressure rating uses bar instead of Mpa specify is misspelled specifiy Gas lift pressure uses bar instead of Mpa



Use Mpa pp for consistency with rest of document


Should be “3-4.6 m (10-15 feet)”




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correct spelling

Use Mpa for consistency with rest of document US Annex A, B,

C, E Figures ed Callouts contained within figure containing text

Move text to legend box to make translation easier

US Annex E.2.4 Figures E.4 ed “Figures” in title Should be Figure

Accepted

US Annex E.2.5 Line 10 ed Reference to Figure E.3 appears to be in error Should it not be Figure E.4?

US Annex F Figure F.1 ed Text at bottom of Figure is illegible Clarify text

US Annex G Table G.3 ed footnote called out as 1 and not a correct callout to a

US Annex G Table G.4 para b)

ed 0.125 uses decimal change to comma

Accepted

US Annex H entire annex te Annex stated as informative should this annex be normative and not informative

US Annex H H.3.2 ed Subclause 5.1.4.8 is incorrect reference Should be 5.1.4.7

US Annex H H.4.1 ed ...performance verification ... is not in alignment with ISO TS29001 or API Q1 subclause 5.1.7 is referenced



US Annex H H.4.2 ed last word is rating working pressure should be rated working pressure

accepted

US Annex I I.3.1 ed 3 references for grit blasting are called out should only one of the three be required?



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US Annex J J.2.1.2.1 a) J.2.1.2.1 f)

ed 100 cm3 (6 in3) not properly expressed …20 ºC ? 1 ºC (68 ºF ? 2 ºF)… Should be 100 cm3 (6.1 in3) like rest of document

Not sure what is intended???

US Annex J J.3.1.1 a) ed O-Ring size -214 – not clear for non-metallic seal? 100 cm3 (6 in3) not accurate conversion Say, “Seal with equivalent volume greater than…”

Should be 100 cm3 (6.1 in3)

US Annex J J.4.1, Para 6 and 7, Line 3

ed 100 cm3 (6 in3) not properly expressed Should be 100 cm3 (6.1 in3) like rest of document

US Annex J J.4.2 ed 100 cm3 (6 in3) not accurate conversion Should be 100 cm3 (6.1 in3)

US Annex K K.2.3.1 ed Manufacturing tolerances show no units These appear to be inches – if so, need metric equivalents as primary units

US Annex K K.2.3.3 ed Key notes that C, N, F need definitions Supply terminology for C, N, F

US Annex K K.2.3.5 ed Figure shows R = .13 inch only Need metric conversion as primary

US Annex K Table K.1 ed Application phrase – “Factor/fat/sit, land…” Should read, Factor/FAT/SIT/, land…”

Accepted.

US Annex K K.3.2 ed Subclause 5.3.1.2 does not exist; 5.1.3.5 does not apply Subclause 5.1.3.5 should be subclause 5.1.3.8

US Annex K K.4.2, Line 2 ed 5.4.3 reference is incorrect Should be 5.4.4

US 5.4.4 Para 2, Line 5

ed …tested with magnetic particles… is incorrect terminology…tested with magnetic particle…

US Annex L te Proposed new Annex L to be re-instated As this is a Normative Annex, change the title to Performance VALIDATION of Wellhead Connectors. This is in keeping with latest ISO terminology used in ISO 9001 and ISO TS29001.



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Also this annex should be limited to test requirements and procedures ONLY. Requirements for calculations come under VERIFICATION requirements and should be contained in a Design Verification clause within the main body text.

US p. 2, subclause 1.2

Mudline suspension systems: tubing spools; Mudline suspension systems:

tubing heads;

US p. 5, clause 2

ISA-SP75.01, Control Valve Sizing Equations Hyphen should be replaced with a space between ISA and SP75. Should read:

ISA SP75.01, Control Valve Sizing Equations

US p. 5, clause 2

Numerous references to NORSOK M-CR-710 in Annex J. Noted from current balloting: ISO 13628-1 is referring to the same NORSOK standard as “NORSOK M-710”.

Add:

NORSOK M-710, Qualification of non-metallic sealing materials and manufacturers (to be replaced by ISO 23936)

at the end of the reference list for consistency between 13826-1 and -4 documents.

US p. 7, subclause 3.1.28

high pressure riser tubular member which extends the wellbore from the mudline wellhead or tubing spool to a surface BOP

high pressure riser

tubular member which extends the wellbore from the mudline wellhead or tubing head to a surface BOP

US p. 11, subclause 5.1.7.7

Life cycle/endurance testing, such as make-break tests on connectors and operational testing of valves, chokes, and actuators, is intended to evaluate long-term wear characteristics of the equipment tested. Such tests may

Since Annexes L and M have been removed, the text should read:



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be conducted at a temperature specified by the manufacturer and documented as appropriate for that product and rating. Table 4 lists equipment which shall be subjected to extended life cycle/endurance testing to simulate long-term field service. For these life cycle/endurance tests, the equipment shall be subjected to operational cycles in accordance with the manufacturer's performance specifications (i.e. make up to full torque/ break out, open/close under full rated working pressure) (refer to Annex M for suggested reliability calculations). Connectors, which include stabs shall include a full disconnect/lift as part of the cycle. Additional specifications for life cycle/endurance testing of the components listed in Table 4 may be found in the equipment specific clauses covering these items (clause 6 through clause 11) and Annex L. Secondary functions, such as connector secondary unlock, shall be included in this testing. The total number of pressure, temperature, and hyperbaric testing cycles may cumulatively be applied to the total number of cycles specified for endurance cycle testing. For example, the 200, 3, and 200 pressure/temperature/hyperbaric cycles used to test a valve can cumulatively qualify as 403 cycles toward the 600 total cycles needed for endurance cycling.

Life cycle/endurance testing, such as make-break tests on connectors and operational testing of valves, chokes, and actuators, is intended to evaluate long-term wear characteristics of the equipment tested. Such tests may be conducted at a temperature specified by the manufacturer and documented as appropriate for that product and rating. Table 3 lists equipment which shall be subjected to extended life cycle/endurance testing to simulate long-term field service. For these life cycle/endurance tests, the equipment shall be subjected to operational cycles in accordance with the manufacturer's performance specifications (i.e. make up to full torque/ break out, open/close under full rated working pressure). Connectors, which include stabs shall include a full disconnect/lift as part of the cycle. Additional specifications for life cycle/endurance testing of the components listed in Table 3 may be found in the equipment specific clauses covering these items (clause 6 through clause 11). Secondary functions, such as connector secondary unlock, shall be included in this testing. The total number of pressure, temperature, and hyperbaric testing cycles may cumulatively be applied to the total number of cycles specified for endurance cycle testing. For example, the 200, 3, and 200 pressure/temperature/hyperbaric cycles used to test a valve can cumulatively qualify as 403 cycles toward the 600 total cycles needed for endurance cycling.

In addition, references to Annex L (footnote C)



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should be removed from Table 3. Also footnote F’s comments should be in a smaller font.


Pressure ratings shall comply with the following paragraphs. Where small diameter lines, such as SCSSV control lines or chemical injection lines, pass through a cavity, such as the tree/tubing hanger cavity, equipment bounding that cavity shall be designed for the maximum pressure in any of the lines, unless a means is provided to monitor and relieve the cavity pressure in the event of a leak in any of those lines. In addition, the effects of external loads (i.e. bending moments, tension), ambient hydrostatic loads and fatigue shall be considered.

Pressure ratings shall comply with the following paragraphs. Where small diameter lines, such as SCSSV control lines or chemical injection lines, pass through a cavity, such as the tree/tubing hanger cavity, equipment bounding that cavity shall be designed for the maximum pressure in any of the lines, unless a means is provided to monitor and relieve the cavity pressure in the event of a leak in any of those lines (See subclauses 7.9.1.2 and 9.2.7 for additional information.) In addition, the effects of external loads (i.e. bending moments, tension), ambient hydrostatic loads and fatigue shall be considered.


Procedures for hydrostatic pressure testing of equipment specified in clause 6 through clause 11 shall conform to the requirements for PSL 2 or PSL 3 as described in ISO 10423, with the exception that parts may be painted prior to testing.

Procedures for hydrostatic pressure testing of equipment specified in clause 6 through clause 11 shall conform to the requirements for PSL 2 or PSL 3 as described in ISO 10423, with the exception that parts may be painted prior to testing. Each valve shall be functioned fully open then closed between pressure tests.

US p. 28, subclause 5.4.6.2.1 (and table of contents for 5.4.6.2.1)

5.4.6.2.1 Hydrostatic body and seat test valves and chokes A hydrostatic body test and hydrostatic valve seat tests shall be performed prior to any gas testing For PSL 3G equipment, the hydrostatic seat tests may be run for opening against full differential pressure stress test of the sealing surfaces and drive trains as described in ISO 10423 subclause 7.4.9.4.5.a, in which case the requirements for hold times, monitoring of leakage, hydrostatic pressure test records, and chart recorder are

5.4.6.2.1 Hydrostatic body and seat test for valves and chokes

A hydrostatic body test and hydrostatic valve seat tests shall be performed prior to any gas testing For PSL 3G equipment, the hydrostatic seat tests may be run for opening against full differential pressure stress test of the sealing surfaces and drive trains as described in ISO 10423 subclause



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not applicable. 7.4.9.4.5.a, in which case the requirements for hold times, monitoring of leakage, hydrostatic pressure test records, and use of a chart recorder are not applicable. Each valve shall be functioned fully open then closed between pressure tests.


Any penetrations into the production (injection) flow stream of the subsea tree shall be made downstream (upstream – injection) the lowest (or innermost) master valve. Flanges, clamp hubs or other end connections meeting the requirements of clause 7, as applicable, shall be used to provide connections for the penetrations to the tree. There shall be at least two fail closed pressure closures, one of which shall be an actuated fail closed valve, between the wellhead and any penetration leading into the production (injection) path of the tree or tubing spool. As the master valve is fail closed it may be classed as one of the two fail closed pressure closures. There shall be at least two testable pressure closures, one of which shall be an actuated fail-closed valve, between the wellhead and any penetration leading into the annulus path of the tree or tubing spool.

The first sentence contradicts figures 4a & 4b. The subclause should be rewritten as follows:

There shall be at least two fail closed pressure closures, one of which shall be an actuated fail closed valve, between the wellhead and any conduit penetration leading into the production (injection) path of the tree or tubing head. The master valve may be used as one of the barriers for conduit penetrations downstream of the master valve. There shall be at least one pressure closure between the wellhead and any penetration leading into the annulus path of the tree or tubing head.

Sealed sensor devices with two or more pressure containing sealing barriers may be directly attached to the penetration without additional barrier devices, so long as the sensor device has at least the same design ratings as tree or tubing head body it is connected to.

Flanges, clamp hubs or other end connections meeting the requirements of clause 7, as applicable, shall be used to provide connections for the penetrations to the tree or tubing head.


At least one pressure-controlling closure shall be used at all SCSSV control line penetrations that pass through either the tree or tubing spool. Manual valves (diver/ROV

At least one pressure-controlling closure shall be used at all SCSSV control line penetrations that



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operated) are acceptable closing devices.

pass through either the tree or tubing head. Manual valves (diver/ROV operated) are acceptable closing devices.

US p. 50, Table 6

Columns E G and N list “over and under” machining dimensions for the SBX 149 gasket. There is some confusion regarding its designation and how tolerances should be applied.

At least one pressure-controlling closure shall be used; add a footnote b) to E G and N figure captions and add footnote:

b Dimensions listed as yyyyxxxx

are considered the maximum dimension (xxxx) and the minimum dimension (yyyy), overriding the nominal tolerances to accommodate certain geometries

to the bottom of the table.

Alternately to list the notation as subclause part d) to subclause 5.1.4.2

US p. 57, Figure 7

Smallest diameter dimension is shown as an “over and under” There is some confusion regarding its designation and how tolerances should be applied.

Add a note below the Figure 7 caption:

NOTE Dimensions listed as yyyyxxxx

are considered the maximum dimension (xxxx) and the minimum dimension (yyyy), overriding the nominal tolerances to accommodate certain geometries.

Alternately to list the notation as subclause part d) to subclause 5.1.4.2

US p. 68, subclause 7.8.1.2 (and table of

Tree/tubing head spool connectors Three types of tree/tubing spool connectors are commonly used …

Tree/tubing head connectors

Three types of tree/tubing head connectors are



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contents for 7.8.1.2)

All connectors shall be designated by size, pressure rating and the profile type of the subsea wellhead to which they will be attached (refer to Table 15). Tree/spool connectors shall conform to maximum standard pressure ratings of 34,5 MPa (5 000 psi), 69 MPa (10 000 psi) or 103,5 MPa (15 000 psi), as applicable. Body proof testing shall be conducted at 1,5 times the pressure rating. The design and installed preload should give consideration to possible higher pressure from an SCSSV seal sub leakage in the gallery inside the tree connector.

commonly used …

All connectors shall be designated by size, pressure rating and the profile type of the subsea wellhead to which they will be attached (refer to Table 15). Tree/tubing head connectors shall conform to maximum standard pressure ratings of 34,5 MPa (5 000 psi), 69 MPa (10 000 psi) or 103,5 MPa (15 000 psi), as applicable. Body proof testing shall be conducted at 1,5 times the pressure rating. The design and installed preload should give consideration to possible higher pressure from an SCSSV seal sub leakage in the gallery inside the tree connector.


The manufacturer shall document the load/capacity for the tree or tubing head connector using the load chart format illustrated in Annex L.

Since Annex L has been removed, the text should read:

The manufacturer shall document the load/capacity for the tree or tubing head connector. The manufacturer shall state whether the basis is stress or seal separation limited.


The manufacturer shall specify the loads/conditions for which the equipment is designed. The manufacturer shall document the load/capacity for their tree/tubing head connector if applicable using the load chart format illustrated in Annex L.


The manufacturer shall specify the loads/conditions for which the equipment is designed. The manufacturer shall document the load/capacity for their tree/tubing head connector if applicable. The manufacturer shall state whether the basis is stress or seal separation limited.



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Means shall be provided for testing all primary seals in the connector cavity to the rated working pressure of the tree/spool connector or tubing hanger, whichever is lower.

Means shall be provided for testing all primary seals in the connector cavity to the rated working pressure of the tree/tubing head connector or tubing hanger, whichever is lower.

US pp. 80-82, Tables 17a, 17b, and 17c

The hydrostatic seat blowdown test mentioned in 10423 is inconsistent with the tables and 17c mentions 3x tests, when there should actually be two.

See revised tables below:


The manufacturer shall specify the loads/conditions for which the equipment is designed. The manufacturer shall document the load/capacity for their tree cap running tool connector if applicable using the load chart format illustrated in Annex L.


The manufacturer shall specify the loads/conditions for which the equipment is designed. The manufacturer shall document the load/capacity for their tree cap running tool connector if applicable. The manufacturer shall state whether the basis is stress or seal separation limited.


The manufacturer shall specify the loads/conditions for which the equipment is designed. The manufacturer shall document the load/capacity for their tree running tool connector using the load chart format illustrated in Annex L, which relates pressure to allowable bending moment for various tensions. The manufacturer shall state whether the basis of the graphs are stress limits or seal separation limits.


The manufacturer shall specify the loads/conditions for which the equipment is designed. The manufacturer shall document the load/capacity for their tree running tool connector, which relates pressure to allowable bending moment for various tensions. The manufacturer shall state whether the basis is stress or seal separation limited.

US p. 106, subclause

Injection lines, connector/gasket seals test lines and pressure monitor lines shall be rated at the working Injection lines, downhole hydraulic,

connector/gasket seals test lines, pressure monitor



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7.20.2.2 pressure of the tree and the SCSSV lines shall be rated at the specified SCSSV operating pressure.

lines, or any line with a potential to see well bore fluids shall be rated at the working pressure of the tree. SCSSV lines shall be rated at the specified SCSSV operating pressure (See subclauses 7.9.1.2 and 9.2.7 for additional information.)


The RWP for the wellhead housing pressure boundary (refer to Figure 13) shall be 34,5 MPa (5 000 psi), 69 MPa (10 000 psi) or 103,5 MPa (15 000 psi). Selection of the rated working pressure should consider the maximum expected SCSSV operating pressure (refer to subclause 5.1.2.1.1). The manufacturer of the wellhead connector shall provide gasket sealing limits as a function of hub face separation for internal pressure and external hydrostatic pressure using the load chart format illustrated in Annex L.


The RWP for the wellhead housing pressure boundary (refer to Figure 13) shall be 34,5 MPa (5 000 psi), 69 MPa (10 000 psi) or 103,5 MPa (15 000 psi). Selection of the rated working pressure should consider the maximum expected SCSSV operating pressure (refer to subclause 5.1.2.1.1). The manufacturer shall specify the loads/conditions for which the equipment is designed. The manufacturer shall document the load/capacity for their wellhead connector, which relates pressure to allowable bending moment for various tensions. The manufacturer shall state whether the basis is stress or seal separation limited.

US p. 143, subclause 9.1

The tubing hanger system is comprised of a tubing suspension device called a tubing hanger and an associated tubing hanger running tool and in certain cases an orientation joint. This part of ISO 13628 is limited to tubing hangers which are landed in a wellhead, tubing spool or horizontal tree. A tubing annulus seal is effected between the tubing hanger and casing hanger or tubing hanger and spool, and the hanger is locked in place. It is designed to provide a means for making a pressure-tight connection between the tubing string(s), tubing annulus and the corresponding subsea tree or

The tubing hanger system is comprised of a tubing suspension device called a tubing hanger and an associated tubing hanger running tool and in certain cases an orientation joint. This part of ISO 13628 is limited to tubing hangers which are landed in a wellhead, tubing head or horizontal tree. A tubing annulus seal is effected between the tubing hanger and casing hanger or tubing hanger and tubing head or horizontal tree body, and the hanger is locked in place. It is designed to provide



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tubing hanger running tool bores. It may also provide a continuous means of communication or control SCSSVs, electrical transducers and/or other devices. There are three basic types of tubing hangers:

a means for making a pressure-tight connection between the tubing string(s), tubing annulus and the corresponding subsea tree or tubing hanger running tool bores. It may also provide a continuous means of communication or control SCSSVs, electrical transducers and/or other devices. There are three basic types of tubing hangers:


The OD of the tubing hanger system shall be compatible with the ID of the BOP stack and marine riser system being used. Particular attention shall be given to the design of the lock and seal mechanisms to minimise the risk of them hanging up during installation or retrieval. The design should keep diameters to the minimum and minimise the length of large diameters in order to ease running and retrieving of the tubing hanger system through the ball/flex joint. The operating procedures should advise the limiting ball/flex joint angle for running and retrieving of the tubing hanger system. The design of tubing hanger systems shall comply with subclause 5.1. Ideally irrespective of orientation system, the seals shall not engage in the sealing bore until the orientation is complete. Typical orientation devices are, keys engaging in slots in the BOP connector, orienting bushings/cams temporarily installed in the BOP connector, orienting bushings/cams permanently installed in the tubing head spool or horizontal tree and extending pins in the BOP stack used in conjunction with a camming profile on the running tool or orientation joint.

The OD of the tubing hanger system shall be compatible with the ID of the BOP stack and marine riser system being used. Particular attention shall be given to the design of the lock and seal mechanisms to minimise the risk of them hanging up during installation or retrieval. The design should keep diameters to the minimum and minimise the length of large diameters in order to ease running and retrieving of the tubing hanger system through the ball/flex joint. The operating procedures should advise the limiting ball/flex joint angle for running and retrieving of the tubing hanger system. The design of tubing hanger systems shall comply with subclause 5.1. Ideally irrespective of orientation system, the seals shall not engage in the sealing bore until the orientation is complete. Typical orientation devices are, keys engaging in slots in the BOP connector, orienting bushings/cams temporarily installed in the BOP connector, orienting bushings/cams permanently installed in the tubing head or horizontal tree body and extending pins in the BOP stack used in conjunction with a camming profile on the running tool or orientation joint.



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The tubing hanger lockdown mechanism amd Mis-spelling “and”

accepted

US p. 183, Annex A

Major items of equipment in a subsea tree are: completion guidebases and tubing head spools;

Major items of equipment in a subsea tree are:

completion guidebases and tubing head bodies;

US p. 191, Annex D

Subsea tubing hangers are located in the wellhead, tubing spool (wellhead conversion assembly) or horizontal tree. After installation the tubing hanger is locked into the mating wellhead, spool, etc. to resist the force due to pressure in the production casing and to resist thermal expansion. Lock mechanisms may be mechanically or hydraulically actuated depending on water depth and specific project requirements.

Subsea tubing hangers are located in the wellhead, tubing head (wellhead conversion assembly) or horizontal tree.

After installation the tubing hanger is locked into the mating wellhead, tubing head, etc. to resist the force due to pressure in the production casing and to resist thermal expansion. Lock mechanisms may be mechanically or hydraulically actuated depending on water depth and specific project requirements.

US p. 222-3, subclauses J.4.1, and J.4.2 (Annex J)

Numerous references to NORSOK M-CR-710 in Annex J. Noted from current balloting: ISO 13628-1 is referring to the same NORSOK standard as “NORSOK M-710”.

Change all references in 13628-4 from:

“NORSOK M-CR-710” to “NORSOK M-710”

Also revise the reference title to M-710 as:

NORSOK M-710, Qualification of non-metallic sealing materials and manufacturers (to be replaced by ISO 23936)



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for consistency between 13628-1 and -4 documents.

US p. 229, Table K.1 (Annex K)

The first line of Table K.1 reads: Factor/fat/sit, land, and dockside lifts The first line of Table K.1 should read:

Factory FAT/SIT, land, and dockside lifts

Accepted above.

US Annex L Removed prior to DIS publication. We advise that Annex L be reinstated, as uniform structural performance requirements are a necessary for proper external load analyses as stipulated in 13628-7

If it is reinstated, disregard the editorial comments to subclauses 5.1.7.7, 7.8.2.1, 7.8.2.2, 7.14.2.2, 7.16.3, 8.5.4 and Table 3.

GB 5.1.7.3 te 1st paragraph states “Gas shall be used as the test medium for all pressure hold periods (leak tests). This statement is far too general and could add significant safety risk (ie large items with high pressure gas in them) without any benefit, it will also effect cost and schedule. Examples of where gas could be substituted by a fluid.

• Hydraulic controls system parts. • Equipment that inherently has an acceptable

leakage rate, e.g. flow-meters

It is suggested that the wording of this section be changed as follows;

“Gas shall be preferably used as the test medium for all pressure hold periods (leak tests). However subject to agreement between the operator and contractor another test medium may be used.

GB 7.18.3.5 ed 3rd paragraph has a typing mistake “Primary seals on flowline connectors shall be metal-to-material” Should read “Primary seals on flowline connectors

shall be metal-to-metal”

See above.



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GB 7.18.3.5 te 6th paragraph is far too restrictive with respect to the choice of connection system that can be used. In-particular for, quote “without the need to retrieve the Subsea flowline/umbilical to the surface” . It may be perfectly acceptable, safe and more economically viable to retrieve these items to the surface prior to the tree being removed.

It is suggested that the wording of this section be changed as follows;

“The flowline connector design should provide a means to disconnect and remove the tree (and to subsequently replace it) where practical, this should be without the need to retrieve the Subsea flowline/umbilical to the surface. Consideration should be given to preventing seawater from entering into the flowline when separated from the tree.”

GB 7.20.3.2 te The method of demonstrating, by certification, what the final hydraulic cleanliness is should be stated. It is suggested that the following is added at the

end of the current paragraph.

A method of final certification of cleanliness level shall be agreed between the operator and contractor. For example for water based fluids certification will use optical microscope counting technique in accordance with ISO 4407.

GB

GB 7.21.8 Tables 26 to 29

te Control fluid cleanliness certification requirements should be include in the relevant table for marking on the choke assemblies.

Control fluid cleanliness certification requirements should be include in the relevant table for marking on the choke assemblies.

GB 8.3.2.4 Bullets a) thru I)

ed Should this section refer to the GRA as well as the PGB? In this section where PGB is noted should it state “PGB (GRA)”

GB 11.1 ed 2nd paragraph final sentence the use of the wording “weighing” may be confusing. Suggest replacing the word “weighing” with

“consideration”



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GB 11.2 ed 1st paragraph word missing. Word missing. Put the word “be” in-between “shall” and “designed”

Accepted above

GB 12.5 c) ed Spelling mistake Cusomter should read customer

Accepted

** Foreword, Clause 2

A new version of Part 2 has recently been published with the new part title: Part 2: Unbonded flexible pipe systems for subsea and marine applications

** Foreword The title to Part 5 is listed as Part 5: Subsea umbilicals (although this part is under review)

Accepted

** Foreword Add parts 10 (Part 10: Specification for bonded flexible pipe) and 11 (Part 11: Flexible pipe systems for subsea and marine applications)

Accepted

** Foreword Add: A Part 12, dealing with dynamic production risers, and Part 13, dealing with Remotely Operated Tool and interfaces on subsea production systems, are under development.

Accepted

** Scope The Scope is informative, e.g. cannot contain permissions (=may; 1.1 third sentence) or requirements (=shall; 1.3 last sentence). It is necessary to put his latter requirement somewhere in the body of the document for it to be normative, i.e, a requirement.

** Clause 2 The last part of the title for 10423 is -- Wellhead and christmas tree equipment; there is no addendum (errata 1) for this edition. It should be dated (2003) as specific elements are cited (see 4.1.3 to 4.2)

** Clause 2 ISO 11960:2004 must be dated (see 10.1.4.2.2)

** Clause 2 ANSI does not seem to be included in the listed title of the last four documents listed on page 4.



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** Clause 2 The listed title for ASME B16.11 is Forged Steel Fittings, Socket-Welding and Threaded

Accepted

** Clause 2 The listed title for SAE J343 is Test and Test Procedures for SAE 100R Series Hydraulic Hose and Hose Assemblies

Accepted

** Clause 2 The listed designation is API RP 5B and the listed title is Specification for Threading, Gauging, and Thread Inspection of Casing, Tubing, and Line Pipe Threads (US Customary Units)

Accepted

** Clause 2 The listed designation is ANSI/AWS D1.1 and the listed title is Structural Welding Code - Steel

Accepted

** Clause 2 The listed designation is ANSI/ISA SP75.02.

** Clause 2 The listed designation is SAE/AS 4059 and the listed title is Aerospace fluid power – Cleanliness classification for hydraulic fluids

** Clause 2 NACE 2, ISO 8501-1 and SSPC should be added to the normative references list. (See I.3.1) and deleted from the Bibliography.

Accepted

** Clause 2 ASTM 1414 should be added to the normative references list. (See J.2.1.2.1 f))

Acce[ted

** Clause 3 The title should be terms, abbreviated terms, definitions and symbols

Accepted

** 3.1.14, 5.1.2.3.2, etc.

Reference to ISO 15156 should mention either a specific part or (all parts).

All parts, accepted

** 3.1.38, 3.1.49, etc.

The terms should be listed first then the abbreviation on a separate line

Accepted



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** 3.2 The abbreviated terms and symbols list should contain all the symbols used. See comments for G.1.3, K.2.3.1, Please verify that the symbols are unique, (e.g no symbol has more than one definition) and reformat those that are not. For example, as the document stands, P is defined in G.3.1 as the pitch diameter and in K.3.4.2 as the maximum vertical load. One of these must be changed.

** 4.1.3, 4.1.4, 5.1.3.5, etc.

ISO 10423 should be dated 2003, e.g. ISO 10423:2003, table....

Accepted

** 4.2 second § Is the referenced 5.4 in ISO 10423 or this part of ISO 13628?

** 5.1.1.1 and following

Clauses are cited as "see Clause X" (with Clause capitalized). Subclauses are cited as "see 5.1.7 without including "subclause". (The note in Table 1 is correct)

Accepted

** 5.1.2.2.1, 6.2.11, Tables 6 to 14 and associated graphics; G.2.3, etc.

Use of the period or the comma for USC units; your choice but please verify consistency throughout: Specifically In 5.1.2.2.1, (-0.4 °F) but in 6.2.11 (1,00 in.). See also Tables 6 to 14 and associated graphics, G.2.3,

Accepted

** 5.4.6.2.3 i). Tolerances should be given in absolute values when possible; e.g. (2 +/-0,2) MPa rather than 2 MPa +/- 10 %

** 5.5.4 References to sections of a document other than in this part of ISO 13628 should follow the number of the document, e.g. ISO 10423:2003, Table 2 and G.2 "...in accordance with Table 2 and G.2 of ISO 10423" leaves room for doubt as to whether the Table 2 is in 10423 or this part of ISO 13628.

** Figures There should be no language-dependent labels on the figures. Items in a figure requiring such a language-

Accepted, figures will be



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dependent labels should be numbered and the labels listed by number in a key below the figure but above the figure title.

updated.

** Figure 4b In the lower tow figures, parts of some of the labels (annulus ISO and Tubing head) have been cut off.

Accepted.

** 8.3.2.1 first 2 items in list

conductor pipe /housing mass ?or load (rather than weight), if the units are grams; weight is acceptable for the jetting string if it is indeed a force (downward) denominated in units of newtons.

** 8.6.2.1, 9.2.2, 11.4.2.1, H.2.1, etc.

suspended mass ?or load; see comment above

** 9.2.9 3rd § "However, the check value shall not..." rather than " must not..."

Accepted.

** 10.1.4.2.2 ISO 11960:2004 must be dated

** 10.3.1.1 support casing mass ?or load; see comment for 8.3.2.1

** 10.6.2 5th § "... material availability shall be examines..."." rather than " must..."

Accepted.

** 12.5.2 b), e), etc.

bar is a metric but not SI unit. The pressure should be given in pascals (followed by the value in bars if desired)

Accepted, will be updated to Pa.

** 12.5.3 k) Normally, the ranges should be specified such that a depth can belong to one and only one category; e.g. 100 to <300 m, 300 m to <915 m, etc.

** 12.5.3 m) - chlorides

ppm is a deprecated unit. use a mass or volume ratio or a concentration unit like mg/l; see also above comment on ranges.



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** Figures B.1, D.3, D.4

The colour will be removed unless it is absolutely necessary.

Accepted.

** G.1.3 The symbols used for the equations should be listed in the abbreviated terms and symbols clause. As the document stands, P is defined in G.3.1 as the pitch diameter and in L.3.4.2 as the maximum vertical load. One of these must be changed.

** I.3.1 NACE 2, ISO 8501-1 and SSPC should be added to the normative references list. and removed from the Bibliography. This will require that the Bibliographic citations in the text be renumbered.

Accepted.

** J.2.1.2.1 f) ASTM 1414 should be added to the normative references list.

Accepted

** Annex K equations The equations should be numbered, beginning with Equation (K.1)

Accepted.

** K.2.3.1 The symbols used for the equations should be listed in the abbreviated terms and symbols clause.

Accepted.

** K.3.3.3 SWL is not an allowable symbol to be sued in mathematical equations. Something of the form FSWL is suggested.

** K.3.4.2 As the document stands, P is defined in G.3.1 as the pitch diameter and in K.3.4.2 as the maximum vertical load. One of these must be changed.

TG agrees with the intent of the 13628-1 TG to change to definition of corrosion-resistant alloys (CRA) at 3.1.14 to the one used in 15156-1 (NACE



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MR0175); i.e., alloy intended to be resistant to general and localized corrosion of oilfield enironments that are corrosive to carbon steels. However, the 13628-4/17D task group will monitor the progress of this issue within 10423/6A which will have a DIS out for ballot by 30 Nov 2007.

result of voting approved - home - mycommittees to review... · dnv rp b401, cathodic protection...

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