template for comments and secretariat observations

Template for comments and secretariat observations Date: 2004-06-01 Document: ISO/DIS 13628-1

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Clause No./ Subclause No./

Annex/Figure/Table(e.g. 3.1, Table 2)

Paragraph/ List item/

Note (e.g. Note 2)

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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) ** = ISO/CS editing unit 2 Type of comment: ge = general te = technical ed = editorial NB Columns 1, 2, 4, 5 are compulsory.

page 1 of 96 ISO electronic balloting commenting template/version 2001-10

BR.001 3.2 p. 4 te 99 We suggest to write descriptions

Descriptions to abbreviations? Not accept. Descriptions are given in TR 172

BR.002 5.5.2.12 1st § ed “… justified or where requirered …” It should be “…justified or where required…” Accepted BR.003 5.5.3.5 1st § ed “Not withstanding” Shouldn’t it be “Notwithstanding”? Accepted BR.004 5.6.5 1st § ed “Evaluate also the risk …” We suggest “Also it is necessary to evaluate

the risk …” Accepted

BR.005 p. 21 2nd § ed In the end of the paragraph item “5.11” is marked Reset the marker Accepted BR.006 p. 28 3rd § te API quotation for flexible pipes

There are ISO stds coming for that, shouldn´t it be quoted in lieu of API?

Accepted. References will instead be made to ISO 13628-10 for bonded and –11 for unbonded flexible pipe.

BR.007 p. 30 Item 2 legend

ed Description of drawing item 2 is jamming with item 7 Correct description aligment Accepted

BR.008 5.12.7.3 2nd § ed “… and structures should if not …” It is missing a comma “… and structures should, if not …”

Accepted

BR.009 5.15.2 Last § te “White colours shall be avoided for large structural elements”

In subsea equipment white colour is just used to paint large structural elements (see colour definition in the Annex B)

Not Accepted Ref suffix “A” in annex B; White for diver intervention and yellow for ROV intervention.

BR.010 p. 44 2nd § te/ed “... temperature is above 50 x 10+12 or 30 oC (86 oF) …”

Wrong measurement definition 50 x 10-12 refer to ppb (parts pr billion) oxygen equivalents. Text has been changed.

BR.011 7.2.1.2 1st § ed “… be structured in a manner similar …” We suggest “… be structured in a similar manner …”

Accepted

BR.012 Several various ed Drawing legends continued in the next page We suggest rearrangement of several legends (e.g. p.70/p.71)

Accepted, will be looked into for better arrangement

BR.013 A.6.1 3rd § ed “… of the flowline(s)and/or umbilical …” Missing spacing “… of the flowline(s) and/or umbilical …”

Accepted


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BR.014 A.6.5 1st § ed “… for gathering of produecd fluids …” Correct the word to “produced” Accepted

BR.015 p. 89 § just before item

A.8

te After sentence “… data back to the host facility”. We suggest adding the sentence “Also, it is necessary to provide an appropriate ground wiring for avoiding electrical loop effects.”

Accepted in principle. It is necessary with an instrument grounding philosophy. The meeting 22 and 23 April concluded to forward this comment to the project leader for the control system standard.

BR.016 A.8.7 1st § ed “… of the hydrcarbon pressure …” Correct the word ”hydrocarbon” Accepted BR.017 p. 100 2nd § above

from item A.8.9

ed “Definition of the frequency with which the abovementioned function …”

It is missing a space in between “above mentioned”

Accepted

BR.018 A.9.3.2.3 1st § ed “… and positioning typically require wire …” It should be “… and positioning typically requires wire …”

Accepted

BR.019 A.10.1 3rd § ed “… as they need to able to …” We suggest “… as they need to be able to …”

Accepted

BR.020 p. 122 § just before item

A.11

ed “… and that all of the various …” We suggest “… and that all the various …” Accepted

BR.021 A.11.2.2 1st § ed “… riser is run inside …” We suggest “… riser is running inside …” Not Accepted Terminology issue.

BR.022 p. 128 Figure A.20 legend

ed Abbreviation “SiV” All words should be in uppercase letters Accepted

BR.023 A.11.3.2 2nd § ed “… [e.g. a 476 mm (18 3/4 in)] tree connector, large bore valves and a large bore riser) in order …”

Wrong position use of parenthesis and brackets. It should be “… [e.g. a 476 mm (18 3/4 in) tree connector, large bore valves and a large bore riser] in order …”

Accepted

BR.024 p. 130 5th § ed “… of an emergency disconnect;” We suggest “… of an emergency disconnection;”

Not Accepted “emergency disconnect” is established terminology.

BR.025 p. 130 8th § ed “… (as described in A11.2.2) for control of the… as We suggest “… (as described in A11.2.2) for Accepted


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well as all of the valves …” controlling the … as well as all the valves …” BR.026 p. 130 12th § ed “… [e.g. a 476 mm (18 3/4 in)] tree connector, large

bore valves and a large bore riser) in order …” Wrong position use of parenthesis and brackets. It should be “… [e.g. a 476 mm (18 3/4 in) tree connector, large bore valves and a large bore BR riser] in order …”

Accepted

BR.027 p. 131 5th § ed “… (as described in A11.2.2) for control of the… as well as all of the valves …”

We suggest “… (as described in A11.2.2) for controlling the … as well as all the valves …”

Accepted

BR.028 A. 11.6 12th § ed “… or by being pused by the …” “… or by being pushed by the …” Accepted BR.029 p. 136 3rd § ed “… use CRA linepipe so as …” “… use CRA pipeline so as …” Accepted, but write “line-pipe” BR.030 p. 137 1st § ed “Thought should also be given …” We suggest “Thought it should also be given

…” Accepted in principle, Rewrite sentence; The need for a subsurface……of the well should also be considered. Such feature may involve…..

BR.031 Table B.1 5th and 7th columns in the 1st row

te There is an “A” near around “Yellow” and “White” Is this a quotation? Where is the referred text?

Missing suffix at end of table. A) to read; Usually yellow for ROV intervention and white for diver intervention

BR.032 Table B.1 p. 140 ed No color reference is provided We suggest to repeat the first row with color reference of the Table

Accepted

BR.033 Table B.1 p.141 ed Idem Idem (Idem is latin for same as above) BR.034 p. 145 11th § ed “- verification of ability of workover ” We suggest “- verification of the ability to

workover …” Accepted in principle Change to; ..verification of the ability to the workover..

BR.035 D.1.5 p. 150 ed “… and people will to a large extent gain experience with …”

We suggest to modify to “… and people will gain experience, to a large extent, with …” or to put the missing commas

Accepted

BR.036 p. 174 11th § ed “… on each of the abovementioned flow …” It is missing a space “… on each of the above mentioned flow …”

Accepted

BR.037 I.10.3 1st § ed “… the choke on thesubsea tree … system by prolongedproduction.”

It is missing a space “… the choke on the subsea tree … system by prolonged

Accepted


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production.” BR.038 J.2 J.1.2, J.2.3,

J.2.4 and J.2.5

ed As several examples are quoted in a “such as” list, the use of “etc.” in the end of the list is inappropriate

We suggest deleting “etc.” in the end of the list

Accepted

IT.001 1 te Add ‘and abandonment’ to first paragraph. …the design phase to decommissioning and

abandonment Accepted

IT.002 2 ed The title of ISO 13628-5 is not correct. Modify as: P&ngi - Design and operation of subsea production systems - Part 5: Subsea umbilicals.

Accepted

IT.003 2 ed The title of ISO 13628-9 is not correct. Modify as: P&ngi - Design and operation of subsea production systems - Part 9: Remotely Operated Tool (ROT) intervention systems.

Accepted

IT.004 2 ed The number and the title of AWS D1.1 are not correct.

Modify as: AWS D1.1/D1.1M, Structural welding code - Steel.

Accepted

IT.005 3 3.1 ed Terms are not in alphabetic order. Correct Accepted IT.006 3 3.2 ed Abbreviations QRA and SARA are not defined. Define. Accepted for QRA

Not accept for SARA.

“SARA characterisation” is decribed in Annex I.

IT.007 3 3.2 ed Abbreviations should be the same as used in the other ISO series documents

Review existing ISO documents and make sure the same abbreviations are being used.

Accepted in principle

IT.008 3 3.2 ed Add some more abbreviations Add:

CXT – Conventional xmas tree

HXT - Horizontal xmas tree

= vertical XT = VXT

Accerpted


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DXT – Drill through xmas tree

SCM – Subsea Controls Module

FWHP – Flowing wellhead pressure

SWHP – Static wellhead pressure

XOV – Cross over valve

THOJ – Tubing hanger orientation joint

TMS – Tether management system (for ROVs)

Not acc. = Drill through HXT

Accepted, but subsea control module

Accepted

Accept;; but Shut-in wellhead pressure

Accepted

Accepted

Accepted.

IT.009 3 3.2 ed LRP and LWRP are the same thing Use LRP as per 13628-7 Accepted IT.010 3 3.2 ed Change DHPT, XT and XTRT DHPT should be DHPTT – Downhole

pressure temperature transmitter.

XT should be Xmas Tree

XTRT should be TRT (Tree running tool)

Accepted

Not accepted (terminology)

Accepted IT.011 4 4.2 te Add some more bullet points to the existing bullet

points Add:

- subsea protection structures

- protection mats

- pig launcher/receiver

- pressure and temperature monitoring devices

- hydraulic power distribution equipment

- tie-in spools and jumper flowlines

- flowline and jumper protection


Delete hydraulic


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devices (mattresses, rock dumping, trenching, dog houses, etc)

- SSIV’s at base of risers IT.012 4 4.3/Fig 1 te change key Change:

- Completion riser and control line to completion/workover riser and WO controls umbilical

- Esport to export flowline

- Riser base to Riser base/SSIV

Accepted

IT.013 5 5.2.1.2 te Add some more words Add to first bullet:

- pH, mass density, specific heat capacity, swell, surge

Add to third bullet:

- subsea obstacles, volcanoes, mudslides, scouring, topology, subsurface hydrates, thermal conductivity, friction factors, lithology

Accepted

IT.014 5 5.2.2 ed Spelling mistake in last para Change proviode to provide Accepted IT.015 5 5.2.3 te Add some more words to existing bullet points Change 10th bullet to read ‘completion

tubing size and drift schedule with relevant plug nipple information Add bullet:

- completion design

Accepted

IT.016 5 5.2.5 te Add/change some words to existing bullet points Add the following bullets: - topsides process equipment

pressure/capacity ratings - existing export flowline capacities

Accepted


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Change 7th bullet to read: - flowline and umbilical routing and

approach corridors IT.017 5 5.3.1 te Add some more words to existing bullet points Add the following bullets:

- reservoir characteristics - produced and injected fluids

characteristics - commissioning requirements

Accepted

IT.018 5 5.7.2 te Add some more words to existing bullet points Add the following bullet points: - type of xmas tree (CXT, HXT or

DXT) - location of TH (in wellhead, in

tubing spool or in XT)


Abbreviations agreed in meeting 22 and 23 April to be used.

IT.019 5 5.7.3 ed ISO 13628-3 and ISO 13628-4 are not in the list of normative references.

Correct Not accepted.

References are listed in the Bibliography according to ISO directives

IT.020 5 5.7.3 te Change wording to external loads bullet point to take account of the difference between CXT and HXT

Change wording to read: ….. case is a workover situation in which a BOP and workover riser (for HXT) or an LRP and a workover riser (for CXT) may be used.

Accepted in principle.

Abbreviations agreed in meeting 22 and 23 April to be used.

IT.021 5 5.7.3 te Add additional bullet to subsea intervention bullets Add bullet: - type of ROV deployment system

(TMS cage deployment system or surface deployed)

Accepted

IT.022 5 5.7.3 te Change wording top last para under tree control bullet

Change the mass and location of the PCS module should be …. To the following: The mass and location of the SCM should be ……

Accepted

IT.023 5 5.11.3.1 ed ASME B31.8 is not in the list of normative references.

Correct Accepted. B31.8 is referred to in a normative manner and will be included


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in the list of normative references. IT.024 5 5.11.3.1 te Add some more words to the bullet points under the

header Basic considerations Add to first bullet:

- piggy-back, pipe-in-pipe or integrated into the controls umbilical

Split second bullet into two after first para ie: Selection of a method ….. now becomes a new bullet change 2nd bullet to read: …..application depends on the number of lines ……and not depends on a number of lines. Add sub bullets to the 3rd bullet as follows:

- flow assurance issues - pigging requirements - produced fluids temperature - insulation requirements - weight coating requirements

Change 5th main bullet to read: …..valleys can induce slug fluid flow and liquid hold-up in the ……

Accepted

IT.025 5 5.11.3.1 te Add some more words to the bullet points under the header Rigid and flexible pipe design

Add the following bullets under the first main bullet:

- laying method (S-lay, J-lay or reeling)

- laying vessel type and limitations. - Fluid characteristics - Material grade - Corrosion allowance (for CS pipe) - CRA cladding requirements - Manufacturability - Water depth - Arrival fluid temperature



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Reword the first part of the 6th main bullet to read: …… occurs most often when the pipe is being installed under …… Add some words to the last part of the 6th main bullet to read: …….decreases sufficiently to arrest the buckle. Buckle arrestors are used to mitigate against extensive buckle propagation. Buckle arrester are usually thicker pipewall pup pieces or sleeves welded into the linepipe.

IT.026 5 5.11.3.1 te Add additional bullet to Pipelines may be coated for

Add the following bullet: - Internally coated to facilitate

commissioning operations (ie to reduce the amount of free water left over from de-watering operations and hence shorter times to dry the line if so required.


Additional bullet should read as follows;

*Internal coating may be performed for the following reasons:

- reduces debris from manufacturing/construction activities

- enhances corrosion protection

- provides faster commissioning (drying) times

- improves pig performance

- improves hydraulic performance

preceding bullet should be modified as follows to take out the reference to


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external coating :

- provide external corrosion protection. External include coal……

5 5.11.3.1 te Delete para under rigid pipe design codes because

it is in the wrong place Delete the last para ‘specific design requirements for control system umbilicals and their components are given in ISO 13628-5

Accepted

Will be replaced by specific section covering umbilicals. Ref US023.

IT.028 5 5.11.3.2 ed ISO 10423, ISO 13628-3 and ISO 13628-4 are not in the list of normative references.

Correct Accepted for 10423 only as it is referred to in a normative manner and will be included in the list of normative references. Disagree for the two others.

IT.029 5 5.11.3.2 te Change wording of first para under bolted flange bullet because SS refers to flange type whereas the para refers to gaskets

Reword para to read: …… and flange connections. API SBX or SRX or proprietary gaskets offer ………

Accepted in principle. The para should read as follows: API SBX, SRX or proprietary gaskets offer …… during make-up subsea. The designer should note that SBX gaskets allow face-to-face contact of the two flange faces whereas SRX gaskets do not. Consideration should therefore be given to bending moment capacities required of the flange connection prior to selecting gasket type.

IT.030 5 5.11.3.2 te Add new para under bolted flange bullet Add para:

Bolted flange types require divers to make up the flange.


But: …flange types may require…. IT.031 5 5.11.3.2 te Add new para after last para under bolted flange

bullet Add para: Clamp type hub connectors are typically used in diverless systems. Make-up masy be performed by either ROV or ROT tooling.

Not accepted.

Discussed and concluded in 22 april meeting.


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No value added. IT.032 5 5.12 te Additional wording required Please add some words to differentiate

between an integrated template, non integrated (ie pre-drilling template + protective structure/manifold and commingling manifold configuration.


Referecne to relavent section in Annex A will be included.

IT.033 5 5.12.1 te Add some additional wording Add the following words to the first para: …… is often built as one integrated structure, however if early drilling is required then a pre-drilling template is usually installed to permit drilling activities to commence followed by subsequent installation of a protective structure with integrated manifold onto the pre-drilling template).


Will be incorporated in A.6.2…

IT.034 5 5.12.2 te Modify the first para Modify the first para to read: The integrated template or pre-drilling template should provide a guide for drilling, landing and latching of the conductor and conductor housing, and provide sufficient space for running and landing of the BOP stack. The conductor may be permanently latched to the template or released subsequent to conductor cementing. The template slots shall be capable of supporting the weight of the conductor and conductor housing until cementing operations are complete.


“shall be” will be modified to “are normally”

IT.035 5 12.7.1 te Add new bullet points to existing bullets Add the following bullets: - The subsea structure shall be sized

congruent with the intervention method (ie ROV, ROT or divers)

- Dropped object protection may be

Accepted


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provided over each wellbay and critical equipment with hinged or removable panels

- Structure corners shall penetrate into the seabed to mitigate snagging hazard.

IT.036 5 5.12.7.3 te Modify 11th bullet and add additional bullet Modify bullet as follows: ……which require torque or stroking to be ……..to use a dedicated torque or stroking tool and interface. Add new bullet:

- Sufficient marking shall be provided to permit easy identification of equipment by divers and/ROV.


Align with NO-053.


Delete sufficient

IT.037 5 5.12.8 te Add additional bullet to existing bullets Add new bullet point: - Piled template systems shall be

provided with a means to mechanically fix the template to the piles (ie grouting or swaging)

Accepted.

IT.038 5 5.12.9.1 ed ISO 13628-3 is not in the list of normative references.

Correct . References are listed in the Bibliography according to ISO directives

IT.039 5 5.12.9.1 te Modify existing bullets Modify 2nd bullet as follows:

- The manifold may provide for flow testing of individual wells

Modify 3rd bullet as follows: ……..should provide appropriate pigging loops (for round trip pigging) or pig launcher/receiver interface flange or hub

Accepted,, but suggest “provide facilities for flow…”

Accepted


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and appropriate valving and line-bore dimensions Modify 9th bullet as follows: …. Manifold connections and other trees. This is usually provided with a flowbase which permits XT recovery without breaking manifold piping.

Accepted

IT.040 5 5.12.9.3 ed ISO 13628-3 is not in the list of normative references.

Correct Disagree. References are listed in the Bibliography according to ISO directives

IT.041 5 5.12.9.3 te Add additional para Add additional para as follows:

Manifold piping shall be designed to naturally drain any liquid accumulation towards the flowline connection end. Offtake piping should drain any liquids into the main header if at all possible.

Accepted

IT.042 5 5.13.4 te Add word Add word into para as follows: ….pressure of the wells. Alternatively, a HIPPS isolation valve may be ……….

Accepted in principal

Wells. Alternatively a HIPPS system can be used. A HIPPS system protect flowlines, or other equipment downstream, not rated for the full shutin wellhead pressure from being overpressured. The HIPPS solution is further described in Annex A.8.8.

IT.043 6 6.2.1.7 te Modify para Modify para as follows:

…… should be evaluated especially if water injection is foreseen.

Accepted

IT.044 6 6.2.2.3 te Add additional words to para Add the following new para: The design should consider solid CRAsor

Accepted


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clad pipe if the corrosion allowance is greater than 3 – 4 mm.

IT.045 6 6.4.1 (Table)

ed ASTM A193, ASTM A194 and ASTM A320 are not in the list of normative references.

Correct Not accepted These are not refered to in a normative manner. -

IT.046 6 6.4.2 ed ISO 898-1, ISO 898-2, ASTM A193 and ASTM

A320 are not in the list of normative references. Correct Not accepted

As above IT.047 6 6.5.6 te Add additional words to 2nd bullet point Add additional words as follows:

….. for the relevant operating conditions. Titanium shall be avoided if there is a possibility for contacting with methanol.

Accepted in principle,

Following text will be included;

Titanium shall not be used for hydrofluoric acid or pure methanol (>95%) or exposure to mercury or mercury based chemicals. Titanium shall not be used for submerged applications involving exposure to sea water with cathodic protection unless suitable performance in this service is documented for the relevant operating temperature range.”

IT.048 8 8.4.1 te Modify 2nd para Modify 2nd para as follows: These rig related requirements should be ……

Accepted

IT.049 8 8.4.2 te Add to and modify existing bullet points Add new bullet point as follows: - For CXT in drilling mode enable

closure of BOP rams and disconnect of LMRP in the event of an emergency drift-off situation.

Modify first bullet as follows: - For CXT in workover mode enable

closure at LRP and disconnection of EDP (if applicable) in the event of


Bullet 1. –In drilling mode enable closure of BOP rams and disconnect of LMRPin the event of loss of station keeping.

Bullet 2. and 3 replaced by;

– In workover mode enabling closure


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an emergency drift-off situation. Modify 2nd bullet as follows:

- For HXT in workover mode enable closure of the SST valves, disconnect of the EDC, enable closure of the BOP rams ………

to isolate the well and safely disconnect in the event of loss of station keeping.

IT.050 8 8.5.5.1 te Add additional bullet point to existing bullets Add bullet point as follows: - Drying of flowline (if required for

flow assurance reasons)

Accepted IT.051 8 8.5.5.4 te Para suggests nitrogen leak testing of flowline

isolation valves as a commissioning activity for gas lines. It is more usual to do gas testing in the factory and then just do hydrostatic pressure test and hydostatic valve leak testing in the field.

Delete reference to nitrogen testing Acceptedt inprinciple

Add to last sentence;

…for topside equipment.

IT.052 8 8.6.2 ed Modify para Reword para as follows: ……… wells from the well intervention vessel via an ESD radio link with the host facility.

Not Accepted

ESD radio link is not defined.

IT.053 8 8.5.6.8 ed ISO 13628-4 is not in the list of normative

references. Correct Disagree. Reference is listed in the

Bibliography according to ISO directives

IT.054 8 8.8.4 ed API RP 57 has been withdrawn so should not really be referenced.

Delete reference Accepted

IT.055 A A.2.2.5 te Add additional words to 3rd para Add following words to 3rd para: ……of one line as a well test line, however this may create flow assurance issues.

Accept

IT.056 A A.3.1 ed ISO 13628-4 is not in the list of normative

references. To correct Disagree. Reference is listed in the

Bibliography according to ISO directives

IT.057 A A.3.2 te Modify NOTE para and modify bullet points Reword NOTE para as follows: Accepted


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…..and connection of the flowlines to the tree. This allows XT recovery without disturbing the flowline connections. The guidebase can be either permanent or retrievable. The flowlines may be connected directly to the tree but this requires the flowline connection to the tree to be broken prior to recovering the tree Add following additional words to 3rd bullet point: ……. Together with the permanent guidebase, or as the case may be production guidebase. Add following additional words to 5th bullet point: ……. Well is put on production. Casing strings may feature burst disks to cover for any possible casing collapse due to excessive pressure build-up in the B-annulus.

Accepted in principal.

The permanent guidebase may be a production guide base. Improve text.

Accepted.

IT.058 A A.4 te We’ve added some words and some drawings (see

below) that you may consider of use for incorporation into this section

Conventional designs Conventional xmas trees (CXT) typically have one or two production bores and one annulus bore running vertically through their entire length (see Fig.) These bores permit the passage of plugs and tools down through the XT and into the TH or completion string. The vertical bores pass through a series of gate valves (production valves) used to isolate the vertical bores at differing levels. Two or more horizontal bores intersect the vertical bores to permit the passage of fluids into or out of the well and each has an isolation gate valve (wing

Accepted in principel

Recommend to incorporate.

Some terminology will be changed.


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valves) to allow flow shut-off. Cross-over valves are usually incorporated to allow communication between the production and annulus bores. The CXT stack-up in its simplest form comprises a top mandrel, solid master and wing valve blocks, re-entry funnel or guide-posts, protective structure, wellhead connector wellhead and TH. With this type of stack-up it is imperative that the XT and wellhead are from the same supplier otherwise the TH to wellhead interface cannot be guaranteed. If this is not possible it would be advisable to install a tubing spool to guarantee the TH interface. A tubing spool would also be installed if the existing wellhead was damaged. See fig A tubing spool simplifies TH installation by providing a known shoulder onto which the TH is landed and a helix to allow passive orientation of the TH. These features eliminate the requirement for: • casing elevation check run prior to

running the TH (saves rig time) • TH orientation check run prior to XT

running (saves rig time) • BOP modifications (saves money) • a THOJ (saves money and rig time) The tubing spool also permits annulus access below the TH for concentric type XT designs (see following section) A dual or triple bore completion/workover riser (see fig. ) is used to provide vertical

Is imperative too strong an expression.


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conduits from the TH up to the surface while running and setting the TH, and similarly provides vertical conduits from the xmas tree to the surface during XT running and wireline operations. The completion tubing and TH run through the drilling riser and BOP and into the wellhead with the BOP providing the necessary well barriers during the entire operation. There are usually no isolation valves or disconnect package in the landing string above the TH since the well is usually killed and TH installation operation usually of a short duration. Since the TH lands on the casing hanger inside the wellhead, it is necessary to check the elevation of the last casing hanger to ensure correct spaceout of the TH locking mechanism. This is done by running a lead impression block into the wellhead to obtain an imprint of the appropriate profiles. The TH landing ring is then adjusted accordingly. The HXT, DXT and CXT (with tubing spool) designs do not require a lead impression block run since in these designs the TH is landed onto a known landing shoulder in the XT (or spool) body. Since wellheads have no means to allow TH orientation other means such as a guide pin or orientation helix in the BOP are used. These devices pick-up on a helix or guide pin helix on the running string (the THROT). The BOP stack is in turn aligned with posts on the flowbase. The inevitable stack-up


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tolerances necessitate an orientation check to be performed on the TH once landed. This is done with a orientation check tool prior to pulling the BOP. An orientation check is not required for HXT, DXT and CXT (with tubing spool) designs since in these case TH orientation is via an internal helix within the XT (or spool). BOP orientation is also not required in these cases. It may be desirable to clean-up and flow test the well immediately after TH landing. This would be the case if kill fluids were likely to damage the reservoir if left for any significant time. In this instance a dual bore well control system, with two valves in each bore and an emergency disconnect package would be required (see Fig.). This equipment allows well closure and emergency disconnection of the completion/workover riser during clean-up and flowtesting. Fig shows a dual bore workover/completion riser, however, a mono bore riser could be used if a bore selector was incorporated above the dual bore completion tree. Annulus access would be via a flex hose during XT running and workover mode and via the BOP choke and kill lines during TH running and clean-up. The CXT can only be installed onto the wellhead after all drilling and casing activities are complete and the TH run and locked into the wellhead. This requires the TH to be temporarily plugged and the completion/workover riser and BOP


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retrieved to the surface prior to progressing with XT installation. Once the XT is installed onto the wellhead the temporary plugs are pulled and the well perforated and cleaned-up. The XT is now ready for production. During TH running operation the completion/workover riser is fitted with an Tubing Hanger Orientation Joint (THOJ) and the BOP fitted with a hydraulically retractable orientation pin (fitted to a spare choke or kill outlet) or orientation sleeve (keyed into the BOP connector) in order to correctly orientate the TH with respect to the wellhead. This in turn requires the BOP to also be orientated to the wellhead. For a guideline run system this is achieved via guideposts on the template or permanent guidebase (also called flowbase if manifold) structure. For a guidelineless system other means are used to orientate the BOP such as a re-entry funnel and orientation key arrangement. A BOP pin and THOJ would not be necessary if a tubing spool was installed since TH orientation would be achieved via an internal helix within the tubing spool. During XT installation and workover operations the completion/workover riser is fitted with a Lower Riser Package (LRP) complete with isolation, shear and cross-over valves, and an Emergency Disconnect Package (EDP) in order to allow safe closure of the well and emergency disconnection of


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the completion/WO riser. Options are available that allow the LRP to be omitted but require the tree swab valves to have wireline and coiled tubing shearing capability. In this case cross-over valves would be incorporated into the xmas tree above the Production and Annulus Master Valves (PMV & AMV) to allow circulation of the completion WO riser. The XT mandrel would also need to be arranged for high angle release of the EDP. This option is not recommended due to the high probability of damaging the swab valve during any shearing operation necessitating retrieval of the XT and replacement of the swab valve. The purchase cost of a multibore completion/WO riser is relatively small in shallow water depths but in deeper water its cost becomes a predominant factor. The cost may be justified if absorbed over a multiwell development but may be prohibitive in a one or two well development. In certain cases the actual feasibility of using a multibore risers in ultra-deepwater has been shown to be doubtful, requiring development of other systems. One such system utilises a monobore completion/workover riser together with a bore selector mechanism to gain access to the TH or XT production and annulus bores (see fig.). The cost of the completion/WO riser is reduced because standard tubing joints may be used instead of a dualbore completion/WO riser. TH and XT running


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times are also significantly reduced because screwed joints are used. In this system annulus circulation during XT installation is achieved via an independent flexible line run alongside the tubing joints or alternatively via a large bore hose in the WO umbilical. Concentric designs Concentric trees are configured with their valves very much like those of the CXT design but with the distinct difference being that the production bore is located concentrically within the tree and the annulus located off-centre (see Fig ) The inherent feature of the design only allows access through the centrally located production bore for TH plug setting and consequently other means are used for accessing the annulus such as a flexible pipe run along the side of the completion/workover riser. The advantage of the design is that the TH can be run on single standard tubing joints. This significantly reduces costs because no special completion/workover riser is required. Since screwed joints are used TH and XT running times are also significantly reduced. The major problem with the design is isolating the annulus. This can be achieved via a poppet stab valve or hydraulically operated sliding sleeve located in the TH, both of which provide access when either the THRT or XT is landed, and of course close when the THRT or XT is removed. These



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valves have proven to be a major failing point in the design since gas lift or circulation debris tends to degrade the elastomeric valve seals over time resulting in their inability to close tightly after THRT or XT removal. Certain configurations are available that eliminate altogether the problems associated with sliding sleeve and poppet annulus access valves by allowing annulus access below the TH. In this case the TH is situated in a tubing spool fitted with a gate valve for annulus isolation. (see Fig. ). The tubing spool also simplifies TH installation by providing an exact elevation into which the TH is landed and an orientation helix to allow passive orientation of the TH. These features eliminate the requirement for: • casing elevation check run prior to

running the TH (saves rig time) • TH orientation check run prior to XT

running (saves rig time) • BOP modifications (saves money) • a THOJ (saves money and rig time) Similarly with dual bore conventional designs, the completion/workover riser (single string) is required to be equipped with an LRP and EDP during xmas tree installation and wireline workover operations, however in this case access to the annulus is usually via a flexible hose run alongside the completion/workover riser (see


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Fig.) The concentric XT can only be installed onto the wellhead after the TH has been run. This requires the TH to be temporarily plugged and the completion/workover riser and BOP retrieved to the surface prior to progressing with XT installation. Once the XT is installed onto the wellhead the temporary plugs are pulled and the well perforated and cleaned-up. The sequence would be quite different if a tubing spool were to be installed. In this case the well would have to be temporarily abandoned after completion of drilling and casing activities and the BOP retrieved to surface. The tubing spool would then be installed onto the wellhead and the BOP re-run onto the top of the spool. At this point the cement plug would be drilled out and the TH run into the tubing spool. Temporary plugs would be run into the TH and the completion/workover riser and BOP retrieved to the surface. The XT would then be installed and the temporary plugs pulled, followed by perforation and clean-up and retrieval of the completion/workover riser. Installation of a tubing spool is quite common among certain operators because it allows freedom to choose what he considers to be the best wellhead and best XT system. Horizontal designs The main difference between the HXT and CXT is that the TH is installed into the XT rather than the wellhead. This allows


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replacement of the downhole completion without disturbing the xmas tree. (see Fig. ). Its use was initially aimed at ESP applications where frequent fullbore workovers were expected, but has now gained acceptance for use even in natural drive wells. They were also of interest due to the ability to run the TH on standard tubing joints rather than dualbore completion riser, but similar systems are now available for CXT systems. The fullbore aspect of the design obviously does not allow vertical bore valves in the XT so HXTs are configured with the valve bores located horizontally within the tree body. This allows the XT to be equipped with a production bore very much larger than that normally allowed in a CXT. Obviously the quality of seal between the TH and XT is of utmost importance since this essentially replaces the seats and gates of valves in CXT configurations. The fact that the TH can be retrieved without disturbing the XT makes this type of tree of considerable interest for installations using downhole equipment deemed to require frequent retrieval (ie., submersible pumps, intelligent completions, etc). The use of CXTs with ESP in a deepwater marginal development, for instance, may prove to be uneconomical purely on account of the frequent costly workover operations. For a HXT design this may not be the case due to the ‘relative simplicity’ of completion



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retrieval. HXT designs are also of interest for use on high production rate wells or water injection wells, particularly in template or clustered configurations. In these cases maybe only one HXT may be needed instead of perhaps two CXT types. The TH stack-up and orientation problems usually associated with conventional dual bore XT designs are eliminated in the HXT design by landing the TH in the XT and incorporating a TH orientation helix into the lower part of the XT. This eliminates the need to perform casing elevation and TH orientation check runs and by default eliminates the need for an orientation pin or sleeve in the BOP. The HXT can only be installed onto the wellhead after all drilling and casing activities are complete. This requires the well to be temporarily plugged and the BOP retrieved to the surface prior to progressing with the completion. Once the XT is installed onto the wellhead the BOP is run once again, but this time locked onto the top of the XT. Once the BOP is locked onto the XT, the temporary cement plugs are drilled out and the completion string and TH run and landed into the XT. This is followed by running of the Internal Tree Cap (ITC) and retrieval of the BOP. The XT is now ready for production. The fact that the BOP has to be retrieved between drilling and completion phases


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certainly has its disadvantages for a single well development but for a batch drilled multi well development BOP retrieval would be expected consequently putting CXT and HXT systems on equal par. More equipment than the CXT system has to be made available prior to completion operations so well commitment has to be quite high in order to justify the additional up-front CAPEX. During TH running and workover operations well barriers are provided by the BOP rams, kill and choke lines and fail-safe close valves located in the TH landing string package (see Fig. ). Fig shows a typical configuration with a flowbase as part of the stack-up. This is to allow tree retrieval without disturbing the flowline and umbilical. Clearly, with the reduced likelihood of having to retrieve the tree, there is less need for a flowbase and in certain circumstances, the flowbase may be integrated with the XT spool. This would save a running operation but at the expense of reducing system flexibility, ie: • restricts installation of the flowline and

umbilical until after the XT is installed • Disturbs the flowline and umbilicals if

the XT ever has to be recovered It should be stressed that failure of any HXT component would require a full workover and kill before the tree could be retrieved to the surface for repair. Statistical analysis has


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however shown the probability of downhole equipment failures, especially SCSSVs and submersible pumps, to be several orders of magnitude greater than the probability of xmas tree component failure consequently adding weight to the FMEA selection of a HXT configuration A variant on the HXT design, utilising a split TH, allows XT retrieval without first having to recover the completion string but unfortunately requires a complicated annulus isolation system. Such a system should be avoided in favour over a CXT configuration Drill-through designs A variant of the standard HXT design, nominated drill-through (DXT), has the same advantages as the HXT design but in addition also allowing drill through mode (see Fig). The DXT system is not yet available, but given the right circumstances may be developed in the next few years. The DXT system reduces the number of BOP deployment operations to one since all drilling and completion operations are performed through the xmas tree sequentially without having to retrieve the BOP. The wellhead system needs to be of a slim-bore design with a standard 16-3/4” (or 13-5/8”) internal profile and standard 18-3/4” external profile. This is to allow the use of a standard 18-3/4” wellhead profile on top of the XT for casing drifting through the tree



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but also allow a positive landing shoulder for landing of the TH inside the XT. As drilling operations go into ultra deep water, the ever increasing riser tensions required, mud volumes and casing storage will make the practicalities of using conventional 21” drilling risers and 18-3/4” BOPs so difficult that other systems will need to be developed. One of these uses a 16-3/4” (or 13-5/8”) BOP, 14” slimbore drilling risers and slimwell casing string designs. Further development in these areas is required and when available will make the DXT design even more favourable. Fig shows a typical configuration with a flowbase as part of the stack-up. This permits retrieval of the XT without disturbing the flowline and umbilical. Clearly, with the reduced likelihood of having to retrieve the tree, there is less need for a flowbase and in certain circumstances, the flowbase may be integrated with the XT spool. This would save a running operation but at the expense of reducing system flexibility, ie: • restricts flowline and umbilical

installation until after the XT is installed • Disturbs the flowline and umbilicals if

the XT has to ever be recovered One of the disadvantages of the DXT design is that, even though the tree is run with a bore protector in place, the sensitive sealing areas may still be subject to damage during


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drilling operations. This is because all drilling bits, casing hangers, wear bushings and seal assemblies have to all pass through the XT. Correct design of the bore protector, with positive lockdown and generous lead-ins and lead-outs will obviously mitigate this problem Additionally there is the possibility of clogging side penetrations with drilling mud and casing cement if the bore protector seals were to fail, especially those used for SCSSV control and DHPT monitoring. Again correct design of the bore protector will mitigate this problem. A further disadvantage is the limitation of bit size to 16” when drilling out for the 13-3/8” casing string but advances in expandable bits, under reamers and abrasive jet bits will again mitigate this problem. The fact that the XT has to be available during drilling operations makes the CAPEX costs of the DXT system the highest of the three XT types so well commitment has to be extremely high. The disadvantage this may bring, however, may be more than balanced out when consideration is given to the reduction in drilling and completion costs. During TH running and workover operations well barriers are provided by the BOP rams, kill and choke lines and fail-safe close valves located in the TH landing string package (see Fig. ).


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IT.059 A A.4.1 ed ISO 13628-4 is not in the list of normative

references. Correct Not accepted for reasons stated above.

IT.060 A A.4.1 te Add additional words and bullet points Modify first para as follows:

…… are transferred to an LRP for CXT systems and the BOP and landing string for HXT systems Add the following to the end of the second para: ….. to as conventional trees) and horizontal trees. Drill through type XT are being developed which permit the TH to be installed into the wellhead rather than the XT as in a HXT configuration. The TH bores extend up through the TH and into the XT where they intersect with horizontal bores that penetrate into the XT. The system allows the TH to be recovered without interfering with the XT and likewise permit the XT to be recovered without disturbing the TH, by stripping the XT over the TH. Add additional words to the end of the first bullet point as follows:


Terminology will be adjusted.



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…… in the vertical portion of the flowpath, unless a ball valve is incorporated into the internal tree cap Add additional words to the end of the second bullet point as follows: ……removal of the tubing hanger and completion string. Add third bullet point as follows:

- Vertical XT systems are run on dual bore completion riser (or monobore riser with bore selector located above LRP and a means to circulate the annulus; usually via a flex hose from surface. TH of HXT are run on casing tubular joints thereby saving the cost of a dualbore completion riser, however a complex landing string is required to run the TH. The landing string is equipped with isolation ball valves and a disconnect package made specially to suit the ram and annular BOP elevations of a particular BOP. Subsequent rig change would require certain components of the landing string to be changed out to suit the new BOP ram and annular BOP elevations.

Accepted

Accepted

Accepted

IT.061 A A.4.2.1 ed Figure A3 doesn’t really illustrate what the system is about. See drawings below.

Consider incorporation of drawings Yes

IT.062 A Figure A4 te Add additional note to key 2 Add the following after key 2: (not required if dual bore or ported TH is used)

Accepted


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IT.063 A A.4.2.4 te Modify first and second para and add third new para Reword 1st para as follows: ……. Riser, using THRT. On wells requiring immediate perforation and cleanup on landing of the TH (to limit reservoir damage from completion fluid) a dual bore completion tree and emergency disconnect connector should be run above the TH to offer emergency shut-in and disconnect. Change LWRP in 2nd para to LRP. Change wireline coiled tubing in 2nd para to wireline/coiled tubing Add 3rd new para as follows: Control of THRT, landing string and XT functions during installation and workover is usually performed via a WO umbilical and surface rig located HPU. Various ESD functions are built in to permit well isolation and disconnect of the running string.


Replace completion with test. Replace should with may. Replace TH with THRT.

Accepted

Delete rig

IT.064 A A.4.3.1 ed Figure A9 is incorrect Change accordingly Accepted IT.065 A A.4.3.3 te Add additional words to end of 1st para and in

middle of 3rd para Add additional words to end of first para as follows: ….. of the well to the tree. A completion stab seal extending from the bottom of the XT penetrates and seals into the upper casing hanger. The completion stab seal features a helix to passively orientate the TH during landing. Add additional words to middle of 3rd para as follows:. …… a second pressure retaining barrier. The ITC may be blind or feature a plug nipple or ball valve to permit easier wireline/CT intervention. A debris cap is then installed

Accepted

Accepted

But spell out ITC as “internal tree-cap”


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IT.066 A A.4.3.4 te Modify 2nd para Modify 2nd para as follows: ….other in line valves and emergency disconnect package are run above the TH

Accepted

IT.067 A A.5.1 ed ISO 13628-4 is not in the list of normative references.

Correct Not accepted

As earlier IT.068 A A.5.2 ed Reference to fig A3 is incorrect Change Accepted IT.069 A A.5.3 ed Reference to fig A3 is incorrect Change Accepted IT.070 A A.6.1 te Modify last para Modify last para to read:

…..to the combined unit, ie the template, protective structure and the manifold.

Accepted

IT.071 A A.6.4 ed Reference to fig A7 is incorrect Change Accepted IT.072 A A.7.2 te Add additional bullet point Add additional bullet point as follows:

- Improves flow assurance Accepted

IT.073 A A.7.5 te Add additional wording to last para Add following word to last para: Injected water may cause reservoir souring

Accepted in principle. Suggest adding the following para at the end of A.7.5: Reservoir souring of originally sweet reservoirs may occur if subjected to seawater injection (water flooding). The most plausible cause of reservoir souring is the growth of Sulphate-Reducing Bacteria (SRB) in the zone where seawater mixes with formation water. Fatty acids and sulphate need to be present in the mixing zone in order for SRB activity to exist. Without these, SRB activity cannot exist. Treatment is not possible so the only remediation is to design for sour service.

IT.074 A A.8.1 te Modify 4th para because HPUs are not located Modify 4th para as follows: Accepted in principle, but add


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subsea This is accomplished by an HPU located on the surface. The 14th para refers to MUX systems. Please also discuss the other types of systems as well.

normally after HPU

Not accepted. This was concluded at an early stage of the revision process.

IT.075 A Table A.1 te Change length in last column Change ‘length’ to ‘command distance’ Accepted IT.076 A A.9.3.3 ed First bullet should be Multibore and not ultibore Change Accepted IT.077 A A.11.2.2 te Reword 3rd para and rework bullet points Reword 3rd para to read ……. Riser system

must be used to provide The bullet points need to be reworded to differentiate between the completion/WO riser of a CXT and a HXT.

Accepted

Accepted

IT.078 A A.11.5 ed ISO 13628-3 and ISO 13628-4 are not in the list of normative references.

Correct Not accepted for reason stated above

IT.079 A Fig A.18 te Show valves in LRP and show EDP Change drg accept IT.080 A Fig A.19 te Show remote control panels, show arrows and add

note saying that HPU and control panel are usually integrated into one container

Change Accepted in principle

Change fig to ; 1)Remote panel, 2) HPU and control panel. Delete mineral oil and water based.

IT.081 A Fig A.20 ed Abbreviations should be the same as ISO 13628-4 Change Agreed IT.082 G G.2.2 ed ISO 10423 and ISO 14313 are not in the list of

normative references. Correct Accepted for 10423., Not for 14313,

which is listed in bibliography. IT.083 G G.2.2 ed ISO 10423 is not in the list of normative references. Correct Accepted IT.084 J J.3.5 ed ISO 13628-4 is not in the list of normative

references. Correct Not accepted for reason stated above

IT.085 K K.1.3.3.2 ed ISO 13628-4 is not in the list of normative references.

Correct Not accepted for reason stated above


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IT.086 K K.3 ed ISO 10423 is not in the list of normative references. Correct Accepted

But where relevant in annex K give reference to 13628 part 7.

IT.087 K K.4.1 ed ISO 10423 is not in the list of normative references. Correct Accepted IT.088 K K.4.2 ed ISO 10423 is not in the list of normative references. Correct Accepted


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A. Galeotto Deputy Manager for Int. Std.


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NO.001 ge Due to the extent and character of the

hereinafter comments, a re-issued DIS revision should be considered.

Not accepted

This was concluded in the joint ISO/API meeting 18 feb04.

NO.002 ge The content of 13628-1 has become too voluminous. Some sections (e.g. Annex A) are more regarded as education literature than a standard, and in addition some sections do not reflect state of the art of today’s technology. Such sections should therefore be removed from this document. Document status as today is considered not to fulfil it’s purpose due to the voluminous and the vague wording throughout the document.

Reduce the document size to maximum 20-30 pages by e.g.: remove sections (see comments), transform remaining text into more specific wording etc.

Noted… for future considereations

Joint ISO/API meeting 18 feb04 concluded to keep doc as is but consider annex a as a separate tech. document for future revisions.

NO.003 ge Words like should, would, may and maybe are too frequently used in this document.

Reconsider words like should, would, may and maybe with shall. Sentences that can’t be changed should be removed from the document. Pure recommendations can be removed to Annex A.

Partly accepted. Where an subpart of ISO 13628 (part 2-11) includes a requirement (“shall” statement) and the same/identical requirement is covered by part 1, this shall also be a “shall” statement.

NO.004 General te Where an subpart of ISO 13628 (part 2-11) includes a requirement (“shall” statement) and the same requirement is covered by part 1, this shall also be a “shall” statement.


suggest additional text to the Scope Note: Where requirements as stated in this part of ISO 13628 are in conflict with, or are inconsistent with, requirements as stated in the relevant complementary parts of ISO 13628 (that is Parts 2 through 11) then the specific requirements in the complementary parts take precedence. Also move last paragraph in Introduction to 1.0 Scope.


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NO.005 Foreword/2 Page ix and page 1

ed Divergency between “Foreword” and “2 Normative references”

Foreword; Part 7: Completion/workover riser systems

2 Normative references; Part 7: Workover/completion riser systems

Correct title of Part 7 shall be “……. Completion / workover riser.”

Accepted

But add “systems”

NO.006 Introduction ed Text in parenthesis in second paragraph is incomplete

Text in parenthesis to be replaced with: (system design, structures, manifolds, colour and marking)

Accepted.

Will add Lifting devices as well.

NO.007 General te Inconsistency between part 1 and the other parts of ISO 13628 for some provisions. Where a subpart of ISO 13628 (part 2-11) includes a requirement (“shall” statement) and the same requirement is covered by part 1, it creates confusion and lack of clarity when this is shown as a “should” statement.

Change a few “should” statements to “shall” statements.


Ref NO 004

NO.008 2 te Reference to 13628-7 may be strengthened Make reference to ISO 13628-7 (not FDIS)

as this part is about to be issued.

Acceptedd

NO.009 3.1.2 te Deepwater , generally depths ranging from 350 m Generally depths ranging from 350 m (1150

ft)……

Align with US 010 &011

NO.010 3.2 ed Some of the abbreviations are obvious and may be deleted

Delete API, DNV, ISO, NACE etc. Not Accepted

Regarded as useful information

NO.011 3.2 te If an abbreviation is used only once in the document, it should not be listed as abbreviation, but be explained in the text.

Remove abbreviations in 3.2 used once only in the text and explain in text.

Accepted

NO.012 3.2 ed New abbreviations to be implemented HSP – hydraulic subsea pump

PLEM - pipeline end module (ref. A.6.1, page


When an abbreviation is used only once the phrase shall be spelled out in the


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78)

RAM - ? (ref. A.8.8)

SCM – subsea control module

SSCSV - ?

corresponding text. And not listed in clause 3.

Ref. A.8.8. Spell out RAM analysis fully: Reliability and maintainability analysis

Accepted

The abbreviation SCSSV ,Surface-Controlled Subsurface Safety Valve will b e used.

NO.013 3.2 ed correction PSD – production shut down

Accepted

NO.014 3.2 ed Correction - Do we need both TRT and XTRT? Should use: TRT – Tree running tool

Only TRT will be used

NO.015 3.2 ed Abbreviations to be explained QRA, SARA

Not Accepted,,but in the text (page 181) Reconsider….

QRA = Quantitative Risk Analysis

SARA = characterisation of crude into persentages of Saturates,aromatics,resins and asphaltenes

NO.016 3.2 ed Correction (FMEA) FMECA


Both will be listed in 3.2

NO.017 4.2 te Suggest clarification & rewording of eleventh “pinne” “one or more flowlines to convey produced

and/or injected fluids between subsea wells and process plants, injection manifold or between subsea installations


Suggest ,….between subsea installations and the Host facility.

NO.018 4.3 Figure 1 and item

ed correction Export

Accepted


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11

NO.019 4.3 ed Typing error 11 Export

Accepted

NO.020 5.1 Page 7 ed correction Provision for possible…. for reservoir

uncertainty

Accepted

NO.021 5.3.1 Page 12 te - moored or dynamically positioned installation vessels

- moored or dynamically positioned installation and intervention vessels


Include for drilling vessel.

NO.022 5.5.1 ge It is considered as not required having the System engineering addressed both in section 5.5.1 and in Annex H.

Include a abstract from Annex H into section 5.5.1 and remove Annex h

Not Accepted.

Valuable considerations will then be lost or clause 5.5.1 will be too volumius.

Ref alsol US-094

NO.023 5.5.2.17 Page 14 ed correction The paragraph should start with a new

section

Accepted

NO.024 5.5.2.6 te e.g clamp connectors do not have such features Type of connectors to be specified Accepted in principle.

Arrangement replaced with inherent feature

NO.025 5.5.2.14 te This section is not relevant for the majority of the “interface connections”.

To be removed Not Accepted

Regarded as important design basis info. Ref also US- 050

Interface replaced by subsea operated…

NO.026 5.5.3 Page 15 te correction This section must include the definition /

clarification of “tested and testable barriers”


Ref US – 060 and 096

Testing of barriers is discussed in J.1.3 including reerence to ISO 10417

And add to last sentence in 5.5.3.5 after……barrier philosophy (including


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test philosophy)

NO.027 5.5.3.1 te The described definition of “barrier” could lead to confusion since this is too general (e.g. what seal material is accepted)

A more precise definition of “barrier” should be included

Not accepted

Current strategy of presenting guidelines in order to help in defining a barrier philosophy for the spesific application ha s been preffered by ISO and API committies

Ref also Annex J and US 60,61,62 and US 96

NO.028 5.5.3.1 te As consequence of barriers A barrier should be defined as….

Not accepted ref. above

NO.029 5.5.3.2 te It is important that the barrier philosophy provide a clear and concise guidance on barrier requirements.

The barrier shall provide… Not accepted ref above

NO.030 5.5.3.3 te New subsea projects; It is important that the barrier philosophy is established prior to detail design

…a complete barrier philosophy shall be developed..

Not accepted ref above, NO-027

NO.031 5.5.3.5 4th list item te It is important that the barrier philosophy is clearly communicated to all relevant personnel.

- the barrier philosophy shall be clearly…… Not accepted ref above

NO.032 5.6 Page 16 ed correction (lack of reference) Implement reference to ISO 13628-4

Accepted ref US-063

NO.033 5.6.2 Page 16 te Description should be more specific wrt loads Include NORSOK drilling loads Noted – ref US-097

NO.034 5.6.2 te Riser loads should also include loading during workover and completion, i.e. Reference to ISO/DIS 13628-7 should be included

… Further guidance can be obtained from ……. And ISO/DIS 13628-7

Accepte in principle;

It is proposed that the 2nd paragraph in 5.6.2 is changed to the following: Riser loads are transferred to the wellhead system during drilling, well completion, workover and production. Depending on the type


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of subsea system, these loads may be either temporary (i.e. marine drilling riser and C/WO riser) or permanent (i.e. production risers or injection risers). These loads should be determined by performing riser analysis. Further guidance can be obtained from API RP 16Q[17], ISO 13628-7, API RP 2RD[xx] and DNV OS-F-201[34]. Fatigue analysis may also be required where variable loading conditions exist (i.e. vessel motion and wave induced riser loads and riser loads due to vortex induced vibrations). It is proposed to included the following notes Note 1 Applicable loads and applicable load combinations, see Annex F, should be determined during system engineering, see Annex H. Note 2 Riser design codes account for normal, extreme and accidental loading conditions. The design codes used for subsea trees and well head systems are normally based on rated capacity for normal operating conditions and are normally based on the working


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stress format. Riser codes are either based on working stress design format (WSD) or load and resistance factored design format (LRFD). Operational criteria for the determination riser loads, identification of accidental riser loads, identification of any code break inconsistencies and their implications should be established during system engineering. It is proposed to change the 1st paragraph in 5.7.3 –external loads as follows: There are two primary external load cases, other than environmental loads, that a subsea tree and its upper and lower connectors may be subjected too. The first is installation, which includes riser loads and sealine connection loads. The second external load case is during workover, which depending on the type of tree may be due to attachment of a C/WO riser system or marine drilling riser system. See 5.6.2 for applicable riser codes. It is proposed to change the 2nd paragraph in 5.7.3 – external loads as follows:


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Structural analysis should be performed to verify that in case the installation/workover vessel accidentally loses its position (rig drift-off) and the installation tool doesnot disconnect immediately, then the structural failure will occur in appoint above the specified barrier elemt for the operation, leaving the well in a safe state. Motion compensator lock-up should also be addressed and structural analysis should be performed to ensure the structural failure point will occur in a point above the specified barrier element. Note the specified barrier elements shall be leak tight after an accidental condition.

NO.035 5.6.2 4th § ed correction For template wells…

Accepted

NO.036 5.6.2 te It is important that the interface is carefully analysed, because it is a critical design feature of a template design.

..feature of at template design, and shall be carefully analysed.


Last sentence to read.

This interface is a typical critical design feature of a template design, and should be carefully analyzed.

NO.037 5.6.3 Page 16 te Should include installation ”….. will retain structural integrity during

installation, operation and workover.”

Accepted

But drilling will also be included

NO.038 5.7.3 Page 19 ed correction All components and connections… tree

Accepted


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components. Tree loops… (Dele space between “components” and “.” )

NO.039 5.7.3 Page 19 te Tree loops should be designed to the same pressure rating as the flowline, if located downstream the wing valve.

This is OK if possible HIPPS is installed on the tree. What about tree without HIPPS?

Not accepted.

The relation beteen application of codes and operating conditions has been misunderstood.

NO.040 5.7.3 Page 20 te correction ”…… running of other downhole tools and

equipment (pumps, separators, chokes, instrumentation ect.) in the tubing string…”


Suggestions in brackets will be deleted.

NO.041 5.7.3 Page 20 te - flowline connection Should implement umbilical connections and

satellite vs template connections.


Last sentence to start with Flowline and umbilical…..

NO.042 5.7.3 Page 20 te - tree valve configuration Include separate paragraph to consider

physical interface to subsea processing equipment such as pumps, metering equipment etc.

Noted

NO.043 5.8.2 te The completion/workover riser design is analogous to downhole tubing design if it is to be used only inside the marine drilling riser and BOP stack or jackup conductor pipe. This sub clause is in conflict with the requirements of ISO/DIS 13628-7 (ref. 6.3.4.5) and current industry practice. Due vessel motion the top of the riser is subjected to inertia loads. Due to marine ball and flex-joint rotations the C/WO riser is subjected to fatigue loads. Norsk Hydro has recently conducted a programme of work with regard to these issues.

5.8.1 Specific design requirements for completion and workover risers including workover control systems for operation in opens sea and inside marine drilling risers are given in ISO 13628-7. 5.8.2, 1st para. The completion/workover riser design is analogous to downhole tubing design if it is to be used only inside a jackup conductor pipe. 5.8.2, 2nd para. A workover or completion riser to be used in

Accepted


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open sea or inside a marine drilling riser, shall be designed by riser analysis (including fatigue analysis) as described in ISO 13628-7. Rest of paragraph to be deleted.

accept.

NO.044 5.8.2 te The subclause should be revised, due to conflict with ISO/DIS 13628-7

A workover or completion riser to be used in open sea or inside a marine drilling riser, shall be designed by riser analysis (including fatigue analysis) as described in ISO 13628-7

Accepted

NO.045 5.10.2 te The text can cause confusion and lead to misunderstanding and represent a potential cost driver

To be removed Not accepted

Ref US 017

NO.046 5.11.3.1 te It is proposed to remove subject describing rigid and flexible pipeline since this is covered in ISO 13628-2, 10 and 11

The following sections to be removed:

“Rigid and flexible pipe design” , “Pipeline may be coated for”, “Rigid pipe design codes” and “flexible pipe design codes”

Not accepted

This was discussed in meeting 22 April.

NO.047 5.11.3.2 te Section should be more specific wrt use of design code for the end connection

End connection design code to be included Olav sjekk med finn kirkemo.

Ref US 088

NO.048 5.11.3.2 Page 29 ed correction - pipeline connectors

Accepted

NO.049 5.12 Page 31 te It seems as requirements to the structures during fabrication and testing have been missing, i.e. geometry/deflection should be representative/checked during testing

Include appropriate text to cover this issue. Accepted in principle for,

This is covered in Clause 7

NO.050 5.12/

Annex 12

te Template and manifold system is proposed pulled out and included into a separate ISO part as exist for the X-tree system

5.12 and Annex G is proposed merged and pulled out into a separate ISO part.

Noted


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NO.051 5.12.7.1 Page 32 te Verification of alignment during onshore testing should be implemented under the first .section

the structure should……

The alignment should be verified during onshore testing.


This is sufficiently covered in 7.2.2.2

NO.052 5.12.7.3 te The landing speed is proposed moved to ISO 13628-9, since this part cover wire deployed running tools

The landing speed to be moved to ISO 13628-9 and a reference to be included into the text.

Noted

NO.053 5.12.7.3 Page 33 te Eleventh statement: “ – any special equipment or arrangements …….” Is considered unnecessary as the torque may be applied directly by the standard ROV manipulator.

Delete eleventh statement Accepted in principle

Rephrased tp ; equipment installed on the subsea structure which requires torque or stroking to be applied during operation may need a dedicated tool and interface.

Ref IT 036

NO.054 5.12.7.3 Page 34 te ”Tools, BOP, modules…. adequate running clearances to any part of the structure…” Should implement references to guidelines, best practice etc

Ref. NORSOK U-CR-001, rev.1, January 1995, sec. 5.5.2 Intervention:

Tools, BOP, modules and all retrievable equipment shall have an adequate running clearance to any part of the structure, adjacent module or equipment etc. to avoid any unintendent impact of clashes during installation and retrieval.

- minimum 0,2 m while running guide posts

- minimum 1,0 m for monohull and 0,5 m for semi submersible operations, respectively at 0,8 m above guide post top and upward

Noted


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when running on guide wires. Tighter clearances can be accepted for final alignment.

NO.055 5.12.8 6th para. te Should implement the possibility of using a suction system

- structures with skirt foundation should be designed for self-penetration, and/or possibly assisted by suction system

Noted

Ref also IT 037

NO.056 5.12.9.1 te This information is not required The following text to be removed: “-if wells are to be completed on template, the corresponding manifold should provide for connection to the tree;”


Ref also IT039

NO.057 5.12.9.1 Page 34 te The following essential requirements are missing and should be implemented

- Accommodate requirements set by the selected barrier philosophy

- Accommodate all requirements set by the installation and testing strategy

Accepted

Rephrase to …. set by the defined….

NO.058 5.12.9.3 te Manifold piping code B31.4 and B31.8 are considered more applicable than B31.3, since the manifold is more part of the hydrocarbon transportation system than part of process system

Replace piping code B31.3 with B31.4 and B31.8

Accepted in principle…

but B31.4 will also be referenced to.

Ref US 091

See also comment below.

NO.059 5.12.9.3 te Asme B31.3 is not written for subsea manifold piping design, i.e. the same “flexibility” as indicated in 5.11.3.1 Rigid pipe design, should be implemented. The application of the ASME B31.3 may result in extremely heavy subsea manifolds as well as rigid constructions. Taking into account that no standard is specifically written for the subsea manifold piping design some flexibility in the recommendation is required.

Applicable parts of ASME B31.3 [24], ASME B31.8 [26] and DNV OS F-101 [31] may be used for subsea manifold piping systems It should be emphasized that this document does not recommend one design theory or code over another; all have their practical applications. Rather, the intent is to show that there are several methods available to address manifold pipe design, given specific unique design requirements. However none of the above referenced standards are specifically written for subsea manifold piping


TBD

The intension with this proposal is appreciated, but mixing of codes is not considered to be a good practice. A better alternative is probably to base design on ASME B31.3 in order to minimize pressure related hoops stress, and apply additional requirements on thermally induced stress, displacements


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systems. Some design exercises may involve the use of multiple codes/theories to develop the best manifold piping design taking into account unique challenges related to optimisation of weight, pipe flexibility and tie in loads.

stresses and other applied stresses at interphases.

NO.060 5.13 te It is proposed to remove subject describing “Production risers” since this is covered in ISO 13628-2, 10 and 11

To be removed Not accepted

But ref also to ISO 21011

NO.061 6.4.2 te Based on experience during several years FMC Kongsberg Subsea propose to include stainless steel boltings of property class A4-80 according to ISO 3506-1 in additional to carbon and low alloy boltings already covered by Section 6.4.2.

Stainless steel type 316 should not exceed property class A4-80 for bolts according to ISO 3506-1 [ ] and property class for nuts according to ISO 3506-2 [ ] with a maximum allowable actual yield strength 950 MPa (alternatively allowable hardness HV 350).

This standard should maximize the use of ISO standards, and replace ASTM where appropriate.

Accepted in principle. New text ;

Bolting for structural applications should generally be carbon or low-alloy steels where the strength class should not exceed property class 8.8 for bolts according to ISO 898-1 [1] and property class 8 for nuts according to ISO 898-2 [2], with a maximum actual allowable hardness of 300 HB or 32 HRC. The hardness shall be positively verified by spot hardness testing for each delivery, batch and size of bolts used. Bolting in stainless steel should be according to ISO 3506 austenitic steel


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Grade A4.

NO.062 6.4.1. Table 1 te Table 1 – Bolting materials Temperature range for grade B8 M bolts is erroneous

Should be corrected

-196 to +60°C

-320 to + 140 °F

Accepted

Ref US100

NO.063 6.4.1. te No hardness restriction is set for pressure bolting in section 6.4.1. while section 6.4.2. set a maxium of 320 HB for structural bolting. This is not logic.

E.g. A 320 L7 in table 1 has no hardness restriction, while A 193 B7 has 35 HRC / 321 HRB

Propose hardness restriction also for pressure bolting, or eliminate hardness restriction for structural bolting.

The following has been included in the last draft of M-001 to improve this:

Bolts used for sub-sea application shall have a maximum hardness of 300 HB/HV10 or 32 HRC. The hardness shall be positively verified by spot hardness testing for each delivery, batch and size of bolts used. Ref US101

NO.064 6.4.2 te Maximum allowable hardness is set to HB 320. This is not harmonised with eg. ISO 13628-4 sec 5.1.3.4. state “Closure bolting manufactured from carbon or alloy steel shall not be used in submerged service at hardness levels exceeding Rockwell C 32 due to risk for hydrogen cracking.

HRC 32 equals HB 301 (HRB)

Hardness requirements should be harmonised between the different sections of ISO 13628 and for both pressure (closure) bolting and structural bolting.

Ref above

Ref US102

NO.065 6.4.3. te Alloy 625 should not be the single choice of material for bolting subsea at ambient temperature.

Ambient temperature at sea bottom is below 10°C and other highly noble nickel alloys or e.g. 25% Cr duplex should be allowed for.

Also other high strength cupro nickel alloys with high hydrogen cracking resistance should be allowed for.


New first sentences ;

Bots that is subject to syclic loading other than pressure should be impact tested. In high corrosion environ ments


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The statement demonstrate lack of knowledge about candidate materials

and /or where CRA materials are used corrosion resistant bolting is recommended.

Proposed wording at the end:

Other alloys can be used if properly documented.

Ref US103

NO.066 6.5 Page 46 ed correction …..to give cost-effective design. A

corrosion… Insert space between “.” and “A”

Accepted

NO.067 6.5.1. te Statement Cathodic protection should be used for all submerged, metallic materials, except for materials which are immune to seawater corrosion. Surface coating should in addition be used for components with complex geometry and where found to give ccst-effective design. A corrosion protection system based on a combination of surface coating and cathodic protection should be included in the design of subsea structures manifolds and modules exposed to ambient seawater

Proposal Cathodic protection should be used for all submerged, metallic materials, except for materials which are immune to seawater corrosion. Surface coating should in addition be used for components with complex geometry and where found to give ccst-effective design.

A corrosion protection system based on a combination of surface coating and cathodic protection should be included in the design of subsea structures manifolds and modules exposed to ambient seawater

Accepted

Ref US 104

NO.068 6.5.1. te Statement

“Duplicate paths should be considered for electrical continuity dependant on specified design life”

Proposal

To be moved to sec. 6.5.2. with the following addition

“Duplicate paths should be considered for

Accepted

Ref US105


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electrical continuity dependant on specified design life, and if risk for failure of continuity path is present”

NO.069 6.5.3. te Statement “The electrical continuity to the cathodic protection system should be verified by actual measurements for all components and parts not having a welded connection to an anode.”

Proposal

The electrical continuity to the cathodic protection system shall be verified by actual measurements for all components and parts not having a welded connection to designated anodes.

Accepted

Ref US106

NO.070 6.5.4. te Statement “Any components permanently exposed to ambient seawater and for which efficient cathodic protection cannot be ensured, should be fabricated from seawater-resistant materials.”

Proposal “Any submerged components permanently exposed to ambient seawater and for which efficient cathodic protection cannot be ensured, should be fabricated from seawater-resistant materials.”

Accepted

Ref US107

NO.071 6.6.1. te Statement “for submerged parts exposed to cathodic protection, the following should apply: For carbon and low-alloy steels, SMYS should not exceed 700 MPa (101 450 psi) r/25 MPa (105 072 psi) for bolts]. The actual yield strength should not exceed 950 MPa (137 680 psi).”

Proposal “for submerged parts exposed to cathodic protection, the following should apply: For carbon and low-alloy steels, SMYS should not exceed 700 MPa (101 450 psi) r/25 MPa (105 072 psi) for bolts]. The actual yield strength should not exceed 950 MPa (137 680 psi).

Alternatively it may be verified that the actual hardness in base materials does not exceed 295 320 HB ”

Ref 6.4.2.

The following has been included in the last draft of M-001 to improve this:

For submerged parts that may be exposed to cathodic protection, the following shall apply: For carbon and low alloy steels, SMYS shall not exceed 700 MPa (725 MPa for bolts). The actual yield strength shall not exceed 900 MPa. Alternatively, it may be verified that the actual hardness in base materials does not exceed 300 HB. For carbon steel welds a max. limit of 325 HV10 applies. For stainless steels and non-ferrous materials, resistance against hydrogen embrittlement shall be controlled by specifying that the actual hardness of the material is less than 300HV10 for base material and


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320HV10 for welds.

Ref US108

NO.072 6.6.1. te Statement “For stainless steels and non-ferrous materials, resistance against hydrogen embrittlement should be controlled by specifying that the actual hardness of the material should be in accordance with ISO 15156-1, unless otherwise documented.”

Proposal “For stainless steels and non-ferrous materials, resistance against hydrogen embrittlement should be controlled by specifying that the actual hardness of the material should be in accordance with ISO 15156-1 3 , unless otherwise documented.”

The new ISO standard does not provide maximum hardness for duplex stainless steel. The above proposal is recommended.

Ref US109

NO.073 6.6.1 te The detailed requirements to max SMYS for submerged parts exposed to cathodic protection should be removed taking into account the recent failures experienced in the industry.

Cathodic protection will cause formation of atomic hydrogen at the metal surface. Hydrogen atoms so formed can either combine to hydrogen molecules or become adsorbed in the metal matrix. In the latter case, hydrogen atoms may interact with the microstructure of components subject to high stresses causing initiation and growth of hydrogen-related cracks, “hydrogen induced stress cracking” (HISC). For high strength martensitic carbon, low-alloy and stainless steels, failures by CP induced HISC have been encountered. Ferritic-austenitic (’duplex’) stainless steels should also be regarded as potentially susceptible to HISC. The compatibility of CP with metallic materials and coatings should be qualified and documented.

Accepted.

Proposed addition from draft M-001:

Cracking due to hydrogen from cathodic protection can occur in ferittic/martensitic and duplex stainless steels with acceptable properties in case of very high local stresses. Attention should always be paid to local design to avoid large stress concentration factors for borderline materials.

NO.074 6.6.2 te It is proposed to remove subject describing “Flexible pipe” since this is covered in ISO 13628-2, 10 and 11

To be removed Not Accepted

Ref US110

But total section 6 to be revised.


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NO.075 7.1.2 Page 48 te …..to give cost-effective design. A corrosion… Insert space between “.” and “A”

Any failure occurring shall be repaired… Accepted.

NO.076 7.1.2 4th para. ed Cleanliness needs to be verified

Add the following text: ….and verified prior to delivery. After the sentence “Cleanliness requirements……..


NO.077 7.1.2 6th para. ed correction Move

Not understood.

NO.078 7.3.1 Page 50 te Integration testing of the subsea production system should be strengthened.

Integration testing of the subsea production system should include the following activities:

Accepted

Ref also US070 & 71

NO.079 8 te Since the content of Section is informative this should be moved out to a separate Annex

To be moved to an Annex Not accepted

Ref meeting 22 april. Content is regarded as important complementary information to previous sections.

NO.080 8.3.2.2 Page 52 ed correction - use installation tools based on a design

failure mode philosophy that prioritise well-control and retrievability

Accepted

NO.081 8.5.5.2 te The specified test period and test pressure needs to be according to existing standards.

Reference to applicable standard to be included


Add tekst to last sentence; Selected standards for design will determine test pressure to be used. Ref section 5.11.3

NO.082 Annex A A.2.2.8 Page 69

ed Correction in 1st § Protective structures/devices for subsea

production systems appears…..

Accepted

NO.083 Annex A Figure A.3 ed correction Implement arrows in the figure?

Arrows are implemented, but not visible. Make visible by increasing line size.


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NO.084 Annex A A.4.3.4 Page 76

ed correction The THis installed….

Space between TH and is.

Accepted

NO.085 Annex A A.6.5 ed correction …manifold system for gathering of produced

fluids…

Accepted

Ref BR 014

NO.086 Annex A Table A.1 ed It is difficult to read the table Should implement columns and rows in the

table

Accepted

NO.087 Annex A A.9.1.1 ed correction (space between each and line) The end connections for each line……

Accepted

NO.088 Annex B Table B.1 ed It is difficult to read the table Should implement columns and rows in the

table

Accepted

NO.089 Annex E E.3.4 te Lifting certificates Lifting certificates should follow the

equipment, and must be available where/when the equipment will be lifted

Accepted

But”during the guarantie period” will be deleted.

In secondsentence “as applicable “ will be added.

In third bullet; delete swab

Delete ex-cerftificates and add work-over equipment certificates

NO.090 Annex F ed Datasheets lacks editing Datasheets need to be edited and put into

single pages for easy use

Accepted

NO.091 Annex I I.10.3 ed correction (space between prolonged and production)

…system by prolonged production. Accepted

NO.092 Annex J J.1 te Barrier philosophy considerations

It has to be amplified that the barrier philosophy


Further tutorial will be considered in


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considerations applies to testable barriers.

A frequency for testing of temporary barriers should be recommended, and if possible the validity of a tested barrier.

annex J

Annex J is for guidance only.

NO.093 Annex J J.1.1 te - in cases where one barrier in a well is lost/fails to test, the corresponding well should be shut-in;

”in case where one barrier in a well is lost/fails to test, the corresponding well should be shut-in;


Add. New sentence. Then possibility of continuing production with reduced or alternative barrier functionality may be evaluated.

NO.094 Annex J J.1.2 te Suggest to change the text in section J.1.2 / Annex J

The considerations should take into account factors such as typical duration of the activity, risk assessment and potential consequences, intervention method and lifting gear, station keeping system of the intervention vessel, whether or not divers are involved, etc. and finally recommend what type and how many barriers are required to comply with the overall barrier philosophy.

After establishing generic requirements, (based on a complete barrier philosophy as specified in section 5.5.3.3), due considerations should be given to the specific characteristics of particular situations. For example :

- In situations where the reservoir cannot produce to the environment without some form of artificial lift, the requirement to have multiple / double barriers vs. one barrier in the well, should be evaluated.

- For intervention activities downstream of the wing valve on the subsea tree (e.g. during tie-in of a new well to a manifold, installation of a pig launcher or replacement of a subsea choke), the requirement to have two vs. one barriere (e.g. a single tested valve) in the flowpath between the hydrocarbon in the manifold / pipeline and the environment, should be evaluated.

Accepted

NO.095 Annex J J.1.3 te correction The barrier philosophy also must address

Accepted in princiøle


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issues involved in the testing of the various barriers ….

Ref NO-092

NO.096 Annex J ge Questions is not relevant in a standard Remove questions and reconsider content Accepted in principle. DW Action

NO.097 Annex K K.1.6.3 ed correction FEA should be FMECA (ref. comment 3.2)

Correct FEA to FMEA. See NO.016

NO.098 Bibliography [12] ed Improve reference to ISO 19901-2 as the DIS is publicly available.

Delete “/DIS” for better references when this standards is issued.

Accepted. Change throughout standard

NO.099 Bibliography [13] and [14]

ed Incorrect reference as both ISO 19901-4 and –5 are now issued as ISO standards.

Delete “/FDIS” for both references Accepted. Change throughout standard

US.001 Techn

ical Recommend that in sections 5.11.3.1 and 5.11.3.2 for the FDIS version, should include the recently passed 13628-10 on recommended practice for design of flexible pipe, in addition to the other codes cited.

Accepted

US.002 Other Will send Mike an email with collected comments. N/A

US.003 5.7.3 Other There should be no physical contact between modules being run and the surronding structure even when all tolerances are pulled in same direction.

"worst tolerance condition"--? Accepted in principle

But relevant for 5.12.7.3

Covered elsewere

US.004 5.7.3 Other For guidelineless operations, positive restrictions, such as guide funnels or bumper beams, should be provided to avoid impact between adjacent equipment.

"positive restrictions"-----? Does it mean Safety barriers?


Ref 5.12.7.3

Consider physical instead of positive,,

Ref also US036


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US.005 5.7.3 Editorial

There should be no physical contact between modules being run and the surronding structure even when all tolerances are pulled in same direction.

There should be no physical contact between modules being run and the surrounding structure, even at worst-case tolerance stack-up.

See US.003

US.006 2 Editorial

All of the 13628 series documents should be listed as normative references in clause 2.

Will be according to ISO rules.

US.007 5.2.3 Well completion data

Other wellhead details, i.e. size, pressure rating; wellhead details, i.e. size, pressure rating; and well interface data if existing wellhead

Accepted

US.008 5.2.3 Well completion data

Editorial

- wellhead details, i.e. size, pressure rating; - wellhead details, i.e. size, pressure rating; and well interface data if existing wellhead

Accepted

US.009 3.1 Technical

The terms and definitions in clause 3.1 are unclear and require further work e.g. deep water could be defined as water depths beyond diver intervention whilst ultra deep water could be defined as water depths requiring the use of guidelineless equipment.


But the current terms in the document is preferred per meeting 22 april. Any suggestions will be welcomed.

US.010 3.1.2 Other (2000ft) and 1830m (2000ft) to 1830m Accepted

US.011 3.1.3 Other Depths exceeding …. Inconsistent with depths presented as note in 3.1.2

to be consistent

US.012 3.2 Other ESD emergency shutdownQRASARA ESD emergency shutdown disconnectNo definitionNo definition

ESD = emergency shut down

QRA = quantitative risk analysis

SARA; desribed in tekst ref. IT 006.

US.013 4.1 General Other Subsea production systems can range in complexity from a single satellite well with a flowline linked to a fixed platform or an onshore installation, to several wells on a template producing via subsea processing facilities to a fixed or floating facility, or directly to an onshore installation.

Subsea production systems can range in complexity from a single satellite well with a flowline linked to a fixed platform or an onshore installation, to several wells on a template or clustrered around a manifold producing via subsea processing/commingling facilities to a fixed or floating facility, or directly to an onshore

Accepted


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installation.

US.014 4.1 General Editorial

Subsea production systems can range in complexity from a single satellite well with a flowline linked to a fixed platform or an onshore installation, to several wells on a template producing via subsea processing facilities to a fixed or floating facility, or directly to an onshore installation.

Subsea production systems can range in complexity from a single satellite well with a flowline linked to a fixed platform or an onshore installation, to several wells on a template or clustered around a manifold producing via subsea processing/commingling facilities to a fixed or floating facility, or directly to an onshore installation.

As above

US.015 4.3 Fig 1 Other 11 Esport 11 Export Accepted

US.016 5, 8, Annex K Editorial

5.5.2.17 to be indented.

8.5.5.5 should be attached to "Function Test of Subsea Manifold Valves", which should be in bold letters, as it is a sub-section heading.

K.1.3.2 First sentence, the "shall" to be changed to "should", as agreed at the June 2003 Conference Meeting.

Accepted

Accepted

Accepted

US.017 5.10.2 Other Control system availability may be maximized by selecting high-reliability assemblies and components; selecting components that have a high resistance to wear and corrosion; providing component redundancy; providing back-up or secondary systems; providing diver/ROV/ROT intervention capability; providing system bypasses; providing spare units (modules) for replacement; establishing control fluid properties and cleanliness standards.

Is it not part of redundancy?To perform what operations?Specific requirements should be included in the BOD.


Minor change in 3`d para. proposed

- providing component and system redundancy.

Delete bullet starting with

- providing back-up or sec…..

US.018 5.10.3 Other designing equipment for accessibility and easy maintenance; designing control system assemblies to be retrieved independently from subsea completion hardware.

Does it mean "designing equipment and system assemblies for easy accessibility for retrieval and maintenance"?

Accepted


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US.019 5.11 Editorial

The ISO designations for API 17J and 17K should be used throughout clause 5.11

Accepted

US.020 5.11.1 Other Interfaces and borderlines between specification regimes need to be adequately considered during system design.

"borderlines" -----does it mean "spec breaks"?

Accepted


Interfaces and borderlines between specification regimes need to be adequately considered during system design.

Interfaces and spec breaks need to be adequately considered during system design.

Accepted

US.022 5.11.3.1 Other ISO 13826-3 Does it mean "ISO 13628-3"? Accepted

US.023 5.11.3.1 Other There is virtually no mention in the main text of umbilicals (other than one sentence in 5.11.3.1) and no mention at all of chemical injection systems. Both of these standard subsea systems deserve at least a small stand alone section in the main body of the document.

Accepted

DW to provide input

US.024 5.11.3.1 Editorial

ISO 13826-3 ISO 13628-3 Accepted

US.025 5.11.3.2 Other After placing a pipeline on the seabed, it may be necessary to reposition the ends, modify them (by adding extensions), or both, so that a connection can be made without further gross adjustment. The choice of a pipeline alignment and connection method and its subsequent design is influenced by several considerations, including the following

What is meant here by adding extensions? Accepted in principle,,

Replace extension with,,,

e.g. tie-in spools

US.026 5.11.3.2 Other ¾ end connection method: it is essential to the integrity of the end connection that the alignment method positions the end of the pipe within the appropriate axial, lateral and angular make-up tolerances of the pipeline connector. Rotational alignment should also be accommodated for bundled pipelines to guarantee proper port orientation. It is also important to understand when

Tolerances----- is it the same as "connector capture area"?Bundle pipelines---- does it imply "multibore hubs/pipe ends" ?

Q1, no it is not.

Q2, yes it is also applicable to bundles.


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the end connections take place in the installation process. Some end connection techniques favor "first-end" connection, either as the start of the pipe lay operation, or the first end to be connected immediately after the pipe is laid. "Second-end" connections favour platform or riser connections, but are accommodated by almost all subsea end connection techniques;

US.027 5.11.3.2 Other ¾ For deep water, all seals experiencing hydrostatic pressure should have bi-directional capability. Pipeline connectors should be designed to provide some verification means to assure the gasket has been formed and the connector has been fully actuated or clamped together after it has been installed subsea.

¾ For deep water, all seals experiencing hydrostatic pressure should have bi-directional capability to withstand the internal design pressure and the external hydrostatic pressure to prevent any seawater ingress. Pipeline connectors should be designed to provide some verification means to assure the gasket has been formed and the connector has been fully actuated or clamped together after it has been installed subsea.


Remove “for deep water”


end connection method: it is essential to the integrity of the end connection that the alignment method positions the end of the pipe within the appropriate axial, lateral and angular make-up tolerances of the pipeline connector. Rotational alignment should also be accommodated for bundled pipelines to guarantee proper port orientation. It is also important to understand when the end connections take place in the installation process. Some end connection techniques favor "first-end" connection, either as the start of the pipe lay operation, or the first end to be connected immediately after the pipe is laid. "Second-end" connections favour platform or riser connections, but are accommodated by almost all subsea end connection techniques;

…tolerances (connector capture area)……bundled pipelines (multi-bore hubs/pipe ends)…

Same as US026

US.029 5.11.3.2 Editori ¾ …For deep water, all seals experiencing For deep water, all seals experiencing Same as US027


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al hydrostatic pressure should have bi-directional capability. Pipeline connectors should be designed to provide some verification means to assure the gasket has been formed and the connector has been fully actuated or clamped together after it has been installed subsea.

hydrostatic pressure should have bi-directional capability to withstand the internal design pressure and the external hydrostatic pressure to prevent any seawater ingress. Pipeline connectors should be designed to provide some verification means to assure the gasket has been formed and the connector has been fully actuated or clamped together after it has been installed subsea.

US.030 5.12.1 Other The template should provide foundation to sufficiently transfer design loads into the seabed.

The template should provide foundation to sufficiently transfer design loads into the seabed depending on the design approach if the structure is intended to be fully load-bearing structure.

Not accepted

It is regarded that enough information has been given. In addition the statement ask for sufficient loads. More info will not add value.


The template should provide foundation to sufficiently transfer design loads into the seabed.

The template should provide foundation to sufficiently transfer design loads into the seabed, depending on the design approach and the extent to which the structure is intended to be load-bearing.

Same as US030

US.032 5.12.7.2 Other The well-supporting structure/production guidebase design should allow for individual thermal expansion of the conductor/wellhead housings.

The well-supporting structure/production guidebase design should allow for individual thermal expansion of the conductor/wellhead housings. Thermal expansion needs to be quantified in the Basis of Design

Not accepted

Decided that the doc can not give reference to all kinds of information that is relevant for “a design basi” doc.

US.033 5.12.7.2 Other The structure should transfer all design loads from interfacing systems and equipment to the foundation system.

Does it include wellhead loads? Yes

US.034 5.12.7.2 Other Design requirements Cathodic protection? Not accepted or relevant here.


The well-supporting structure/production guidebase design should allow for individual thermal expansion of the conductor/wellhead housings.

The well-supporting structure/production guidebase design should allow for individual thermal expansion of the conductor/wellhead housings. Thermal expansion needs to be

Same as US032


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quantified in the Basis of Design.


For guidelineless operations, positive restrictions, such as guide funnels or bumper beams, should be provided to avoid impact between adjacent equipment.

For guidelineless operations, positive restrictions/safety barriers, such as guide funnels or bumper beams, should be provided to avoid impact between adjacent equipment.


But physical instead of positive

Ref US004

US.037 5.12.8 Other Typical levelling methods include one- and two-way There is no mention of suction piles or mono conductor pile foundation design. Should these be added?

Not accepted

Ref IT037 , No055


Typical leveling methods include one- and two-way…

There is no mention of suction piles or mono conductor pile foundation design. Should these be added?

Same as US037

US.039 5.12.9.4 Other fault analysis capability to identify failed components.

Is it part of FMEA? Yes

US.040 5.14 Other The second sentence in clause 5.14 incorrectly describes the contents of 13628-9.

Accepted

Text will be changed to include ROV and ROT

US.041 5.15 Other The clause relating to colors and marking i.e. 5.15 may be better placed in a normative Annex that could be more easily referenced in other 13628 series documents as the Annex numbering is less likely to change over time than the clause numbers in 13628-1.

Accepted

General statement to be placed in 5 with ref. to new annex. B.

US.042 5.2.3 Other Interfaces ….. Would be worth mentioning subsea test tree. Accepted

See ISO 13628-7

US.043 5.2.6 Safety and Hazards

Other fishing intensity fishing intensity and protection design criteria Accepted ,,,, se below

US.044 5.2.6 Safety and Hazards

Editorial

- fishing intensity - fishing intensity and protection design criteria


Replace intencity with activity


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US.045 5.3.1 System Definition

Other anchor patterns and/or footprint; anchor patterns and/or footprint; and rig heading

Accepted

US.046 5.3.1 System Definition

Editorial

- anchor patterns and/or footprint; - anchor patterns and/or footprint; and rig heading

Accepted

US.047 5.3.3.2. and 6.1.2.4.1.

Technical

Our opinion is that the relevant ISO standard should be basically identical to API Spec. 17K, but errors or inconsistencies found in API 17K should be corrected.

We propose to omit the following part of 5.3.3.2: "of the end fitting seal ring ". This seal ring is not relevant for bonded flexible pipe, only to unbonded ones standardised in API Spec. 17J.

Referring to 6.1.2.4.1. the requirement for chemical compatibility of the embedding compound in Tab. 9 may be removed, since the embedding compound is not in contact with the internal fluid.

Dr Tibor Nagy

Phoenix Rubber Ltd

Comment is not relevant for part 1

US.048 5.5.2.11 Other In order to improve overall availability the possibility to replace components while other parts of the system are in operation should be evaluated during the subsea system design phase.

Such a requirement to component level for deepwater applications may not be practical.

Not accepted

e.g. non intrusive sensors.

US.049 5.5.2.12 Other The subsea system should include, where justified or where requirered by local regulations, protection of sensitive equipment from potential damage caused by fishing gear and dropped objects. The protection should be evaluated on a probability/consequence basis. For protection related to intervention, overall design requirements

Should the cost be a factor in the consideration?Needs explaining.

Dropped object protection should be provided where considered necessary not within "safety/restricted zone"Definition of "trawl resistant structures"?

Not accepted. This is outside the scope of this document. Noted


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should be evaluated based on operational philosophy and procedures.Subsea production equipment installed inside the applicable safety/restricted zone of a production unit should be protected against dropped objects. Dropped objects protection should be evaluated on the basis of probability of drop/hit during operations.In areas with fishing activity two options exist:¾ establishment of a restricted zone, i.e. no bottom gear fishing is allowed in the area. This will require trawl resistant structures and/or continous surveillance;¾ if the establishment of a restricted zone is not allowed, overtrawlable structures may be required.

.

US.050 5.5.2.14 Other The subsea production system should have position indicators for all interface connections

The extent of this requirement should be clearly stated in the BOD.


Leave as is


The subsea production system should have position indicators for all interface connections

The subsea production system should have position indicators for all interface connections, as specified in the BOD.


Leave as is

US.052 5.5.2.16 Other allow well intervention with rig offset within specified limits.

Needs to be clearly defined in the BOD. Read 5.5.2.17


Leave as is but

expand datasheets in annex F and provide better references to annex F.


-allow well intervention with rig offset within specified limits.

- allow well intervention with rig offset limits specified in the BOD.

Read 5.5.2.17

Ref above

US.054 5.5.2.4 Other A high system availability should be obtained through use of simple designs and reliable products

"high system availability" needs to be quantified in the Basis of Design (BOD) for

Ref below


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(suppliers' standard equipment preferably with a satisfactory field performance record).

the project to avoid any confusion over this requirement.


A high system availability should be obtained through use of simple designs and reliable products (suppliers' standard equipment preferably with a satisfactory field performance record).

A high system availability should be obtained through use of simple designs and reliable products (suppliers' standard equipment preferably with a satisfactory field performance record). The system availability requirement needs to be quantified in the Basis of Design (BOD) for the project.


US.056 5.5.2.5 Other Operational reliability should be documented for the subsea systems. For noncritical and temporary equipment, relaxed requirements may be accepted.

It needs further clarification as to the extent of the documentation and whether it is to be made available in the public domain.

Proposed change relative to subject question is not understood.

NA


Operational reliability should be documented for the subsea systems. For noncritical and temporary equipment, relaxed requirements may be accepted.

(Note: Add reference to API 17N when published.)

Same as above.

US.058 5.5.2.7 Other Means of obtaining/maintaining cleanliness in hydraulic systems to the standard required for intended operation should be included.

Means of obtaining/maintaining cleanliness, what is the intent here, does it apply to the hydraulic systems operational on the seabed during the operational phase? Is continuous monitoring of the cleanliness level a requirement?

Accepte in principle

New text after ….required for fabrication,testing,installation, commissioning, and operational periods should be included in the design


Means of obtaining/maintaining cleanliness in hydraulic systems to the standard required for intended operation should be included.

(Note: It is not clear if this is a manufacturing or operational requirement, or who is responsible for this.)

Ref above

US.060 5.5.3 Other Barriers There appears to be some repetition in this section. The actual requirement and how to achieve this needs to be clearly stated.

Not accepted

Ref NO-026 and NO 027

US.061 5.5.3.3 Other well intervention activities, involving re-entry into a well;

Should the "Retrieval of xmas tree" be included?


Add text to bullet 5; and or retrieval of tree.

US.062 5.5.3.5 Other development of both generic and case specific HAZOP and other studies are often carried Accepted in principle


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barrier philosophies requires the use of experienced personnel and typically involves the use of one or more risk assessment techniques such as HAZOP, FMEA, QRA, task analysis and/or scenario based risk assessment;

out to check the integrity of the system against an agreed/specified barrier philosophy which, may be based on double barrier isolation with a b/b facility as the minimum requirement. This may be adjusted to suit, depending on the criticality of the system.

Additional bullet point to be included in annex J.2.6 whether double barrier functionality and/or block and bleed facility is required.

US.063 5.6, 5.7, 5.9, 5.10 & 5.12

Other A clause similar to clause 5.8.1 is required in clauses 5.6, 5.7 and 5.9. Similarly references to ISO 13628-8 and –9 should be included in clauses 5.10 and 5.12 ala clause 5.11.3.1.

Accepted

US.064 5.6.6 Other Adequate flowby area around or through tool. For tools run through drilling riser adequate …

Not Accepted wording

US.065 5.7.3 Other Tree design considerations- external loads Cathodic protection not mentioned.Flow control not mentionedBOP stack drilling riser not mentioned (spool tree)


US.066 6.2.1.8 Other Corrosian Corrosion Accepted

US.067 7.2..2.3 Other Special tests may-be needed for handling and transport, dynamic loading, and backup systems

Please explain Noted.

Applicable also for part 4.

US.068 7.2.2.2 Other Functional checks should include make-up, normal emergency release, reversibility, repeatability and pressure integrity. The sequence and items to be tested would normally be individual components, running tools, subsystems, and the total system assembly.

Reversibility and repeatability tests for specific items involved should be specified in the Basis of Design.

Noted

This is normally too detailed for a design basis.


Functional checks should include make-up, normal emergency release, reversibility, repeatability and pressure integrity. The sequence and items to be tested would normally be individual components, running tools, subsystems, and the total system assembly.

Add: Reversibility and repeatability tests for specific items involved should be specified in the Basis of Design.

Same as US068


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US.070 7.3.1 Other The different tests performed during integration testing should be used to check reliability, and to demonstrate interface requirements

"----check reliability, and to demonstrate interface requirements-"please explain. Does it mean "to check interface compatibility"?


Ref below


The different tests performed during integration testing should be used to check reliability, and to demonstrate interface requirements…

The different tests performed during integration testing should be used to check reliability, and to demonstrate interface requirements are met,…

Accepted but,

…demonstrate that functional and interface requirements are met, …

US.072 A.8.8 Editorial

The title of clause A.8.8 is inconsistent with the HIPPS abbreviation in clause 3.2.

Accepted

HI pipeline or pressure Protection S??Correct term is Pressure

US.073 A.8.9 Other Clause A.8.9 on Chemical Injection Systems, should be a separate section i.e. not part of the section on Production Control Systems.

Accepted

US.074 Annex A Editorial

Annex A still contains several references to “sealines” e.g. in A.9.1.1, A.9.1.2, A.9.3.2.3 & A.10.1 and Figure A.3, which were supposed to have been replaced by the relevant term i.e. flowline or umbilical, etc. as applicable.

Accepted

US.075 Annex B Editorial

The table column headings in Annex B should be repeated at the top of each page.

Accepted

US.076 Annex D: Other How does one commission a subsea processing system?

Noted

US.077 Annex F Other The data sheets do not take into account the info required to design a subsea processing station. Despite that, I would like to add:

Bubble/Dew Point at Reservoir and wellhead temperatures.

Density, Viscosities at Reservoir, Bubble/Dew Point

Noted


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Fluid Molecular Weights.

US.078 Annex F Editorial

The tables contained in Annex F need to be reformatted so they each fit on a single page.

Accepted

US.079 Annex G: Other The subsea processing system will need active actuators.

Noted

US.080 Annex I Flow Assurance Considerations

Other Page 183: Three mechanisms are mentioned for breaking emulsions: heat, time and chemicals. Electrostatic forces should be mentioned as a fourth mechanism. Use of electrostatic forces for emulsion breaking is new technology, but test installations show very promising results.

Page 197: We think it would make sense to include a short section on erosion here as this is definitely a material-related flow assurance issue. As an example, if a needle valve is selected instead of a more conventional choke in order to minimize particle impact angle, this is a material-related flow assurance issue, not just a materials issue. Erosion is briefly mentioned earlier in the annex, in the sand section, where it is referred to the erosional velocity concept. We are sceptical about the use of erosional velocity (API RP 14E) for line sizing. Instead, we prefer DNV RP 0501, which is a physically more correct model as it accounts for fluid velocity, viscosity, particle impact angle, and particle properties (density, size, amount). Based on DNV RP 0501, we recently recommended a 6'' flowline for a field where API RP 14E required larger diameter.

Page 175: It says: "The cooldown time of the system


183. add after….. of the emulsion. A fourth mechanism is use of electrostatic forces. Use of electrostatic forces for emulsion breaking is new technology, but test installations show promising results.

Ref I.10 page 197.

Prepare new sub clause on erosion. David W


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is dependent on both the characteristics of the insulation as well as the thermal mass of the system and its surrounding environment. Hence whilst some materials/methods may be good insulators due to their low density and low thermal conductivity (e.g. nitrogen) they may also have low thermal mass and hence will allow the system to cool quickly once production is shutin, thus limiting the available response time." We think the opposite case also deserves to be mentioned, which is doghouses or heatbanks containing large amounts of trapped seawater. These have higher heat loss during steady state, but long cooldown time due to the large specific heat capacity of the trapped water.

Page 197: It is perhaps worth mentioning that high temperatures may be critical not only for flow lines, but also for components like valves and sensors, which contain electronics, sealings etc. with temperature limitations.

Doghouse facility will be included.

Last paragraph on page 197. after flexible flowline add; and all system elements. //// mrewrite to reflect all system elements including flowlines…

US.081 Annex I.2 Other The general chemical selection discussion ignores the mismatch between the OSPARCOM signees and the rest of the world. Some of the technologies discussed are banned by OSPARCOM. The section should refer to relevant environmental authorities.

OSPAR commission for the protection of the marine environment in the north-east Atlantic.

Further info on;

http://www.ospar.org/eng/html/whatsnew.htm

Ongoing…..

US.082 Annex I: Other Should include a section giving recommended practices for:



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1: Types and volumes of reservoir fluid samples to be taken

2: Choice of sampling methodologies

3: Rig/logging/drilling preparations for proper sampling operations

4: Test/sampling procedures

5: Analysis requirements for different equipment and usages.

5: Reporting

The composition should include the components that is required for material selection such as chlorides etc.

Will be aligned with Annex I I and Annex F.

US.083 Annex K Other Annex K requires some preamble/introduction at the beginning.

Accepted

US.084 Bibliography Other ISO 3183 is referred to in clause 5.11.3.1 and should therefore be included in the Bibliography. All of the ISO 13628 series documents should be listed in the Bibliography.


US.085 multiple sections as listed below

Technical

ISO/DIS 13628-1 Comments from Paul Hansen ChevronTexaco – 1/6/04

5.5.2.16

- equipped with facilities………..

5.5.2.17 make this a new paragraph

5.6.3

changes are incorporated in the comments above.


Accept

Accept


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Figure 2

Add 7 Guidewire Tension (if applicable)

5.11.3.2

- bolted flange:

Note – spelling…...(dynamic)

5.11.3.2

Figure 3

Graphic has angle as delta, but it should be alpha

5.15.3 Marking Requirements

Paragraph 8

The following areas shall be considered…

8.3.2.2

2nd bullet

spelling – retrievability

8.5.5.5 Function Test of Subsea Manifold Valves

Title should be in bold font

Change successive numbers in sequence: 8.5.5.6, 8.5.5.7, etc.

Accept

Accept

Accept

“Shall” is Accepted

move section 5.15 into annex B

Accept

Accept

Accept


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8.6.2

….It shall be possible to initiate….

8.6.7

Sentence needs to be reworded. Running offset is not understood. Use terminology such as rig moves in the field, around the manifold, to the Heavy Goods Handling Area, etc. instead of running offset.

9.2

The engineering and manufacturing documentation should include (as applicable)….

Appendix A

A.2.2.4 Clusters

Paragraph 4

The satellite cluster approach can alleviate……

A.9.3.3

- Multibore pipeline connectors

Appendix B

Marking Colours table comments

Continue column lines throughout table

“ shall” is accepted


Scentance modified to read;

Requirement for safe handling area shall be assessed.

Accept

Accept

Accept

Accept


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Repeat table headers at the top of successive pages

Appendix K

1.4 Design Documentation

…retention shall be for a minimum of 5 years after last unit …is manufactured – I’m surprised we’re not advocating retention for life of field for design documentation. I see we’ve compromised a bit with shall and minimum of 5 years. What is it we’d really like to see? I think you’d want the design package retained by the owner until the equipment is removed from the seafloor.


Change wording to;

…retention shall be agreed

US.086 Section 5.10.2 Other The text can cause confusion and lead to misunderstanding and represent a potential cost driver.

Proposed change by the MB: To be removed.

Not Accepted

Concluded in meeting 22 April 04

US.087 Section 5.11.3.1

Other It is proposed to remove subject describing rigid and flexible pipeline since this is covered in ISO 13628-2, 10 and 11.

Proposed change by the MB: The following sections to be removed.

Not Accepted

Concluded in meeting 22 April 04

US.088 Section 5.11.3.2

Other Section should be more specific wrt use of design code for the end connection.

Proposed change by the MB: End connection design code to be included.

Ref NO 047

US.089 Section 5.12.7.3

Other The landing speed is proposed moved to ISO 13628-9, since this part covers wire deployed running tools.

Proposed change by the MB: The landing speed to be moved to ISO 13628-9 and a reference to be included into the text.

Noted


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US.090 Section 5.12.9.1

Other The following text to be removed as it is not required: "-if wells are to be completed on template, the corresponding manifold should provide for connection to the tree."

Accepted

US.091 Section 5.12.9.3

Other Manifold piping code B31.4 and B31.8 are considered more applicable than B31.3, since the manifold is more part of the hydrocarbon transportation system than part of the process system.

Ref NO058

US.092 Section 5.13 Other It is proposed to remove subject describing "Production risers" since this is covered in ISO 13628-2, 10 and 11.


But in 5.13.1 clarify difference between static and dymamic riser.

US.093 Section 5.4 Other Dropped Item loads. Should we de-rate or design in allowances for subsea pressure vessels, for potential stress points or dents?¨

Noted

US.094 Section 5.5.1 Other The System engineering is addressed both in Section 5.5.1 and in Annex H.

Proposed change by the MB: Include an abstract from Annex H into Section 5.5.1 and remove Annex h.

Not accepted

Ref NO-022

US.095 Section 5.5.2.14

Other This section is not relevant for the majority of the "interface connections."

Not accepted

Concluded in april 22 meeting

US.096 Section 5.5.3.1 Other The described definition of "barrier" could lead to confusion since this is too general (e.g., what seal material is accepted).

Proposed change by the MB: A more precise definition of "barrier" should be included.

Ref NO-026 and N= - 027

US.097 Section 5.6.2 Other Description should be more specific wrt loads. Proposed change by the MB: Include NORSOK drilling loads.

Noted

US.098 Section 5.6.4 Other Wellhead/flowline pressure rating for well-kill, bullhead, fracing operations. The document might want to recommend a method for this.

The reduction in pressure standard for deepwater (by taking into account external pressure) is not readily accepted for subsea pressure vessels (separators, etc). Could

Ongoing…

Ref illustration in part 3, Annex B for guidance.


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this be resolved somewhere.

US.099 Section 6.2.1 Other This section discusses acid-gas related chemical corrosion on an "agreed-upon model" basis, while direction is given to correlations for corrosion for oxygen. In section 6.2.1.5, this is related to flow phenomena. This should probably refer to individual standards, rather than these specifics.

Noted

US.100 Section 6.4.1 Other Table 1 - Bolting materials

Temperature range for grade B8 M bolts is erroneous.

Proposed change by the MB: Should be corrected

-196 to +60 C

-320 to140 F

Accepted

Ref No062

US.101 Section 6.4.1 Other No hardness restriction is set for pressure bolting in section 6.4.1 while section 6.4.2 set a maximum of 320 HB for structural bolting.

E.g., A 320 L7 in table 1 has no hardness restriction, while A 193 B7 has 35 HRC / 321 HRB.

Proposed change by the MB: Propose hardness restriction also for pressure bolting, or eliminate hardness restriction for structural bolting.

Ref No063

US.102 Section 6.4.2 Other Maximum allowable hardness is set to HB 320. This is not harmonized with e.g. ISO 13528-4 section 5.1.3.4 state "closure bolting manufactured from carbon or alloy steel shall not be used in submerged service at hardness levels exceeding Rockwell C 32 due to risk for hydrogen cracking.

HRC 32 equals HB 301 (HRB)

Ref No064

US.103 Section 6.4.3 Other Allow 625 should not be the single choice of material for bolting subsea at ambient temperature.

Proposed change by the MB: Ambient temperature at sea bottom is below 10 C and other highly noble nickel alloys or e.g. 25% Cr duplex should be allowed for:

Ref No065

US.104 Section 6.5.1 Other Statement.

Cathodic protection should be used for all

Proposed change by the MB: Proposal

Cathodic protection should be used for all

Not understood


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submerged, metallic materials, except for materials which are immune to seawater corrosion. Surface coating should in addition be used for components with complex geometry and where found to give cost-effective design.

A corrosion protection system based on a combination of surface coating and cathodic protection can be included in the design of subsea structures manifolds and modules exposed to ambient seawater.

submerged, metallic materials, except for materials which are immune to seawater corrosion. Surface coating should in addition be used for components with complex geometry and where found to give cost-effective design.

A corrosion protection system based on a combination of surface coating and cathodic protection should be included in the design of subsea structures manifolds and modules exposed to ambient seawater.

Ref No067

US.105 Section 6.5.1 Other Statement

"Duplicate paths should be considered for electrical continuity dependant on specified design life"

Proposed change by the MB:

Proposal

To be moved to sec. 6.5.2 with the following addition:

"Duplicate paths should be considered for electrical continuity dependant on specified design life, and if risk for failure of continuity path is present.

Ref No068


"The electrical continuity to the cathodic protection system should be verified by actual measurements for all components and parts not


Proposal

The electrical continuity to the cathodic protection system shall be verified

Ref No069


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having a welded connection to an anode."

by actual measurements for all components and parts not having a welded connection to designated anodes.


"Any components permanently exposed to ambient seawater and for which efficient cathodic protection cannot be ensured, should be fabricated from seawater-resistant materials."


Proposal

"Any submerged components permanently exposed to ambient seawater and for which efficient cathodic protection cannot be ensured, should be fabricated from seawater-resistant materials."

Accepted

Ref No070


"for submerged parts exposed to cathodic protection, the following should apply: For carbon and low-alloy steels, SMYS should not exceed 700 Mpa (101 450 psi) r/25 Mpa (105 072 psi) for bolts]. The actual yield strength should not exceed 950 Mpa (137 680 psi)."


Proposed

"for submerged parts exposed to cathodic protection, the following should apply. For carbon and low-alloy steels, SMVS should not exceed 700 Mpa (101 450 psi) r/25 Mpa (105 072 psi) for bolts}. The actual yield strength should not exceed 950 Mpa (137 680 psi).

Alternatively it may be verified that the actual hardness in base materials does not exceed 295 320 HB."

Ref No071


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Ref 6.4.2.


"For stainless steels and non-ferrous materials, resistance against hydrogen embrittlement should be controlled by specifying that the actual hardness of the material should be in accordance with ISO 15156-1, unless otherwise documented."


Proposal

"For stainless steels and non-ferrous materials, resistance against hydrogen embrittlement should be controlled by specifying that the actual hardness of the material should be in accordance with ISO 15156-1 3, unless otherwise documented."

Ref No072

US.110 Section 6.6.2 Other It is proposed to remove subject describing "Flexible pipe" since this is covered is ISO 13628-2, 10 and 11.

Not accepted,, but clause 6 to be revised.

Ref No074

US.111 Section 7 Other In this section, the authors recommend the use of DnV RP A203. I am not sure if this commits everybody to such methodology as testing "to simulated operational environment." This alignment needs checking.

Not accepted

It is a “should”.

The DNV ref. is just an example.

US.112 Section 8.3.2.1 Other This section could reference environmental considerations. Seabed evaluations and preparations …


New bullet ; - installation method and operations should reflect environmental conditions, including seabed properties and preparation requirements .

US.113 Section 8.3.2.2 Other This commits the system to a standardized interface to well intervention systems. Are we at that stage for all products? Where is the boundary definition?

Not accepted

It is a recommendation.


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US.114 Section 8.5.5.2 Other The specified test period and test pressure needs to be according to existing standards.

Proposed change by the MB: Reference to applicable standard to be included.


Include sentence at the end;

Selected standards for design will determine test pressure to be used. Ref sectiojn 5.11.3.

US.115 Section 8: Other Since the content of this Section is informative this should be moved out to a separate Annex.

Not accepted

Ref Joint meeting 17feb04

US.116 Section A. I.10.3

Other Extreme temperatures: (if it goes to the detail level it has) should give recommendations as to the kind of thermodynamic evaluations which should be considered. It also makes no reference to high temperature.

Ongoing

US.117 Section A.2.2.6:

Other Table

Production allocation is needed to meet the legal required management of reservoir volumes. As a result the values for reservoir management and for production allocation should be the same. (For example the Canada has a 2% production allocation requirement designed to ensure proper reservoir management).

Para. 4

These technologies do not need "high accuracy measurements throughout the system." Suggest this sentence is deleted.


DW to investigate

US.118 Section A.7 Other This is not tied into the main document. It describes the advantages but gives no general requirements or recommendations. By this I mean I see no requirements for fluid data, etc. (see below)

Annex 7 is about subsea processing in general and covers the various issues well. It could have been written more or less comprehensive, but it is hard say what is right in this context. There are hardly any "hard" statements based on numbers etc.

Noted

US.119 Section A.8.5 Other At the end of this section, it says that "Multiphase flow metering may be effectively combined with a range of other techniques including downhole pressure/temperature monitoring, flow control and/or


Include general statement that software


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separation..." However, it does not say anything about flow monitoring softwares that calculate flow rates in each well based on state-of-the-art multiphase models incorporated in a network solver, which takes as input ALL pressure and temperature measurements in the production network, from downhole to topsides. Such software packages are now capable of calculating up to three independent flow rates (oil, gas, water) per well. The overall accuracy depends on:

1) Field layout.

2) Number, location and accuracy of sensors.

3) Fluid properties, in particular density difference between oil and water.

4) Phase fractions. High GVF or a water cut close to the inversion point might cause low accuracy.

5) Velocities. Low velocities induce more slip between the phases, which makes the multiphase models more uncertain.

6) Number of independent flow rates per well.

For an oil field, the oil rate can typically be calculated within +/- 10%. On some fields, remarkably good accuracy can be achieved, in particular if the number of independent flow rates per well is less than three, which means that either:

1) The water cut is zero or a known constant, or

2) The GOR is given by natural GOR, meaning that

is now available which can in some applications replace multiphase meter technology or it can be used as an alternative.


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no free gas is entrained from the reservoir (for an oil field), or

3) The liquid fraction is given by saturation conditions, meaning that no free liquid is entrained from the reservoir (for a gas field).

The expected accuracy of a flow monitoring software for a particular field is normally determined as part of an early feasibility assessment. If it can be demonstrated that the accuracy will be at least as good as for MPFMs, we think that the flow monitoring software should be accepted as a stand-alone option not requiring additional flow metering techniques.

If used in combination with other flow metering techniques, a flow monitoring software introduces redundancy and can serve as a "soft sensor" that replaces erroneous sensors. It may also be used in combination with an optimized number of strategically located MPFMs, thus removing the need for a MPFM on each individual well.

Flow monitoring softwares have become gradually more popular and therefore deserve to be mentioned, either at the end of section A.8.5, or - even better - as a separate section between A.8.5 and A.8.6.

US.120 Section K.2 Other Add the sentence "Toughness requirements should be considered for material subjected to impact loads

Accepted

But delete addition in brackets.


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at low temperature (i.e. on the seabed)".

US.121 Sections 6.2 & 6.3

Other This should discuss chemical resistance evaluations for equipment used in subsea processing equipment. (because the equipment may be exposed to well-treatment chemicals)


US.122 Whole Document

Editorial

Document contains various minor typographical and formatting errors which need to be corrected e.g.

- item 11 in figure 1 has a misspelling

- last sentence in clause 5.2.2 has a misspelling

- position of clause 5.5.2.17

- position of words in clause 5.5.3.5

- words are run together in second last sentence of A.9.1.1

- title for figure A.10.a) is not on the same page as the figure itself

- extra period in first sentence of A.11.3.2

- words are run together in the first paragraph of clause I.10.3

- in the third paragraph of clause I.10.3 it should read “and/or” not “sand/or”.

- clause J.2.2 is mislabeled as J.1.2

- starting position of sentence in clause K.2

- the list of abbreviations is incomplete e.g. SARA & QRA and some abbreviations used in the document are not included in the list e.g. PLEM from clause A.6.1 and SS from clause 5.11.3.2

Accepted for all US 122 comments


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US.123 Whole Document

Editorial

Figures

- some of the figure references throughout the document are incorrect, especially in Annex A

- figures A.8 & A.11 do not exist

- many of the figures could do with being redrawn and additional figures would be helpful in some areas e.g.:

i. item 7 in figure 2 is not keyed, also the weight of the subsea tree should be shown as another load on the subsea wellhead system

ii. the text in figure A.1is so small as to be almost illegible

iii. the upper portion of figure A.3 is so small as to be almost illegible

iv. a diagram of a typical HIPPS would be useful in A.8.8

Accepted for all US 123 comments exept the last one.

Noted.

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