Section Review Comments Section Section # Comment ... · 2. Subsea battery system Accepted Item g) revised as proposed. (included in mark-up) Clause 1 Fig 1-1 New in WD5 and requires

Section

TypeSection Section # Comment TypeComment Proposed Change Accepted Rejected

Review Comments

Clause 1 1.1 Technical

Statement about SIL is both unlogic and unclare. Correct: The IEC 61511 practice of establishing a

SIL rating will still be allowed, but only to the

extent as it pertains to that portion of the

complete system that operates identified safety

functions including final function element.

Delete: A SIL-defined overall intervention system

should no longer be recognized or practiced.

Accepted

Scope 1.1 will be rewritten to adress this comment

Clause 1 1.1 after e) TechnicalThis text is removing all demands for a SIL

system.

The API has to clearly state what part of the

system shall be SIL verified and to what SIL level. AcceptedScope 1.1 will be rewritten to adress this comment


Section 1.1 – paragraph 3

” The IEC 61511 practice of establishing a SIL

rating will still be allowed, but only to the extent

as it pertains to that portion of the IWOCS that

operates identified safety functions. A SIL-

defined overall intervention system should no

longer be recognized or practiced.”

Section 2 – IEC 61508 and 61511 as normative

reference

Comment: This is not in line with Section 1.1;

Propose to change to informative.

Comment: If it is intend that SIL shall be

informative, the IEC 61508 and IEC 61511 shall

be removed from the Normative refrences and

placed in the bibliography.

Accepted


Clause 1 1.3(g) Technical include subsea accumulator to list 2. Subsea accumulator systems Accepted Accepted as proposed (included in mark-up)

Clause 1 1 Technical

Currently, Table 1 states that a Well Intervention

operation is Not Applicable (NA) when using a

Landing String with BOP Spacer Joint. This is

misleading as setting and pulling a tubing hanger

plug after installing a vertical tubing hanger with

a BOP spacer joint could be considered Well

Intervention.

Update the Well Intervention operation when

using a BOP Spacer Joint to include d+e (vertical

dual bore tree and vertical monobore tree).

Rejected

The basis for Table 4-1 is based on the following, where

Pulling of a TH plug is part of the completion operation:

For each mode of operation there are typically four main

operations performed (see Table 4-1):

a) subsea tree installation and retrieval;

b) well completion (e.g., production tubing/tubing hanger

installation, well perforation, and test production);

c) well intervention (e.g., through production tubing

operations, well perforation, and test production);

d) full workover (e.g., retrieval and replacement of

production tubing).

24 22, 23 2 tDD tDDp yioy

Clause 1 1 Technical

Footnote b requires clarification. Update with

the suggested change.

Well completion, well intervention and full

workover operations are limited due to lack of

barrier elements in the BOP Spacer Joint. Refer

to Section 4.6, System Review, for guidance on

how to determine if a BOP Spacer Joint is fit for

purpose for a given operation.

Rejected

Table 4-1 is labeled “Typical” and therefore is not

normative. Industry practice has been to limit operations

when using a BOP spacer joint.


The introduction focuses and specific topics

rather than addressing all the changes made

from the 2nd to 3rd edition of API 17G. The

discussion regarding SIL is very negative and this

text should not part of an industry standard. The

requirement regarding safety function and the

scope of SIL are well covered in the standard do

not need to be repeated in the introduction

It recommended that the Editorial team of API

17G write an introduction that briefly address

the changes made from the 2nd to 3rd edition

and the general philosophy the standard. The

following should be mentioned: 1) applicable for

designers, manufactures, service providers and

end users. 2) System based standard, but where

components can e dsign and qualified

independent of the system requirements. 3)

Stand alone standard, where Annex K, Annex J,

Annex L and Annex M have been included. 4)

Safety philosophy, safety barrires, safety

functions etc. 5) Component, equipment and

system verification and validation covering

qualification, FAT, EFAT, SIT and operations. 6)

etc.

Accepted

Introduction has been re written to address these issues

Clause 1 1.2

Titanium reference in 1, WD4 - now in 1.2 needs

to be updated - in conflict with 7.4.2

go back to WD4 and bring reference back into

WD5 - usage in the system is acceptable, this

doc focuses on ferrous materials (non-ferrous

covered in G1)

Accepted

Last para in Clause 1.2

Replace:” This API 17G Specification is limited to

components manufactured from carbon, low-alloy steels,

and corrosion-resistant alloys. Components fabricated

from composite materials and flexible pipes are beyond

the scope of this document. However, this document does

not prohibit the use of special materials.”

With the following:

“Structural design methods and criteria given in API 17G

Specification are limited to components manufactured

from materials which ensure ductile failure modes (e.g.

carbon steels, low-alloy steels, and corrosion-resistant

alloys). Components manufactured from materials which

may not ensure ductile failure modes (e.g. composite

materials, titanium and titanium alloys) are beyond the

scope of this specification, but their use is not prohibited.”

Clause 1

Scope pg

13

#2

following f)

Editorial

This lengthy paragraph appears to be primarily

tutorial and conversational, therefore, It would

be better served as a "Note:" It does not appear

to include requirements of substance. The

reference to allowing IEC 61511 SIL ratings is

supplemental unless mandated.

Make this a Note:

Accepted


Clause 1

Scope pg

13

#3

paragraph

Editorial

For clarity of purpose, move this to ahead of the

aforementioned note which is formerly

paragraph #2

Move this to ahead of the aforementioned note

which is formerly paragraph #2

Accepted


Clause 1

Scope pg

14

Last

paragraph

Technical

The content of this paragraph indicates that the

remainder of the content is optional and non-

mandatory; I do not believe this is the intention

of this text. If this is intent no change is

required.

Refine the wording to have the requirements of

this specification mandatory. Accepted


Clause 1 1.3

Specific Equipment covererd in Document section g) Topside power storage item c) is

further separated into hydraulic and electrical

power. The same philosophy should apply to

item g). Suggest defining item g) as follows:

1. subsea accumulator systems

2. Subsea battery system

Accepted

Item g) revised as proposed. (included in mark-up)

Clause 1 Fig 1-1New in WD5 and requires some explanation

AcceptedIntroduction to Figure 1-1 to be provided

Clause 3 Figure 3-2

Need to update the Figure 3-2 on the CWOR to

illustrate the annulus conduit line (Section 3.4)Rejected

Moved to WD6 Comments

Ray/Brian


Definition of what is meant by a DH-system and

a EH-system is required to establish consistency.

Add:

direct hydraulic IWOCS

IWOCS design where the control valves for

subsea hydraulic functions are located topside,

e.g. in a hydraulic distribution unit

electro hydraulic IWOCS

IWOCS design where the control valves for

subsea hydraulic functions are located subsea,

e.g. in a subsea control module

Accepted

3.1.95 Intervention and workover control system (IWOCS)

controls and monitors intervention, retrieval, access and

deployment of subsea well control equipment with or

without a marine riser.

direct hydraulic IWOCS

IWOCS design where the control valves for subsea

hydraulic functions are located topside, e.g. in a hydraulic

distribution unit

electro hydraulic IWOCS

IWOCS design where the control valves for subsea

hydraulic functions are located subsea, e.g. in a subsea

control module

Clause 3 3.1.184 Technical

The difference b/w the SSTTA and SSTT is not

obvious

Clarify that the SSTA a subcomponent of the

SSTTA and resides b/w the Lower shear Ram and

the PSJ.

Add the SSTT acronym to the header.

Accepted,

with

modifications

3.1.183 subsea test tree (SSTT)

the SSTT alone constitutes the primary intervention well

barrier, which isolates the well from the landing string or

C/WO riser with or without wireline and coiled tubing

present. Typically includes an upper isolation valve, lower

shear/seal valve, and disconnect latch.

NOTE 1 The SSTT valves are backup barrier elements in the

primary barrier, i.e., when the SCSSV is not available, the

SSTT valves will constitute the upper closure device in the

primary barrier after a disconnect of the SSTT latch.

NOTE 2 When the landing string is connected, the

combination of the SSTT valves and SSTT slick joint work in

Clause 3

Section

3.1.23/3.1.

24

Editorial

Section 4.20 gives broad defintion of V&V.

Section 3.1.23 and 3.1.24 only refers to testing.

Although clearly stated that list is not inclusive

this tends to imply only physical testing

Suggest broadening definitions in Section 3.1.23

and 3.1.24 to inlcude other methods of V&V or

add reference to section 4.20. Rejected

Clause 3

Section

3.1.198/3.1

.199

EditorialSame as above except refers to 3.1.198 and

3.1.199

Same as above except refers to 3.1.198 and

3.1.199 Rejecteddefinition already includes: "prove by analysis or test"

Clause 3 Figure 2 editorialno description of the entire assembly EDP+WCP

= LWORP RejectedReject.

See next line item

Clause 3 3

Define: Verification (eg FAT, FEA ..) and

Validation (qualification testing). However in

the ISO 9001` is opposite … These definitions are

outlined in Clause 3:

Qualification and Validation Interchangeable -

Ref Q1 - Design validation is proof by testing -

ISO 9000 : 2005 definitions - (2) definitions in

Qualification and Validations

Accepted

Accept as follows:

Was: "Figure 3-2: Nomenclature for a typical open-water

intervention system"

change to

"Figure 3-2: Nomenclature for a typical open-water

intervention system (LWRP)"


Definition contradicts table 6 wrt. Functional

design factor

has to include pressure

Accepted


Clause 3Definitions

General

Definitions shall not include requirements and

shall be just a definition of the term. Many of

the definitions are protracted and include

several notes; this information is much better

served within the text of the standard.

Relocate all data but single phrase or sentence

definitions of the terms into the applicable text.

Rejected

Valid comment, but no specific action, except to review

existing definitions for inclusion of potential requirements.


Add example of loss of station fail safe

philosophy.

EXAMPLE 3: In the event of a loss of

stationkeeping of the vessel, the CWOR system

shall be validated to have a weak point above

the WCP shear/seal devices. This is inherent

chracteristic of a fail safe system and is known as

weak point analysis.

Rejected

No basis for this comment found in 4.1

Clause 4 4.2 GeneralThe responsible for barrier philosophy should be

clear.

Operators responsible to establish an overall

well barrier philosophy.Rejected

This document addresses system requirements and

strategy not company policies.

Clause 4 4.2 GeneralEnd user is reponsible to follow operating

limitations set by the contractor(s)

Operator is reponsible to follow operating

limitations set by the contractor(s)Rejected

requirement is clear in note b)

Clause 4 4.2 General

Who has the overall HMS responsible in design,

production, testing and operation?

The responsible party shall ensure that the

management of health, safety and the

environment comprises the activities, resources,

processes and organisation necessary to ensure

prudent activities and continuous improvement

Rejected



Section 4.2

4.2.2 System engineering

a) System engineering responsible is defined as

the role responsible for the subsea well

intervention system design and integration on

behalf of the end user.

6.2.2 System design

System design is end user responsibility.

Propose to clarify that the end user is

responsible, since the end user is the final

arbiter of the system.

Rejected



Is the retainer valve a part of a safety system in

EQD, ref safe state?

Safe state shall ensure safety for rig and

presonnel with no or limited spill to sea from the

production bore(s). Closure of the RV shall be

evaluated as part of safe state.

Rejected

requirement is clear and covers the designed system


Definition of safety strategy need to be clear on

critical interlocks related to HSE.

Add new sentence:

... the basis for a safe operation of the system.

This shall include requirements for interlocks

between the different barrier elements in a

safety sequence, e.g. before a EDP disconnect

can be executed isolation of well and riser shall

be verified.

Rejected

requirement is clear and covers the designed system


4.13 Safety strategy

“…The reliability method used to quantify the

performance shall be based on a recognized

method of analysis, see ISO TR 12489[59]…”

Comment:

Since ISO TR 12489 is not yet formally released,

this reference is misleading. Please remove

subject reference, if not published by release of

API 17G or state in bibligraphy that publication is

pending, or replace with IEC 61511. According to

ISO CS the target publication date: 2014-05-31 Accepted

requirement revised.


Requirements for independance between safety

functions is unclear.

Correct:

... 3. emergency quick disconnect (EQD) to

isolate well at wellhead and disconnect from the

well.

Safety-related functions shall as far as practically

possible be independent to non-safety functions

such that a failure in non-safety systems shall

not adversely affect intended safety functions.

There should be independence between the

different safety functions to the extent that the

functional integrity of the safety functions is not

compromised. The safety strategy shall define

how many functional elements in a safety

function that shall be independent, e.g.

independent control valves and upstream

functional elements but common final functional

element like a valve, ram or connector.

Periodic testing shall ...

Rejected

requirement is clear

Clause 44.15 3r

paraTechnical

The first sentance of the para does not make

sence and this para needs to be made norative

"Components and systems, which are outside

the scope of API 17G, and have an influence on

the overall system (design, manufacture, test,

operation), shall be clearly highlighted and any

effect implemented to ensure overall

system safety. In particular, equipment supplied

in accordance with component standards (e.g.,

API 6A, API 14A, API 17D, and API 16A) are

designed and qualified for designated sizes and

rated working pressures (RWPs) only (i.e.,

pressure-based design). For subsea well

intervention system applications, it is normal

industry practice to ensure that the load

combinations determined in API 17G (e.g.,

normal, extreme, and accidental loading

conditions) do not exceed the rated capacity

(i.e., normal capacity) of pressure-based

designed equipment"

Change to "Components and systems included in

a subsea well intervention system, which have

not been design and manufactured and qualified

in accordance with API 17G, shall be indentified.

A risk assessment (see Clause 4.7.1) shall be

conducted to indentify any risk associated with

use of these components and systems Corrective

measures shall be implemented, when neccasary

to ensure . In particular, equipment supplied in

accordance with component standards (e.g., API

6A, API 14A, API 17D, and API 16A) are designed

and qualified for designated sizes and rated

working pressures (RWPs) only (i.e., pressure-

based design). During operation of subsea well

intervention systems, all loads and load

combinations determined in API 17G (e.g.,

normal, extreme, and accidental loading

conditions) shall not exceed the rated capacity

(i.e., normal capacity) of pressure-based

designed equipment"

Accepted

requiremetn was partially revised for clarity


Table 4-2 incorrect cross references For subsea test tree replace "annex C" with

"Annex K" for design and qualification. For

lubricator and retainer valve replace "Annex C &

D" with "Annex K & l2 for design.

Rejected

requirement is clear. Modifications to the current annexes

will provide clarity

Clause 4 4.2.5 Editorialcontent stating "hold" populate to ensure all "shall" content is

captured.Accepted

requirement is revised

Clause 4 4.5.6 Generaltext stating "all parts" seems to loose to be

captured asa shall statement

previous revision spelled out which relevant

sections of ISOAccepted

requiremetn has been clarified by removing reference to

all parts

Clause 4 4.9.a Technicalthe term "well completion" does this imply

completion installation?

allow well completion (installations/retrieval),…Rejected

completion represents installatons and retrieval

Clause 4 4.10. General

"the overall system design shall be fail-safe".

How is this possible for well completion

installation on drill pipe for vertical trees?Rejected

requirement is clear. System design and exception

requirements are clear.

Clause 4Section

4.20Editorial

There are many mislabelled references to this

section throughout document. Section 4.20 is

mislabelled Section 4.19

Change mislabelled references from Section 4.19

to 4.20. There are multiple instances throughout

body of document (too many to list)Accepted

requirements revised

Clause 4

4.14, Table

2 Accepted


Add note to Tubing hanger running tool and to tubing

hanger orientation system:

Reference to Clause 4.14 paragraph 3.

Paul will propose an update to Table 2. In progress

Clause 4 4.3, Figure General

Feedback loops are open to interpretation and

should be reassessed

Re-visit the flow diagram

Accepted


Review flow diagram

Table reference is 4-1. Tony has made a new proposal

Clause 4 4.2 GeneralAdd 4.2.5 Testing Facility Testing Facility should have a written out list of

responsibilities as wellRejected

requirement is clear for service provider

Clause 4 4.2.5 General No text in section Add hierarchy of responsibilities Accepted requirement revised


Manufacturer is instructed to eliminate or

reduce hazards, but what if the manufacturer

isn't made aware of all of the potential hazards?

Say that it is the responsibility of the end user to

inform the manufacturer of all potential hazardsRejected



"No single failure of a barrier… loss of well

control" is not possible with only a single metal

to metal seal or a pipe wall between bore and

the environment

Although this would be preferred, it can not be

guaranteed with only single metal to metal seals

or with a pipe wall that could have a fatigue

failure. Remove this statement, because it's

almost impossible to guarantee with a single

tube wall or a metal to metal seal

Rejected


Clause 4 4.20' General

"It shall be verified that provisions contained in

API 17G, end user's specification(s), and

regulatory requirements have been met." By

who?

Who verifies this?

Accepted

requiremetn revised


To define

the requirements for SIL.

c) safety instrumented systems shall be used as

one of the safety barriers. The safety functions

of the safety instrumented system for subsea

well intervention systems shall, as a minimum

unless otherwise identified in the safety

strategy, be as follows:

1. process shut down (PSD) for well flowing

conditions;

2. ESD to isolate well at wellhead;

3. emergency quick disconnect (EQD) to isolate

well at wellhead and disconnect from the well.

NOTE: A SIL rating number is not a

requirement on the safety instrumented

systems, unless specifically stated in the safety

strategy.

Accepted



"Requirements not specifically required by the

end user… shall be specified by the

manufacturer." How is the manufacturer to

know other requirements if the end user doesn't

specify.

Manufacturer could be put in a hard place here,

so specify that the end user must provide and

verify that all of these requirements are fit for

purposeAccepted

requirement revised

Clause 4 4.7.1 a Editorial Qunatitive should be qualitative Change first word to qualitative Accepted Revision made.

Clause 4 4.8 Editorial 3rd paragraph below (d), include Fig 4.3 ...see Figure 4-2 and Figure 4-3 Accepted Revision made to section

Clause 4 Fig 4-6 Technical

The labels are all out of order. See Figure 4-7 for

correctd labelling. Must have been a typo. I

won't list all 18 of them here, but almost all

lablel are incorrect.

Correct labels as per Figure 4-7

Clause 4 4.13 EditorialFirst paragraph under (d), second sentence.

Should be Fig 4-8, not F-4-10

Change Fig 4-10 to Fig 4-8Accepted

4.13 is now 4.11 due to Clause revision

Clause 4 4.13 Editorial NOTE: section still have [xx] in reference replace xx in reference or remove. Accepted NOTE revised

Clause 4 4.13 EditorialFirst paragraph under NOTE, first sentence.

Section should be M.1.2.15, not M.1.3.15

replace M1.3.15 with M.1.2.15Accepted

Specific reference removed.

Clause 4 4.13

To define

the requirements for SIL.








conditions;







strategy.

Accepted

Clause 4Section 4.8,

Table 4-1Technical

Currently, Table 1 states that a Well Intervention

operation is Not Applicable (NA) when using a

Landing String with BOP Spacer Joint. This is

misleading as setting and pulling a tubing hanger

plug after installing a vertical tubing hanger with

a BOP spacer joint could be considered Well

Intervention.

Update the Well Intervention operation when

using a BOP Spacer Joint to include d+e (vertical

dual bore tree and vertical monobore tree).

Rejected

Technical review consulted and requirement not changed.

Clause 4Section 4.8,

Table 4-1Technical

Footnote b requires clarification. Update with

the suggested change.

Well completion, well intervention and full

workover operations are limited due to lack of

barrier elements in the BOP Spacer Joint. Refer

to Section 4.6, System Review, for guidance on

how to determine if a BOP Spacer Joint is fit for

purpose for a given operation.

REjected

Requirement is clear, references to other sections within

the document are expected by the users.

Clause 4

4.16.2 Ops

from a DP

vessel

Editorial

"Preventiative measures to reduce both the

probability and consequences of drift-off/drive-

off shall be implemented."

Remove the word probability. API 17G has not

influence on reducing the probability of a drift-

off/drive-off.Accepted

referenceed wording removed

Clause 4

4.16.2 Ops

from a DP

vessel

Editorial

Bullet No. 1…"measures directed toward

reducing the probability of experiencing a drift-

off/drive-off situation"

Same comment as above. API 17G has not

influence on how to reduce the probability of a

drift-off/drive-off. API 17G should only focus the

functionality of equipment designed to secure

the well should a drift-off/drive-off occur.

Probability of the event actually happening is

outside the scope of API 17G.

Accepted

Referenced workding removed.

Clause 4

Section

4.16.2,

Table 4-3

Editorial

Dynamic positioning systems, power systems

and thruster systems are outside the scope of

API 17G

Remove Table 4-3. API 17 G should only focus

on preventative measures to reduce the

consequence of a drift-off/drive-off. API 17G has

no influence around reducing probability.Rejected

4.3 is not a NOTE and used only for informational purposes

to help clarify the document.

Clause 4

4.9, 4.10.

4.11, and

4.12

Initial

Technical

Each of these subsections requires a lead-in

sentence (paragraph) that states how to apply

and use its content. Otherwise these are

interesting lists of information without an

applicability plan.

Author lead in text to assure these topics are

applied as intended. (this may apply elsewhere

in the specification these are four examples)Rejected

Requirements are clear

Clause 4 4.13 Safety

strategy

Editorial

Because there are three or more lists within this

text and they are on at least two different levels,

it is suggested that there be internal numbering

of the content to better identify the key areas of

concern and prevent the intermixing of the

thoughts provided.

Sub-divide the section into at least four parts to

support the data provided clearly

Rejected

Requirements are clear

Clause 44.14, para

#3Technical

"At least two independent and tested barriers

between the reservoir and the environment

should be to prevent unintentional flow from

the well." I believe the intention of the authors

is to have the barriers close and seal to prevent

leakage, therefore, why offer the "should" ?

Replace the "should" with "shall" and require it

to be tested to verify the sealing.

Accepted

Requirement revised.

Clause 4

Table 4.16

Table lead

in

Technical

This table contains references to many clauses

and documents of requirements, however, the

lead-in to it does not indicate if this is just to aid

in finding the data or if these requirements are

mandatory.

Clarify the purpose of the table and its contents.

If all is mandatory that is substantial, if just

recommendations for review OK too but the

user must know. Accepted

Requirement revised

Clause 44.2 in its

entirityTechnical

The content of this section is at best disjointed

and it lacks the kind of clarity that would appear

as merited. The terms verification and validation

are used but their applicability is not clear. Is

this at a system level, an operational level or at a

component level or all the above? I think I can

develop my own philosophy about these

requirements but clarity would bring ease of use

and purpose.

A complete restructure and rewording of this

section is merited, the impact is substantial, and

therefore, clarity is merited. Perform and

document design verification of each product

and product interface to the requirements of a

documented procedure and acceptance

criteria".......... and similar wording.

Documented results and approvals are

necessary.

Accepted

Requiremnts revised and clarified

Clause 4 4.5 n)

Designer's corporate system design

philosophies.

It is assumed that the term 'corporate system' is

synonomis with 'standard'. If not please clarify

the meaning of 'corporate system'. If so please

replace with the term 'standard' as it will be

more readily understood

Accepted

Requirement revised

Clause 4 4.7 l)

designer's corporate system design

philosophies.

It is assumed that the term 'corporate system' is

synonomis with 'standard'.

If not please clarify the meaning of 'corporate

system'.

If so please replace with the term 'standard' as

it will be more readily understood

Accepted

Requirement revised

Clause 4 4.9

System Functional Requirements

Add additional comment:

m) proved means for returning the well to a safe

state in the event of an emergancy

Figure 4.6 is incorrectly labelled. Please revise

Accepted

Requirement revised

Clause 4 4.14

Barrier requirements

… During emergency operations, a minimum of

two mechanical barrier elements in the system

should be available and functioned before

removal of a portion of the WCP or SSTTA, see

Subsection 5.8 and Subsection 5.18.

Systems will now have safety joints to protect

the well head, tree, etc. As per its design, the

safety joint will break before the safety barriers

are closed. Is it relevant to mention this here.

Suggested addition:

'In the event of a separation of a safety joint, the

two mechanical barriers should automatically

close in a time that meets the safety

requirements'

Accepted

Requirement revised

Clause 4 4.15 Regulations, codes, and standards Please include the safety joint in table 4-2 Accepted Requirement revised

Clause 4 4.19

Documentation, records, and traceability

...Records of the subsea well intervention

system shall be kept and maintained to

demonstrate compliance with the requirements

of API 17G throughout its lifetime, see

Subsection 11.11.

There is no section 11.11

Accepted

Reference removed

Clause 4 4.2

Verification, Validation, and Integrity

Management

...Continuous verification and integrity

management of the subsea well intervention

system shall be conducted during the life of the

system. General guidance with regard to system

reliability and technical risk management can be

found in API RP 17N[61] and ISO 20815[60].

There is no section 11.11

Accepted

Reference Removed

Clause 4 4.2

In both modes of operation the primary barrier

envelope extends to the surface tree. The

secondary barrier envelope terminates at the

subsea isolation device. In thru-BOP/drilling riser

intervention mode, primary subsea well

isolation is provided by the subsea test tree and

secondary subsea well isolation by the subsea

drilling BOP. In open water intervention mode,

subsea well isolation is provided by the well

control package (i.e. the well control package is

a common barrier element).

Definition required: Common Barrier Element

Rejected

Requirement is clear

Clause 4.13

To define

the requirements for SIL. Jamie's text








conditions;







strategy.

Accepted


second last sentence of section : Rams

with bidirectional hydraulic actuators shall

include an automatic and mechanical locking

system to prevent

unintentional opening;

Rams with bidirectional hydraulic actuators shall

include an automatic and mechanical locking

system to prevent

unintentional opening or closing........ some

designs out there will close due to bore pressure

if actuator open pressure is lost, not always a

good thing if wireline is getting run at that point.

Accepted

New Text " Rams with bidirectional hydraulic actuators

shall include an automatic and mechanical locking system

to prevent unintentional opening or closing."

Clause 5 5.4 Editorial

The following should be none prefixed list items

list items: " - active (rotary) type, requiring the

rotation ……." and " - passive (helix/linear) type,

uses downward …."

Revise as commented.

Accepted

Missing letter bullets from sent WD 5 document, was

correct before hand.


Ist para "The purpose of the tubing hanger

orientation system is to orientate the tubing

hanger before engagement of the

tubing hanger seals in the sealing bore(s)"

combines both a purpose and a requirement. Th

erequirem,enst is given in the 4th para. 1st

Should only include purpose.

Change "The purpose of the tubing hanger

orientation system is to orientate the tubing

hanger before engagement of the tubing hanger

seals in the sealing bore(s)" to "The purpose

of the tubing hanger orientation system is to

orientate the tubing hanger"

Accepted

New Text "The purpose of the tubing hanger orientation

system is to orientate the tubing hanger."


The following provison is not precise and can

misunderstood to mean that a singel valve shall

have both types of failure modes. "The retainer

valve shall be a remotely operated, “fail-in-

position” or “fail-safe close” isolation valve

depending on operational requirements."

This provision shall be changed to "The retainer

valve shall be a remotely operated and shall be

either “fail-in-position” or “fail-safe close”

isolation valve depending on operational

requirements." Accepted

new text "The retainer valve shall be a remotely operated,

and shall be either “fail-as-is” or “fail-safe close” isolation

valve, depending on operational requirements."


Ambiguous statement:

"Retainer valve design(s) shall support both fail-

in-position and fail-safe close configurations,

and position shall be fixed before deployment."

Statement as written is confusing and can be

understood that the same valve shall be

designed to have both failure modes and would

exclude spring assisted actuator designs.

This sentance is uncessary and the normative

requirements is covered in the preceeding

sentance (i.e."The retainer valve shall be a

remotely operated and shall be either “fail-in-

position” or “fail-safe close” isolation valve

depending on operational requirements.")

Delete the following "Retainer valve design(s)

shall support both fail-in-position and fail-safe

close configurations, and position shall be fixed

before deployment."

Accepted

Accept in principle, but the statement is required such that

the valve if it has a spring close and then have the spring

removed (as stated in comment). This is required due to

the possible saftey stratery.

New text "Retainer valve design(s) shall support both “fail-

as-is” and “fail-safe-close” configurations by either physical

or via control system logic, but the position shall be fixed

before deployment."

Clause 55.21.2 Item

eTechnical

"Hydraulic functions for EDP and TRT connectors

shall be incorporated into the intervention and

workover control system (IWOCS) operating

system"

Statement as written would exclude installing XT

on wire with ROV-operated TRT

Replace "Hydraulic functions for the EDP

connector and WCP connector (TRT) shall be

incorporated into the intervention and workover

control system (IWOCS) operating system" Accepted

new text "Hydraulic functions for the EDP connector and

WCP/TRT connector shall be incorporated into the

intervention and workover control system (IWOCS)

operating system."

Clause 5 5.18 c) Editorial

The interface connection between the TRT and

the rest of the LWRP shall have

a defined minimum combined structural

capacity equivalent the subsea tree.In addition

to the pressure capacity rating shall not less

than the pressure rating of the subsea tree;

In addition the pressure capacity rating shall not

be less than the pressure rating of the subsea

tree.

Accepted

new text "c) The tree running tool (TRT) shall interface with

the subsea tree's re-entry spool and may be integral to the

LWRP, WCP or a separate item. The TRT shall comply with

the functional requirements specified in API 17D. The

interface connection between the TRT and the rest of the

LWRP shall have a defined minimum combined structural

capacity equivalent the subsea tree. In addition the

pressure capacity rating shall not be less than the pressure

rating of the subsea tree."

Clause 5 5.18 d) Editorial

These upper interface connection(s) shall have a

defined minimum combined structural capacity

equivalent the subsea tree. In addition to the

pressure capacity rating shall not less than the

pressure rating of the subsea tree;

These upper interface connection(s) shall have a

defined minimum combined structural capacity

equivalent to the subsea tree. In addition the

pressure capacity rating shall not be less than

the pressure rating of the subsea tree.Accepted

new text "d) The WCP may be configured as a single unit or

as a sectioned unit (reference Annex A) and may be

equipped with an upper re-entry spool interface with the

EDP or with a connection to mate with the lower end of

the C/WO riser. These upper interface connection(s) shall

have a defined minimum combined structural capacity

equivalent the subsea tree. In addition the pressure

capacity rating shall not be less than the pressure rating of

the subsea tree.;"


Second paragraph : Choice of

configuration will depend on the type of subsea

tree and the other types of well intervention

equipment may have accessed the well.

Choice of configuration will depend on the type

of subsea tree and any other type of well

intervention equipment that may have accessed

the well.Accepted

New text "Note: The choice of configuration will depend

on the type of subsea tree and any other type of well

intervention equipment that may have accessed the well."

Clause 5 5.21.1 p) Editorial

p) reuse of seals, seal rings/gaskets that are

replaceable on the surface vessel shall be as

specified by the

manufacturer and shall be available for

inspection and easily replaceable on the surface

vessel.

This is a repeat of 5.21.1 l)....remove one or the

other

Accepted

Remove p. see mark up

Clause 5 5.21.2 j) Technical

the connector should allow for low-pressure

back seal testing to ensure that the

connector/seal is correctly made up;

surely this requirement is introducing an

unneccesary leakpath, suggest that it removed

as a internal pressure test would always be

preferable

Accepted

Delete j). This as picked up in API colour code and it cant

be shall, as it is only a should therefore remove.

Clause 5 5.21.3 f) Technical

Riser connectors should be designed with

rotational orientation to enable monitoring of

tubing hanger angular orientation before

landing or subsea test tree latch angular

orientation prior to re-entry;

This statement suggest that the the connection

must have some sort of timing feature to ensure

it always ends up in the same orientation once

made up...how is this possiple with T&C design

riser joints ...suggest this statement is either

clarified or removed

Accepted

Remove f), as it was also yellow coloured by API.

Clause 5 5.21.1 Editorial Item L and P are the same Delete item P Accepted duplicate of Line 51.


these are the b) and c) that come after g) for

some reason, suggest that they become i) & ii)

of g) b) to

accommodate asymmetric pull caused by

malfunction of at least one tensioner; c)

to accommodate skew loads due to

misalignment of the vessel’s tensioner wires;

Surely these are extreme or accidental events

...we should not need to design for these but

should consider them as extreme or accidental

load cases onlyRejected

You still require to design for these conditions if they are

extreme or accidental. The design safety factors will be

different and you can document what the capability is then

it is up to the client to determine if there is enough safety

factor.


When tension joint is connected to Direct Acting

Tensioners (DAT), provisions should be given to

avoid large skew compression loads on the riser

following a DAT cylinder lock-up on a wave crest

Modify sub-bullet b) as follows:

to accommodate asymmetric load caused by

malfunction of at least one tensionerAccepted

new text " 2. to accommodate asymmetric pull load caused

by malfunction of at least one tensioner."


To ensure simple and safe make-up of the

tension joint to the uppermost standard riser

joint, connections requiring rotation and

torquing of the tension joint should be avoided.

Amend bullet f) as follows:

the bottom of the tension joint shall be

connected to a standard riser joint. The bottom

connection shall be a non-rotational quick

connector, ref. Subsection 5.21.5

Rejected

This is an optional addition and can not be mandatory


A note on responsibility for selection of

connector should be added. Wireline/coiled

tubing adapters constitute the interface

between the well intervention system provider

and the coiled tubing system provider

Add the following: "NOTE Wireline/coiled tubing

adapters constitute the interface between the

well intervention system provider and the coiled

tubing system provider" Accepted

new text "c) NOTE: Wireline/coiled tubing adapters

constitute an interface between the well intervention

system provider and the coiled tubing system provider."

Clause 5Section

5.35Editorial

Portions do not fit with the adjoining text. This

pertains to the phrases starting with "dynamic

environmental load …" and ending with "… in

accordance with API 7k".

Align these phrases with the adjoining text as

intended. If each phrase is meant to be a unique

item within this listing, the last listing within this

section will be identified by letter "t)' once

corrected.

Accepted

Changed section call out as it stated 5.35 which was

incorrect.

Wrong in WD 5.2 document but correct as per marked up

document.

Clause 5Section

5.35Editorial

Portions do not fit with the adjoining text. This

pertains to the phrases starting with "provision

of sufficient …" and ending with "… into the

marine drilling riser".

Align these phrases with the adjoining text as

intended. If each phrase is meant to be a unique

item within this listing, the last listing within this

section will be identified by letter "j)' once

corrected.

Accepted

Changed section call out as it stated 5.35 which was

incorrect.

Wrong in WD 5.2 document refer to marked up document.


The below requirement applies dual bore

vertical trees. Horizontal access to the annulus

on horizotnal trees is through the crossover

wing valve and not through the SSTT.

c) Permit fluid access to the production tubing

and the annulus between the production tubing

and last casing string to allow pressure testing

and fluid circulation;

Revise to clarify that this only applies to dual

bore vertical trees.

Accepted

New Text "c) Permit fluid access to the production tubing

to allow pressure testing and fluid circulation. Permit fluid

access to the annulus between the production tubing and

last casing string for vertical trees

Clause 55.10.1

5.11Editorial

"fail-in-position" used in 5.10.1 (RV) while "fail-

as-is" used in 5.11 (LV)

Change 5.11 to match 5.10.1

Accepted

Accept with in principle, changed 5.10.1 to match 5.11

new text to add to 5.10.1 " replace "fail-in-position" with

"fail-as-is"".


RV does not not need to be gas tight after

shearing coil tubing during. Some amount of

leakage could be allowed since finite source of

gas in landing string

Add comment to section. Leakage rate similar to

that recommended for RSM could be acceptable.Rejected

This is a option of cutting with the RV, however in

deepwater riser could hold a large volume of gas and as

such will have to seal. Leakage criteria given in Annex K.


sub section e) states the unlocking force shall be

greater than the locking force. This can be an

issue in deepwater in riser connectors due to

differentials between control fluid and

completion brine.

Change shall to should.

Add statement about pressure differentials as

result of completion brine and control fluid

density to be considered and reviewed during

HazOp. Accepted

Agree in principle but can not be a should otherwise it

could unlatch even in deepwater. Also modified due to API

Colour coding.

new text "e) The connector shall be hydraulic and remotely

operated. The connector design shall provide greater

unlocking force than locking force, typically 25% greater,

however, it is the responsibility of the manufacturer to

document the locking and unlocking pressures and forces ,

taking into account pressure differentials due to dis-similar

fluids."


sub section j) back testing of seals to be

provided. This can lead to excessive seperation

force if the port is plugged and a seal leaks.

Back testing of seals should be optional.

Accepted

Delete j). This as picked up in API colour code and it cant

be shall, as it is only a should therefore remove.

Clause 5 5.26 Technicalsub section a) pupose is to provide protection to

umbilcal. If there is no umbilical then there is no

need for CWJ

…protective sleeve that extends trhoguh the

rotary and protects and umbical from damage as

the rig heaves.

RejectedThis point is covered in new e) was old d)

Clause 5 5.26 Technicalsub section b) CWJ are normally rigid pipes with

a slot. The stiffness is an issue and should be

considered as part of the GRA.

Add statement that stiffness be consdiered in

GRA. RejectedThis is covered in Annex B, which details the GRA etc


CWJ may be required to transmit torque to align

THRT or SSTT Latch.

Add statement that troque transmission be

considered based on the project requirements.

Rejected

Correct the CWJ may have to take torque, but so will most

other connections, therfore it shold be taken into acocunt

during the design phase the use of the CWJ. I.e. is it a bolt

on or a one piece body.


General RSM comments:

1) They may be used alone or in combination

with CWJ's

2) The diverter may be closed on an RSM so the

strip thru load capacity needs to be defined

3) The RSM shall be rated for 500 psi external

pressure with a acceptable gas leak rate of 100

psi in 10 minutes with an initial gas volume of

6.8 ft^3

Add comments as stated

Accepted

Point 1 is rejected.

Point 2 is rejected. Strip through capacity is based on the

divertor bags

Point 3 is accepted but the on the gas rate is not applicable

to add as it depends on the diverter.

New Text.

b) The riser sealing mandrel shall provide the means to

allow closure of the riser diverter bag on its external bore

while providing a seal to protect the rig floor above it. The

riser sealing mandrel shall be rated for 500psi external

pressure and the leakage rated recorded for each 100psi

increment. The leakage rate shall be reviewed against the

diverter design during the safety strategy.


sub section b) states the length should be long

enough to allow compensated heave of the rig.

The RSM length and psoition is based on the

disconnect position of the string and wether it is

being used in comination with a CWJ. The

disconeect position is when the SSTTA is

unlatched and picked up to clear the LMRP /

BOP connector.

Add a section on RSM length and postion

determination

Accepted

New text

c) The riser sealing mandrel shall have internal conduits or

covered slots where umbilical hoses can be constrained

and protected from being damaged by the diverter bag.

The riser sealing mandrel shall be long enough to allow

compensated vertical movement (heave) of the rig and the

distance from the unlatch SSTTA to the LMRP / BOP

Connector point..


sub section e) New WOM 7-3/8 flowhead does

not have manual overide of wing valves

Change wing valves to have optional manual

overide

Accepted

Have added should has if the safety strategy states there

shall be override then it will be required.

New Text.

e) Annulus bore and main bore isolation valves shall have a

secondary means of operation/override if defined in the

safety strategy. Fail-safe-close valve type actuators (e.g.,

with spring force to close) should have override to open.

Fail-in-position valve actuators should have override to

close or open.


sub section a & b) On in-riser C/WO, FHD

conencts to CWJ or RSM whiel reference is to

slick joint

Add CWJ and RSM to reference

Accepted

new text for purpose "The purpose of the surface tree

adapter joint is to provide an interface between the

surface tree and the slick joint, cased wear joint or riser

sealing mandrel. Alternatively, the surface tree adapter

joint may be integral with the slick joint."

new text for "b) The bottom connection shall match the

interface with the slick joint, cased wear joint, riser sealing

mandrel or with a connection to mate with the riser."


subsection j) pressure monitoring at FHD is

possible but not required

no change required since statement is "should"

Rejected

j has been removed as it is a should rather than a shall and

will not pass the API colour code.


General FHD comments:

1) bending stresses of upper and lower subs

should be considered in GRA

2) swivel as described in section 5.3.2 may be

installed above master valve

no change required since statement is "should"

Rejected

not clear enough proposal.

Clause 5 5.31 Technicalh) rotation does not need to be accomodated if

there is a provided below.

change shall to shouldRejected

comment not clear. Rotation shall allow relative rotation


l) recommendation for an ingersoll rand product

should not be part of this specification. In

addition the device would need to have a speed

greater than the rig prevent injuries as personell

approached the rig floor.

change recomendation description and add

speed consideration.

Accepted

remove. K) defines winch, and agree should not list one

company supply product.

Clause 5 5 Editorial

multiple areas of the text do not reference the

correct table. For example, in section 5.2, 4th

paragraph states table 5-5 which should be table

5-1.

Accepted

Clause 5 Figure 5-1 Generalgraphics of drift bar dimensions are blurry

Acceptedbetter graphics required. Refer to word document for

clearner picture

Clause 5 5.3.g Technical

all seals shall be independently qualified… all seals shall be qualified…

more plyable for all supplier to prove their

component design meet the

environment/design specifications.

Accepted

Remove "independently"

Clause 5 5.8.j Technical

chemical injection line/port shall be located

between the valves.

shall include a chemical injection line/port with

duel sealing/backflow valve arrangement. Ideal

location is always below a well barrier. Rejected

This would be a downhole line. Ideal location is between

well barrier elements otherwise no way to stop hydrates in

this location or to see if lower barrier elemant is sealing.

Clause 5 5.8 Editorial check lettering bullets - not fluent Accepted format is not correct see mark up in document

Clause 5

5.8.a the

second "a"

bullet

Technical

shall be above the upper SSTT valve. Spell out

which valve - top well isolation valve or the

landing string/riser containment valve.

shall be above the upper well isolation valve…

Rejected

Is actually 5.8, K.1.

It states uppr valve and it is part off SSTT, therefore clear it

is the upper most valve in the SSTT.Note it is not SSTTA,

stated here.

Clause 5

5.8.c the

second "c"

bullet

Technical

shall have an active pressurized latch function to

be engaged…

change "pressurized" to "positive". Currenty it

implies only hydraulic style latches are possible.

Accepted

Is actually 5.8, K.3.

new Text "3. shall have an active positive latch function to

be engaged during the entire operation. The connection

shall be designed to allow for tagging on a subsea drilling

BOP ram."

Clause 5 5.18 EditorialFigure reference numbers in the text do not

match the picturesRejected

they match

Clause 5 5.3 n Editorial There are no clause 6.5.2.3 or 6.5.3.3 correct for appropriate clause Rejected This is not in 5.3n nor Clause 5.


The following should be none prefixed list items

list items: " - active (rotary) type, requiring the

rotation ……." and " - passive (helix/linear) type,

uses downward …."

Revise as commented.

Accepted

Duplicate of Line 43.

Clause 5 5-1' General

What is the purpose of this table if it's only for

nominal flange size? What about casing,

drillpipe, etc.?

Remove table or create drift table for casing,

drillpipe, etc.Rejected

Table provides general sizes used in open water and in

riser equipment. Main section been has re-writen so sizes

can be taken for casing drill pipe etc using the same

relationships


d) Infers that only a single metal-to-metal seal (a

single seal) will be an adequate barrier between

the bore and the environment

If so, then there's no redundancy in sealing. Is

that ok? Specify that if a metal-to-metal seal is

used in the connection and pressure rated it can

be the stand alone sealing mechanism if the end

user agrees to just a single seal

Rejected

If metal to metal seal is used and is qaulified then single

seal can be used. If using elastomers then two barriers

required.

Clause 5 5.21.1 Editorial e) subsection 6.4.11.5 does not exist Create 6.4.11.5 or fix reference Accepted Reference should be 6.2.7


j) for a metal to metal seal which features

mating surfaces of two machined surfaces,

should this requirement still be required?

Make corrosion resistance sealing surfaces

recommended and not required Rejected

There should br cossion resistance on the parts.

new text "j) All sealing surfaces shall exhibit a means of

corrosion resistance."


a) What about drillpipe? Drillpipe is not

considered OCTG

Include drillpipe as an option for landing strings,

because drillpipe is not OCTG

Accepted

There are various areas were Drillpipe is classidied as a

OCTG, however the word shall has been replaced with

should.

New text.

Standard landing string joints should be based on oil

country tubular goods standard lengths to facilitate

racking. All standard joints should have equal length

Clause 5 5.7 EditorialBullets b) and c) missing from text for bore

selector and for landing string adapter.

Add bullet b and c.Rejected

Bullets are in WD5.2

Clause 5 5.3 and 5.4 Editorial

Would be good if you could manage the page

breaks so that the figure and the text/key are on

the same page.Accepted

Im assuming this is the figure 5-3 & 5-4 as clauses 5.3 & 5.4

do not have figures.

When editing please ensure the the figures and title are on

the same page


second paragraph text refers to Fig 5-5, not 5-4. Change reference of paragraph 2 to Fig 5-5

Accepted

Comment is wrong way round. Text references figure 5.4

but should be 5.5.

This also affect clause 5.18.

Clause 5 Section 5.5 Editorial

"A BOP spacer joint does not normally include

any remote-controlled well control devices; its

use is generally limited to operations on killed

wells." This statement is misleading.

Consider revising to state that "its use is

generally limited to operations on wells that are

isolated from the production zone". Many

tubing hangers are installed in the GOM on "live"

wells using a BOP Spacer Joint along with a

mechanical barrier in the lower completion,

isolating the production zone during installation

of the upper completion.

Accepted

New Text "A BOP spacer joint does not normally include

any remote-controlled well control devices; its use is

generally limited to operations on wells that are isolated

from the production zone."

Clause 5Section

5.18Editorial

bullet d)…missing "be"…"The WCP may be

configured..."

Correct sentence

Accepted

New Text "d) The WCP may be configured as a single unit

or as a sectioned unit (reference Annex A) and may be

equipped with an upper re-entry spool interface with the

EDP or with a connection to mate with the lower end of

the C/WO riser. These upper interface connection(s) shall

have a defined minimum combined structural capacity

equivalent the subsea tree. In addition the pressure

capacity rating shall not be less than the pressure rating of

the subsea tree.;"


Note 4 references figure (d) and e) as single and

sectioned WCP configurations, however the

WCP illustrated are indentical for both

Should Note 4 be revised to state the figure e)

illustrates a EDP/WCP configuration that allows a

disconnect of the riser for suspension

operations, while figure d) does not?Accepted

Accept in princple.

New Text "Figure 5-5 d) and e) illustrate WCP

configurations where at least two barrier elements are left

behind should well intervention operations be suspended

for an extended period."


bullet d) that all surface tree valves shall be

remotely operated and fail-safe close. This

statement should only apply during well test or

flow back operations. Such surface trees are

rarely used when landing a tubing hanger in

wells equipped with vertical trees with no

planned slickline or wireline operations and

wells with a bi-directional barrier isolating the

production zone during upper completion

installation.

Revise this bullet to state that remotely

operated and fail-safe valves shall be during well

intervention, post production or a well test. This

is not a "shall" during initial well construction.

Rejected

There are operations of landing the TH which require this

functionality as the tubing plugs will be pulled. If during

the well construction this is not required then this can be

waved during the safety strategy.

Clause 5

5 Drift

requireme

nts

#3 and #4

Technical

The terms "if possible" allow the designer to

ignore the requirements without justification.

This text would be better to use "where required

by the technical design and justified by approved

documentation a deviation from these drift

requirements may be acceptable." Combine the

next paragraphs #3 and #4.

Accepted

Due to comment plus API colour codes Section 5.2 should

now read;

"Each tubular section of a subsea well intervention system

or component within the system that requires a tool to be

passed through it shall be drift-tested

Drift testing shall be performed at both the system level

and the component level.

At a system level, drift testing shall be conducted with the

system’s minimum bore size.

At the equipment level, it shall be drift tested to the

equipment’s nominal bore diameter.

The purchaser shall specify the drift requirements of the

tubing hanger through-bores.

In cases where an alternative nominal bore size is used, the

same relationship between drift major and minor

diameters and nominal bore size shall be maintained.

Note: Consideration should be given to component

deflections, flow-by area during tool string operations,

changes in center lines, and steps in equipment packages

Clause 5

5.8 Subsea

test tree

Requireme

nts listing

Editorial

Within the letter identified listing, an anomaly

occurred after item k) on page 78. I believe the

intent may be to start a new listing after the

new item a). However, the letter designation

does not indicate that correctly. Additionally,

the next 14 items start with "shall" this term

can therefore be used in the lead-in sentence to

eliminate the redundancy

Re-structure this listing ro add clarity, eliminate

redundancy and to provide a clear purpose.

Rejected

Formating is corerct on WD5.2

Clause 5 5.10.1 Technical1. failure mode of the retainer valve (e.g., fail in

position or fail-safe-close);

1. failure mode of the retainer valve (e.g., fail-as-

is or fail-safe-close);Accepted

Clause 5 5.10.2 (c.) Technical

API Colour code issue with current text.

may be designed to allow closure of the subsea

drilling BOP annular preventer on the external

surface. If this design feature is included, then

the following shall apply

c) If the design allows closure of the subsea

drilling BOP annular preventer on the external

surface, then the following shall applyAccepted

Clause 5 5.10.2 (d) Technical


d) As defined within the safety strategy, the

retainer valve may be required to cut coiled

tubing, braided wireline, and slickline and seal in

accordance with Annex K procedures and as

specified by the end user requirements.

d) If defined within the safety strategy, the


tubing, braided wireline, and slickline and seal. If

cutting is defined, then cutting shall be, in

accordance with Annex K procedures and as

specified by the end user requirements.

Accepted

Clause 5 5.10.3 (a) Technical


a) The retainer valve or EDP shall include

features to vent trapped pressure between the

closed retainer valve and the shut-in WCP to

open sea in the case of an EQD. Any venting

functionality may be ported to the

circulation/kill line(s) to prevent venting into the

open sea.

a) The retainer valve or EDP shall include

features to vent trapped pressure between the

closed retainer valve and the shut-in WCP to

open sea in the case of an EQD.

Note: Any venting functionality may be ported to

the circulation/kill line(s) to prevent venting into

the open sea.

Accepted


c) As defined within the safety strategy, the


tubing, braided wireline, and slickline and seal,

in accordance with Annex L procedures and as

specified by end user requirements.

c) If defined within the safety strategy, the


tubing, braided wireline, and slickline and seal. If

cutting is defined, then cutting shall be, in

accordance with Annex L procedures and as

specified by end user requirements.

Accepted

Clause 5 5.18 (g) Technical

add in new item to list service conditon etc insert as a new item

The following service condition classes and

ratings shall apply for well control devices in the

LWRP:

1. Service specification level (i.e. SSL-Liquid and

SSL-Gas) shall be in accordance with Annex L.2.1.

2. Pressure rating shall be in accordance with

Annex L.2.2.1.

3. Temperature rating shall be in accordance

with Annex L.2.2.2.

4. Material class rating shall be in accordance

with Annex L.2.2.4.

5. Safety class (i.e. safety function class and

normal operation class) shall be in accordance

with Annex L.2.2.5.

6. Service class (i.e. sand class I, sand class 2 and

sand class II) shall be in accordance with Annex

L.2.2.6.

7. Shear class i.e. wireline/coiled tubing class and

safety head class ) shall be in accordance with

Annex L.2.2.7.

Accepted

Clause 5 5.18h Technical

add "be operated by " h) Other interfaces may be operated by a diver

or remotely operated vehicle (ROV) control

function interfaces. The ROV interface shall

comply with API 17H;

Accepted

Clause 5 5.18l Technical

Remove "Bores in the LWRP should be the same

or larger then the bore of the subsea tree". API

Colour issue & not really required

Necessary transitions shall be provided in mating

riser components to accommodate changes in

bore sizes or bore spacing to the tree bore

spacing specified in API 17D, to allow passage of

drifts or through-tubing tools for vertical access

into these bores whenever applicable;

Accepted

Clause 5 5.18m Technical

m) Consideration shall be given to the possibility

of overhead clearance problems when stacking

or handling the LWRP and subsea tree together

in the cellar deck. Stack-up height will affect

riser design relative to moment loading at the

subsea tree and LWRP interfaces. Allowable

stack-up height shall therefore be agreed in

each case.

API Colour issue & not really required

m) Consideration shall be given to the possibility

of overhead clearance problems when stacking

or handling the LWRP and subsea tree together

in the cellar deck. Allowable stack-up height shall

therefore be agreed in each case.

Note: Stack-up height will affect riser design

relative to moment loading at the subsea tree

and LWRP interfaces

Accepted

Clause 5 5.20. TechnicalAdd a note in front of "A WCP may typically

include the following components". API colour

code issue

Note: A WCP may typically include the following

components: Accepted

Clause 5 5.20. Technical

Delete "The number of sealing rams or shearing

valves used in the shear/seal device may vary

depending on the design

of the closure device and the purchaser’s

requirements. The WCP shall include, as a

minimum, the following

valves:

a) an upper bidirectional isolation valve in every

through-bore;

b) a shearing device in any bore that will have

coiled tubing or wireline equipment (or any

other tool/device) in the bore."

new text: "The number and type of well control

devices, safety class of well control devices, and

shear class of well control devices shall be

configured to achieve a safe-state condition for

each applicable safety function as specified in

the safety requirements specification, see

section 4.13 and Annex M.1.2.16. As a

minimum, the vertical through access bores in

the WCP shall include the following well control

devices:

1) an upper bidirectional isolation valve in every

through access bore;

2) a shear/seal device in any bore that will have

coiled tubing or wireline equipment (or any

other tool/device) in the bore.

The shear class, safety head class for well

control devices, shall be selected when there is a

risk for accumulation of multiple work strings in

the vertical through access bores(s) of the WCP

and/or when anything more than a wireline or

coiled tubing shall be run through the WCP.

Selection of shear class shall be included in the

safety requirements specification"

Accepted


The is para should be moved further down in

the clause “The WCP shall provide all mechanical

support and be able to withstand the combined

effects of both riser tension and bending, as well

as internal and external pressure.”

move to the end of the section

Accepted


Bullet points G, H & M require to be moved to

the end of the section as notes rather than

bullet points.

Note 1: Connectors and/or associated running

tool(s) should provide positioning and alignment

of mating components such that connection can

be accomplished without damage to sealing

surfaces or structural connection devices;

Note 2: If an environmental seal is used,

consideration to pressurizing control lines by

possible communication with the production or

annulus bore should be given;

Note 3: Effects of pressure end loads acting over

the area enclosed by the environmental seal

should also be considered in the design because

one or more of the interior seals could leak;

Accepted

Clause 5 5.21.1 (q) Technical

API colour issue, remove "Dimensional control

may be performed with go/no-go gauges in

place of regular interchangeability tests, if

applicable."

machining tolerances and clearances shall be set

such that all connectors of the same design and

configuration are interchangeable. Production

dimensional control shall be performed to

ensure interchangeability.

Accepted

Clause 5 5.21.2 (i) Technicalmissing text "and shall be" An external position indicator shall be provided

and shall be suitable for observation by

ROV/diver

Accepted

Clause 5 5.21.3 (k) Technical Delete as covered in Section 5.3 Delete J Accepted

Clause 5 5.21.3 (m) Technical

API Colour code issue. "A back-seal test, i.e., a

low-pressure test to check correct installation of

seal, can achieve this" should be a note not in

main text

The connector may provide a means for pressure

testing of the connection after makeup without

pressurizing the C/WO riser.

Note: A back-seal test, i.e., a low-pressure test to

check correct installation of seal, can achieve

this.

Accepted

Clause 5 5.21.4 (€) Technical

API Colour Issue & following statement causing

confiusion.

"For example, this requirement may be achieved

with the use of an inlay or surface coating. "

All sealing surfaces shall exhibit a means of

corrosion resistance. Accepted


API Colour Issue & following statement causing

confiusion.

"A suitable flange, a hub, or a proprietary riser

connector may be used. "

c) The lower end of the stress joint shall be

suitable for connecting to either the EDP

connector or the TRT. Accepted

Clause 5 5.21.4 (g) Technical Delete as covered in Section 5.3 Delete J Accepted

Clause 5 5.26 (a) Technical

Split (a) into to sections and create a new (b)

and also remove "The cased wear joint, if

installed, shall "

A & B should be as per below.

a) Shall provide a protective sleeve that extends

through the rotary table. Unless otherwise

agreed upon, the sleeve shall be removable to

enable inspection and maintenance of interior

pipes.

b) The sleeve length shall be sufficient to pass

through the rotary table, diverter, and ball/flex

joint, including extra length to allow for vessel

motion relative to the riser string.

Accepted

Clause 5 5.26 (b) Technical

Remove "The bending stiffness introduced by

the sleeves should be reduced to reduce the

bending moments introduced in the connecting

riser joints. Continuous or segmented sleeves

may be applied." due to API colour issue and

moved to end of section as a note.

Note:The bending stiffness introduced by the

sleeves should be reduced to reduce the bending

moments introduced in the connecting riser

joints. Continuous or segmented sleeves may be

applied.

Accepted

Clause 5 5.26 (c.) Technical

Remove "The top end of the cased wear joint is

connected to the surface tree adapter joint. The

bottom end of the cased wear joint may be

connected to the tension joint or a spacer joint

(pup joint)."

C wording now "c) The cased wear joint shall,

unless otherwise specified, be equipped with

standard riser connectors. " Accepted

Clause 5 5.26 (d) Technical

Below wording requires re-wording due to API

colour comments.

A control umbilical may run in parallel with the

cased wear joint. In such cases, it shall either run

inside the outer sleeve or be properly supported

on the outside in a suitable groove or recess in

the sleeve to prevent damage to the umbilical as

it passes through the rotary table, diverter, and

ball/flex joint.

new wording "e) if a control umbilical is used

with the cased wear joint, it shall either be run

inside the outer sleeve or be properly supported

on the outside in a suitable groove or recess in

the sleeve to prevent damage to the umbilical as

it passes through the rotary table, diverter, and

ball/flex joint."

Accepted

Clause 5 5.28 (c.) Technicalc) The adapter joint shall be made made as short

as possible

c) The adapter joint shall be designed with the

shortest possible lengthAccepted

Clause 5 5.29 (b) (c.) Technical

b) The surface tree shall be a vertical through-

bore design. The vertical bore(s) shall permit the

clear passage of wireline/coiled tubing tool

strings. the number of bores should be

compatible with the landing string or C/WO riser

design and operation.

(c.) should be removed and incorporated into b

New Text.

b) The surface tree shall be a vertical through-

bore design. The vertical bore(s) shall permit the


strings.

Delete c) The vertical bore(s) shall permit the


strings

Accepted


remove current (d) wording and replace due to

Tony's comments to tie in with Annex L

new text

"The number of well control devices and safety

class of well control devices shall be configured

to achieve a safe-state condition for each

applicable safety function as specified in the

safety requirements specification, see section

4.13 and Annex M.1.2.16. As a minimum, the

surface tree well control device arrangement

shall consist of:

1) One valve in each vertical bore.

2) One wing valve for each vertical bore unless

specified otherwise by the end user.

3) All valves shall be remotely operated.

4) Wing valves shall be remotely operated, fail-

safe-close with bidirectional sealing.

5) Master and/or swab valves shall be remotely

operated, fail-in-position with bidirectional

sealing; "

Accepted

Clause 5 5.29 (i) Technical

"Wing and kill outlets should be arranged 90°

down" to be moved as a note in the text, due to

API coloour code

i) Outlets shall have provisions for attachment of

flexible pipes or swivel connections. Bending,

tension, and shear loads induced by the flexible

jumpers, combined with internal pressure, shall

be considered in the design of the outlets.

Note: Wing and kill outlets should be arranged

90° down.

Accepted

Clause 5 5.29 (k) Technical

"The wireline/coiled tubing adapter may be

separate or an integral part of the tree" to be

moved as a note in the text, due to API coloour

code

k) The top of the surface tree shall support the

wireline/coiled tubing adapter.

Note: The wireline/coiled tubing adapter may be

separate or an integral part of the tree.

Accepted


API Colour issues. Bullet point a) needs to go

into the introduction. Bullet b) needs to habve

"for colied tubing operations, a flange or

specifiatly connector is preferred.

New Text:

The purpose of wireline or coiled tubing

adapters is to allow the connection of

wireline/coiled tubing BOPs and lubricators to

the surface tree or directly to the riser. The

adapter may be integral or non-integral with the

surface tree or riser.

The following requirements apply to

wireline/coiled tubing adapters:

a) The connection shall be qualified for all

relevant make/break loads, pressures,

temperatures, and external loads.

b) The adapter shall be provided with a profile to

interface with a standard casing elevator. The

outer diameter and load shoulder in such cases

shall be consistent with standard casing collars

of similar size. The adapter shall be capable of

maintaining the pressure integrity/seal between

the wireline/coiled tubing BOP and the adapter

in operational conditions.

Accepted

Clause 5 5.31 (f) Technical

API Colour code issue. "Provisions should be

made for handling and make/break of the

bottomhole assembly in the frame. " should be a

note not in main text

f) The tension frame shall have sufficient height

to allow installation of the wireline/coiled tubing

components.

Note: Provisions should be made for handling

and make/break of the bottomhole assembly in

the frame.

Accepted

Clause 5 5.31 (h) Technical

API Colour code issue. "90° rotation about the

vertical axis should be accommodated. " should

be a note not in main text

h) The design of the tension frame shall allow

relative rotation between the frame and surface

tree. Typically

Note: , 90° rotation about the vertical axis

should be accommodated.

Accepted

Clause 5 5.31 (m) TechnicalAPI Colour code issue. "Provisions shall be made

for anchoring personnel safety harnesses

suitable areas. "

new text "Anchoring of personnel safety

harnesses shall be placed at suitable areas.) Accepted


This should be the introduction to the swivel not

a bullet point.

First paragragh: "A pressure-containing swivel

may be included in the landing string or C/WO

riser to allow relative rotations between the riser

and the workover vessel. The main purpose of

the swivel shall be to maintain the same surface

tree and surface tree tension frame orientation

relative to the drill floor. Relative rotations

normally occur during landing of the tubing

hanger and due to heading variations on

dynamically positioned vessels.

The following requirements apply to the swivel:"

Re-number the bullet points

Accepted

Clause 5 5.32 (e) Technical

e) All seal surfaces that may be exposed to

hydrocarbons shall be of corrosion resistant

alloy (that is, inlay welded).

This has an API Colour issue

Reword to the following

"All sealing surfaces exposed to hydrocarbons

shall exhibit a means of corrosion resistance. "Accepted


Remove "A flexible circulation line(s) may be

used to provide annulus fluid access." from (a)

due to API colour issue and as a note at the

bottom of the section

as per comment

Accepted

Clause 5 5.33 (b) TechnicalRemove due to API colour issue and is covered

in the note section already at the bottom of the

section

removeAccepted

Clause 5 5.33 (c.) TechnicalRemove due to API colour issue and is covered

in the note section already at the bottom of the

section

removeAccepted

Clause 5 5.33 (note) TechnicalRemove "flexable" and replace with "Auxillary" new text "Auxillary circulation line(s) may be

used for"Accepted

Clause 5 5.34 (e.) Technical

Current wording had an API colour code issue

"e) During operation, all work on the spider

should be possible by personnel while they are

standing on the drill floor.

new text "e) During operation, all work on the

spider shall be possible by personnel while they

are standing on the drill floor, unless otherwise

agreed by the relevant parties. "

Accepted


Missing shall in "d) The length of the handling

tool shall be minimized, but have sufficient

length to allow makeup and break-out of the

drillpipe or casing elevator and adequate space

for makeup of any control or test lines"

d) The length of the handling tool shall be

minimized, but shall have sufficient length to

allow makeup and break-out of the drillpipe or

casing elevator and adequate space for makeup

of any control or test lines

Accepted

Clause 5 5.36 (a) TechnicalThe word "umbilical" should have been removed

as per previous comments.

as per commentAccepted

Clause 5 5.36 (b) TechnicalThe word "umbilical" should have been removed

as per previous comments.

as per commentAccepted

Clause 5 5.3a Technical

Confusion over existing wording and also

conflict with API Colour code.

a) The design of the subsea well intervention

system shall include inputs for functional and

technical requirements to include (but not

limited to) the following:

1) internal and external cleaning and

preservation of the system;

2) identification of system components;

3) identification of components or areas of the

system where enclosed fluid volumes require

evacuation prior to disassembly;

4) consumables;

5) seals and gaskets, which are intended to be

made up on the vessel

Accepted

Clause 5 5.3b TechnicalConfusion over existing wording and also

conflict with API Colour code.

Inculded in comments in 5.3aAccepted

Clause 5 5.3d Technical

Conflict with the below text during the API

Colour code review. The below text to be moved

as a note such that you still have the

information.

Resilient, elastomeric, or metal-to-metal seals

may be used as primary seals to contain

hydrocarbons, well control, completion, and kill

fluids on riser system assembly interfaces and

riser connectors

Where metal-to-metal seals are not used as a

barrier to the environment, redundant seals

(primary plus backup) shall be provided.

Note: Resilient, elastomeric, or metal-to-metal

seals may be used as primary seals to contain

hydrocarbons, well control, completion, and kill

fluids on riser system assembly interfaces and

riser connectors

Accepted

Clause 5 5.3e Technical


Colour code review, eg part to be moved as a

note such the information .

Connection pressure separation loads shall be

based on worst-case sealing conditions.

Note: (e.g., leakage to largest diameter

redundant seal shall be assumed unless relief is

provided).

Accepted

Clause 5 5.3o Technical


Colour code review. The below text to be moved

as a note such that you still have the

information.

A general guideline on bolted flange joint

assembly is presented in ASME PCC 1-2000 [37]

Bolted flange connections shall be assembled

and made up in accordance with a written

procedure that has been qualified by test to

achieve the specified bolt pretension.

Note: A general guideline on bolted flange joint

assembly is presented in ASME PCC 1-2000 [37].

Accepted

Clause 5 5.5p Technical

The three bullet points under p) should be

separate bullet points as per supplied WD 5

comments 10-08-13.

q) Maximum anticipated rotation required for

tubing hanger orientation and the torsional

resistance of the downhole completion and

landing string shall form the basis for

determining requirements for torque capacity.;

r) Torsional resistance shall account for static

and dynamic effects (i.e., orientation at

maximum landing speed).;

s) For non-oriented tubing hangers, anti-rotation

features might not be required.

Accepted

Clause 5 5.7i Technical

Make sure that component structural capacities

shall be established and documented in

accordance with API 17G to allow the

performance of an overall system design

analysis

Component structural capacities shall be

established and documented in accordance with

API 17G to allow the performance of an overall

system design analysis

Accepted

Clause 5 5.7p (3) Technical

3. the subsea test tree (SSTTA) manufacturer

shall have a contingency procedure/method that

will operate the valves and connectors of the

subsea sea test tree in the correct sequence to

isolate the well.

3. SSTTA manufacturer shall have a contingency

procedure/method that will operate the valves

and connectors of the subsea test tree in the

correct sequence to isolate the well. Accepted

Clause 5 5.8i Technical

API Colour code issue with current text g) provision shall be made to avoid damage to

electric equipment connected above and below

the point of shearing due to cutting of the

electric line.

Accepted

Clause 5 5.8k (9) Technical

API Colour code issue, therefore need to add

some text as notes.

9. shall include sufficient clearance from the

subsea drilling BOP shear rams to allow milling

and fishing. An internal fish-neck may be

provided as backup for running an overshoot

tool.

9. shall include sufficient clearance from the

subsea drilling BOP shear rams to allow milling

and fishing.

Note: An internal fish-neck may be provided as

backup for running an overshoot tool. Accepted

Clause 5 5.8m (4) Technical

4. shall include sufficient clearance for closure of

subsea drilling BOP rams to account for stack-up

tolerances in the subsea drilling BOP stack and

SSTTA .

4. shall include sufficient clearance for closure of

subsea drilling BOP rams.

Note: Stack-up tolerances in the subsea drilling

BOP stack and SSTTA to be accounted for.Accepted

Clause 5 5.9(e, f & g) Technical

bullets e, f & g were supposed to be under 1

bullet. API Colour code issue therefore

reworded. Coomets were also provided under

WD 5 comments 10-08-13.

e) Qualification shear trails are the responsibility

of the end user and shall follow one of the

following:

1) BOP Shear trial of shear sub. The shear trial

qualification specimens shall include

external/internal hydraulic lines, slick line,

braided wire and coiled tubing (single or

multiple) as specified by the end user.

Shear sub orifice size shall be documented after

BOP shear test to determine if the remaining

orifice size will have sufficient flow area for

bullheading after post milling/dressing. Refer to

Annex J for additional information on the cutting

trials.

2) Physical cutting trials maybe waved by the

end user, if data from previous shear trials using

the same shear sub material properties,

hydraulic line types and identical BOP ram type

were used.

3) Calculations from the BOP manufacturer (or a

qualified independent 3rd party engineering

representative) verifying that the BOP can shear

the shear sub can accepted by the end user if

physical data to calculation results are

representative.

Accepted


Remove "is an optional valve that " A lubricator valve is typically located near the

top of either an open-water intervention mode

C/WO riser or thru-BOP/drilling riser

intervention mode landing string. The purpose of

a lubricator valve is to seal off the bore in the

landing string or the C/WO riser to allow

lubrication of long wireline or coil tubing tool

strings without having to close the SSTT/WCP

and depressurize the entire landing string or

C/WO riser. A lubricator valve may also be used

to assist with the circulation of fluids and

isolation and pressure testing of the

landing/riser string.

Accepted



The ported annular slick is typically located

between the lubricator valve and retainer joint

on the SSTTA. Its purpose is to allow for isolation

of the subsea drilling BOP from the marine

drilling riser by closure of a subsea drilling BOP

annular preventer. The ported slick joint shall:

The purpose is to allow for isolation of the

subsea drilling BOP from the marine drilling riser

by closure of a subsea drilling BOP annular

preventer. The ported slick joint shall:Accepted


Original comments below were agreed to be

changed in Technical commitee meeting.

The tubing hanger running tool adapter provides

the interface between the tubing hanger

running tool and the ported slick joint, either on

the SSTTA or the BOP spacer joint.

Requirements for the tubing hanger running

tool adapter shall be as follows:

a) include a lower interface compatible with the

tubing hanger running tool or with an interface

as specified by the end user;

b) include a upper interface compatible with the

SSTTA and/or the BOP spacer joint;

c) structural capacities of the upper interface of

the adapter shall be established and

documented in accordance with API 17G. The

structural capacities of the lower interface shall

be defined by the tubing hanger running tool

provider to API 17D criteria.

NOTE The tubing hanger-running tool is

included within the scope of API 17D.

The tubing hanger running tool adapter provides

the interface between the tubing hanger running

tool and the SSTTA or the BOP spacer joint.

Requirements for the tubing hanger running tool

adapter shall be as follows:

a) include a lower interface compatible with the

tubing hanger running tool which is provided by

the tubing hanger running tool provider or with

an interface as specified by the end user;

b) include a upper interface compatible with the

SSTTA and/or the BOP spacer joint;

c) structural capacities of the upper interface of

the adapter shall be established and

documented in accordance with API 17G. The

structural capacities of the lower interface shall

be defined by the tubing hanger running tool

provider to API 17D criteria.

d) it shall be designed for effects of internal and

external differential pressure in combination

with the applicable external lading conditions in

accordance with this document.

e) tubing hanger running tool provider shall state

if any component in the tubing hanger running

tool limits the internal or external pressure

rating of the tubing hanger running tool adaptor

due to design or functionality.

Accepted


Remove "A bore selector may be used in thru-

BOP/drilling riser intervention mode and open-

water intervention mode" and move to end of

section as a note due to API colour code

comments

Note: A bore selector may be used in thru-

BOP/drilling riser intervention mode and open-

water intervention mode Accepted


remove "during well testing." from first

sentence

The purpose of an adjustable fluted hanger is to

allow for temporary hang-off of well completion

equipment and allow space out of the SSTTA

inside a subsea drilling BOP. Accepted


Remove "A flange…." From the below

statement, due to API colour issue.

The upper end of the EDP shall have a

connection to mate with the lower end of the

riser. A flange, hub, or a proprietary riser

connector may be used.

The upper end of the EDP shall have a

connection to mate with the lower end of the

riser. A flange, hub, or a proprietary riser

connector may be used. Accepted


Remove the folllowing sentance as not appliable

to the functionality of a landing joint and API

Colour issue.

"A control umbilical(s) may be used to provide

hydraulic supply and electrical signal/power to

the SSTTA and tubing hanger running tool

functions. Suitable umbilical clamps shall be

installed to attach the umbilical(s) to the landing

string joint at specified intervals. "

delete "A control umbilical(s) may be used to

provide hydraulic supply and electrical

signal/power to the SSTTA and tubing hanger

running tool functions. Suitable umbilical clamps

shall be installed to attach the umbilical(s) to the

landing string joint at specified intervals. "Accepted


add from Tonys mark ups and to tie in with

Annex L.

"The following service condition classes and

ratings shall apply for well control devices in the

surface tree:

1) Service specification level (i.e. SSL-Liquid and

SSL-Gas) shall be in accordance with Annex L.2.1.

2) Pressure rating shall be in accordance with

Annex L.2.2.1.

3) Temperature rating shall be in accordance

with Annex L.2.2.2.

4) Material class rating shall be in accordance

with Annex L.2.2.4.

5) Safety class (i.e. safety function class and

normal operation class) shall be in accordance

with Annex L.2.2.5.

6) Service class (i.e. sand class I, sand class 2 and

sand class II) shall be in accordance with Annex

L.2.2.6."

as per comment

Accepted


Below statement was agreed, but removed from

WD 5.2. This should be added back in.

All equipment that can be subject to net

external pressure (i.e., from hydrostatic head)

shall be designed to withstand hydrostatic

collapse

Add. All equipment that can be subject to net

external pressure (i.e., from hydrostatic head)

shall be designed to withstand hydrostatic

collapseAccepted


API Colour issues, thefore slight reword to below

text required.

"2. provision of sufficient clamping force to

support the weight of the filled umbilical(s)

between clamps. The the required clamping

force shall account for weight of the filled

umbilical(s) between clamps, umbilical outside

diameter tolerances, operational friction

coefficient of the umbilical outer sheath, outside

diameter contraction due to clamping force and

external hydrostatic pressure; "

new text "2. the required clamping force shall

account for weight of the filled umbilical(s)

between clamps, umbilical outside diameter

tolerances, operational friction coefficient of the

umbilical outer sheath, outside diameter

contraction due to clamping force and external

hydrostatic pressure;" Accepted



some text as notes & also bullet point 2 was not

editied as per supplied WD 5 comments 10-08-

13

"Note: Selection of the orientation system is

dependent on the type and design of the tubing

hanger. Typically, there are two types of

orientation systems:"

"2. passive (helix-type/linear) type: uses

downward or upward motion of the running

string to engage a pin or key in an orientation

device that automatically orients the tubing

hanger relative to the wellhead/tubing

head/horizontal tree."

"Note: Typical orientation devices are:"

Accepted

Clause 5.5 Technical

Below text to be moved to end of section and

added as a note.

Depending on the type of well and type of

subsea tree, the BOP spacer joint may include

the following components,; see Figure 5-2:

a) tubing hanger orientation joint or device;

b) intermediate (annular) slick joint;

c) upper (annular) slick joint;

d) pressure containing pipe-in-pipe spacer sub

to convey two or more tubing bores, hydraulic,

chemical or electrical lines.

Note: Depending on the type of well and type of

subsea tree, the BOP spacer joint may include

the following components,; see Figure 5-2:

a) tubing hanger orientation joint or device;

b) intermediate (annular) slick joint;

c) upper (annular) slick joint;

d) pressure containing pipe-in-pipe spacer sub to

convey two or more tubing bores, hydraulic,

chemical or electrical lines.

Accepted

Clause 5.7 Technical


some text as notes

Note: Depending on the type of well and type of

subsea tree, the SSTTA may include the following

components (see Figure 5-3 and Figure 5-4):Accepted


The SSTT shall consists of a minimum of two

valves and a latch and can include additional

means of cutting coiled tubing or wireline.

The SSTT shall consist of a minimum of two

valves and a latch and can include additional

means of cutting coiled tubing or wireline.Accepted


Equations, symbols and subscripts have been

changed from ISO 13628-7:2005, this means

that all code check sofware will have to be re-

written. This will results in uncesssary costs with

out any added value

All equation, symbols and subscripts should be

revised back to ISO 13628-7:2005.Accepted

ref ISO 13628-07 : 6.5.2.2 (Equation 10: ) Min Pipe Burst

capacity , closed end

Clause 6 6.5.4.5

NOTE 1

NOTE 2

error regarding D/t below 25

Change "D/t ratios below 25" to "D/t ratios

above 25"Accepted

Clause 6 6.7.3.9.3

Table 25. Normative requirement to life time

(endurance) is not pratical as life time relaibility

modesl are not well estblished and API 17 N

Annex D is an over simplification

Recommned that informative guidance is given

to monitor valve/ram cycles in operation. For

temporary applications life time will depend on

inspected condition.

Accepted

Ref API 17N -- Does this apply to Life time endurance ?

"However other confidence levels maybe established by

the End User "?

Clause 6 6.8.8 e) Editorial

It is considered that requirement shall not be

normative but a recommedation

Change to "e) Swivel joint should have a manual

locking device to prevent rotation during

handling."

Accepted

No Action - already in text.


This clause needs to be re-written, The

formulation of technical provisions are not

adequate for an industry standard. The allowed

utilisation of 0.72 is not code calibrated and is a

safety issue.

API Editorial committe to appoint a responsbile

party to re write this clause.

Accepted

Alternatively, the manufacturer can conduct extra quality

checks to confirm structural integrity and reduce the

FAT….. (Delete / edit paragraph)

Change to:

1. FAT test pressure cannot be altered or changed per code

(0.9 Sy) shall be used.

2. Supplier cannot conduct extra quality checks to reduce

FAT test pressure integrity checks for equipment.

Clause 6 6.8.9 c Technical

NDE inspection for surface and subsurface

defects in all four quadrants for the entire

tubular cross section

per API 6A PSL3 requirements.

API 6A PSL 3 allows cracks for MPI, if this is

acceptable for a shear sub, this comment can be

removed.

API 6A PSL 3 NDT requirement is not ref Clause

7.

Rejected

No surface cracks are allowed.

Clause 6

Table 6-X

Clause

6.8.11

Technical

Use of tubing and casing is not defined for open

water intervention mode.

This option may be applicable for future

development of typically upset pipes with

integral connectors.

Add a column for open water intervention

modes, all section for material, design, testing

etc shall comply to API 17G Rejected

Clause 6

Table 6-X

Clause

6.8.11

Technical

Connection material

Specification

API 5 DP defines material requirements for tool

joints used in a friction welded configuration.

API 7-1 defines material requirements for none

friction welded components, such as pup joints

and saver subs etc.

Add additional reference to API 5DP for column

referring to API 7-1

Accepted

WG to review and propose change

Clause 6Table 6-X

Clause Editorial

Change "ISO 13679" to "API 5C5" all casesAccepted


Clause 6

Table 6-X

Clause

6.8.11

Technical

All columns shall include internal pressure

design factor and combined internal pressure

and effective tension design factor. Also stated

design factors for normal, extreme and

accidental based on elastci analysis in

accordance with API 5C5 for casing and API 7G

for drill pipe.

Incude a internal pressure design factor and

combined internal presseur and effetcive

tension of 0.6 for capped ends, at design

temepature, including corrosion allowance. For

API 7G and API 5C5 design factor shall be based

on elastic von Mises stress criteria.

Accepted


Clause 6

Table 6-X

Clause

6.8.11

Technical

Pipe material specification

General reference to API 5D

API 5DP replaces API 5D

Change reference to API 5DP

Accepted


Clause 6

Table 6-X

Clause

6.8.11

Technical

Welding requirements

API 7G, (API RP 7G?)

Welding requirements are given by API 5DP

Add reference to API 5DP instead of API RP 7G

Accepted


Clause 6

Table 6-X

Clause

6.8.11

Technical

Welding requirements pipe open sea well

intervention

Clause 7

Clause 7 does not address friction welding.

Clause 7 does not address friction welding.

Propose to add section in clause 7 that gives

modifications to friction welding as given in API

5DP. As an option, this section may include

requirements for forge welding /die welding

such that future development is not restricted.

Accepted


Clause 6

Table 6-X

Clause

6.8.11

Technical

Pipe material specification

Clause 7 gives requirements for upset pipe that

might not be feasible to get a drill pipe

manufacture to implement into their production

line

Might be that the strictly process definition,

implementation and process control being used

by typically Drill Pipe supliers for line production

(as per API standards) is sufficient or even

exceeds requirements for such production,

thinking specially of NDE requirements as part of

production line

Propose that this is addressed in clause 7, a GAP

analysis should be performed and typical Drill

Pipe suppliers should be given the option to give

input and comments.

Accepted


Clause 6

Table 6-X

Clause

6.8.11

Technical

Connection material

Specification

Clause 7 does not cover tool joint and pup joint

manufacturing as performed today.

Tool joints are forged to shape, however it may

not be feasible to perform 100% manual UT

after forge due to forge geometry. The way tool

joints are produced may give confident that

internal defects are not presented after final

forging , the rolled bar that are being used to

forge connectors has been UT checked prior to

sawing to specified length.. A spot UT check of 5

to 10 % of all forgings may cover such

requirement.

Pup Joints and saver subs are machined from

rolled bars, manufacture of such bars performs

NDE according to API 7-1 , which does not

comply with requirements given in clause 7.

Propose to address this in clause 7, a gap

analysis should be performed to API 5DP and

typical drill pipe suppliers should be given the

option to give input and comment.

If section 7.6.2 is intended to cover the

requirements for drill pipe accessories produced

from rolled bars, it should be specified.

Accepted



Clause 6.8.10 needs to be re-written, such that it

clearly defined which barrirer shall be protected,

these barrirers shall be defined in the safety

strategy. Clearly define the weak link philosophy

and acceptance criteria

FMC will write a new proposal for clause 6.8.10

for review by the API editoral committe. This

proposal will be submitted by 30th September

2013.Accepted



Clarify which well barrier (envelopes) to protect.

Please note that it may be severe pressure

energy in the riser itself (primary barrier

envelope)

The responsible party shall ensure sufficient

protection of primary and/or secondary barrier

envelope for excessive loads.Accepted


Clause 6 6.8.10 EditorialBe presice on the wording 'release' - complete

separated or stroked out (telescope)?

Typically, such device may release the vessel

(change from will) AcceptedWG to review and propose change

Clause 6 6.8.10 TechnicalThe device may also include activation joints to

initiate ESD / EQD

Add a bullet point; d) Tension and/or bending

activated deviceAccepted



Please note that pressure balanced safetyjoint

may be beneficial for the system. The

safetyfactor Fd is normally used on effective

tension, bending and internal pressure (burst

and end-cap). A pressure balanced design may

remove the safetyfactor for end-cap. A note

should be added.

Note: Pressure balanced design will change the

usage of design case factor Fd (safety factor) on

internal end-cap pressure. This factor will only

be added on effective tension, bending and

burst. Sufficent robustness shall therefore be

evaluated and included for in the design.

Accepted


Clause 6 6.8.10 EditorialNote 3' is a typo and should be changed to 'Note

4', page 159

Note 4Accepted


Clause 6 6.8.10 Editorial

The confidence intervall may be missused /

missunderstood, please add a figure which

explains allowable operating loads and how to

use the intended standard deviation i.e. 95%

intervall.

Include a figure to explain how to use.

Accepted


Clause 6Section

6.2.3Technical

Would like to add a bit more clarification to the

last paragraph regarding the motivation/uses of

the global load analysis

Add the following text to the last paragraph

ending with "and interference checks.":

"The purpose of the global load analysis is to

define expected component loads during service

for defined metocean conditions and operations.

Comparing expected component loads to

component capacities allows for setting

operational limits, including metocean

conditions, for various planned operations of the

riser.

Accepted


Clause 6Section

6.2.3Technical

The three Notes at the end of this section are

not necessary.

Remove Note 1, Note 2, and Note 3 at the end of

Section 6.2.3.Accepted


Clause 6

Section

6.2.4

through

Section

6.10.9 (and

related

Annexes)

Technical

In our opinion, these sections (and annexes) are

way too long and overly prescriptive. This is

very good information but better suited for a

textbook.

All of Sections 6.2.4 through 6.10.9 (and all

related Annexes) should be replaced with

Section 4, 5, and 6 (and related Annexes) of API

Standard 2RD (2nd edition, September 2013).

Accepted

The following are meant to provide some further

explanation of our concerns that led to these

comments/suggestions. Note that these are listed in no

particular order.

- Completion/intervention risers and top-tensioned risers

are similar systems and basically just "pipe". However, the

API documents addressing the design/analysis of these

systems (Working Draft 5 of 17G and 2RD) are quite

different. The recently issued revision of 2RD includes a

total of less than 80 pages (including Annexes), while for

comparison, this draft of 17G includes more than 660

pages. It would be advantageous for this document to

better align with the "less is more" philosophy used in the

recent 2RD re-write.

- There are a number of topics within this document that

are already addressed with other existing API documents

(e.g., Spec 2RD, RP 16Q). It would be advantageous for

17G to merely reference these existing for appropriate

topics. Doing so would reduce the chance for confusion by

the user (where differences/inconsistencies may exist), as

well as remove the need to update multiple documents

when changes are needed.

- Due to their prescriptive nature, the methodologies

Clause 6 6.4.4.4 Technical

Change paragraph: If the calculated fatigue life

is less than 10 times the service life.....

Based on the precedent within the airline

industry of using a MFOP on fatigue based

inspections at 1/3 of design life. Use a risk

based approach as long as the loads remain

within the Normal operating load limits.

Rephrase as proposed:

Fatigue life tracking and subsequent inspection

plan should be defined based upon the following

factors; Maintenance free operating period,

fatigue life, load cycles within normal load limits,

DNV OS-F201/RP-C203 guidance and internal

company best practice. Fatigue inspections to

begin no later than 1/3 of estimated fatigue life.

All excursion(s) above normal load limits will

accelerate fatigue life consumption for the asset

and shall be analyzed and logged as unique

events. As these may trigger immediate

inspections and accelerate fatigue depreciation

of the asset.

Accepted



Equation (5) has an error the denominator in equation (5) should be as

modified on left where 2 is replaced by the 4

Accepted

4

Clause 6Table 6-8

WD5.2Technical

What does "-" mean in table. If it means "Not

Applicable" then replace with N/A. In either

case, add footnote to clarify.

Change "-" to "N/A" and and footnote N/A

meaning: Not Applicable AcceptedWG to review and propose change

Clause 6 6.5.4.2 TechnicalFirst paragraph. D/t < 3,1 should be D/t > 3,1 Change D/t < 3,1 to D/t > 3,1 in first paragraph

AcceptedWG to review and propose change

Clause 6 6.3.2.2 Editorial

duplicate sentence in 4th paragraph. Change to: Alternatively the design

temperatures can be determined from

calculations, tests, or service experience based

on measurements. Any heat transfer calculation

shall be performed on the assumption that there

is no heat loss due to wind. Heat loss due to

seawater can be considered for submerged

parts; however, only conduction heat loss to

seawater shall be considered. Convection heat

loss due to seawater current flow shall not be

included.

Accepted


Clause 6Table 6-7

WD 5.2Technical

Landing String shear subs have no guidance

listed

Landing String Shear Subs; Design code : API

17G, General Design Requirements : Subsection

6.4 and 6.5, Additional Design Requirements :

6.8.9

Accepted


Clause 6Table 6-7

WD 5.2Technical

Additional design Requirements and testing

columns not correct for PIPE.

Row "Pipe" Additional Design Requirements :

6.8.11, Qualification Testing : Subsection 6.7 AcceptedWG to review and propose change

Clause 66.4.3.6

WD5.2Technical

Delete material requirement which is covered in

Clause 7

Delete paragraph ; Furthermore, the yield

strength used in design ….Accepted



Current paragraph above equation (5) implies

the normal internal design pressure rating is

calculated in equation (18) and is based on burst

calculation in equations (3) or (4) and only the

FAT proof test is reduced the pressures in

equation (5) or (6). To keep a 1.5 proof test and

to clarify, recommend rewrite this paragraph.

Minor distortion may occur during hydrostatic

pressure testing when using equations (3) or (4).

In cases were no distortion is acceptable during

hydrostatic pressure testing, the minimum

pressure to initiate yielding on the inside of the

pipe will be used to determine the maximum

FAT proof test. The normal internal design

pressure rating will therefore be equal to 2/3 of

this (Max proof test -500 psi). The 500 psi is the

recomended allowance pressure testing

tolerance but can be adjusted to the

manufacturing testing capability. For open-end

pipe the minimum pressure to initiate yielding

on the inside of a pipe may be calculated by

equation 5:

Accepted



Pressure testign of subsea equipment should

not be limited to MEG fluid. MEG definition is

not correct.

Change "shall" to "should" and state reason is to

prevent hydrates. MEG stands for

Monoethylene Glycol.Accepted


Clause 6 6, Table Technical

Functional limit is 1.0 so does that mean no FOS

is required for functional limits. Also if functional

limit limits, then capacities are the same for all

operating conditions

review and consider safety factors

Rejected


Table 6.1 has been amended to address lack of clarity.

Clause 6 6.4.2 TechnicalTable 11: This table is in complete Complete Table 11. Moved to WD6 Comments

Clause 6 sub team to complete asap

Clause 6 6.5.5.2 Technical add an additional note for equation 23 to

connect table 6Accepted

What needs to go in the note??


Equation (5) has an error the denominator in equation (5) should be as

modified on left where 2 is replaced by the 4

Rejected

See 6.5.4.2 Eq 5 in WD6 Additions folder

Clause 6 6-1 GeneralThe table is not easy to follow, especially for the

Pressure design portion. What is meant by 0.90

for make-break in structural?

Try to make the table easier to follow, because

it's not immediately apparent to the reader what

any of these factors mean

AcceptedWG to review and propose change

Clause 6 6.2.5.2 GeneralIn the NOTE, it says that pressure/ temperature

cycling may also be included in fatigue testing if

significant

If it is significant, add a test or test procedure for

this fatigue evaluation AcceptedWG to review and propose change

Clause 6 6.3.1.2 General

NOTE 2 says the internal pressure will rarely be

above RWP then it says that the pressure will be

equal to or greater than RWP in the following

paragraph

Make sure these two statements agree

Accepted


Clause 6 6-6 General

For these temperature design classes, the

maximum temperature only goes to 350F, but in

Table 6-10, it goes to 390F.

Need to establish the maximum temperature

covered within the scope of 17G. If the

temperature (this goes for pressure as well),

then there needs to be a contingency of what

that means to have loading conditions outside

the 17G. (Reference API 17TR8 HPHT?)

Rejected


Design calculations are performed for min and

max coeff's of friction. What if the manufacturer

of the thread compound used for making up a

threaded connector only supplies a single

friction factor?

Remove statement since the connector

manufacturer uses the thread compound

manufacturer's value(s) Accepted


Clause 6 9' TechnicalCheck equation to see if correct, because when

equation attempted, it didn't come out as

expected.

Check equationAccepted


Clause 6 10' Technical

Check equation to see if correct, because when

equation attempted, it didn't come out as

expected.

Check equation

Accepted


Clause 6 14' TechnicalIt says that the equation is for plastic capacity,

but only using the yield stress

Take out plastic capacity and switch it to yield

capacity or the equivalentAccepted


Clause 6 15' TechnicalIt says that the equation is for plastic capacity,

but only using the yield stress

Take out plastic capacity and switch it to yield

capacity or the equivalentAccepted


Clause 6 19, 22 Technical

Using the net differential pressure does not

equate to the same stress in the material as

using simultaneous internal and external

pressure. Ex. 10,000 psi internal pressure and

5,000 psi external pressure does not create the

same stress distribution or loading as simply

applying 5,000 psi internal pressure, or the net

differential pressure

Fix these equations, because these equations are

not equivalent do 18 and 20, respectively

Accepted



What is meant by short-term and long-term

relaxtion of preload?

Provide details as to what's considered "short-

term" and what's considered "long-term". How is

this tested? If it's required, put this test in Annex

I.

Accepted


Clause 6 6-16' General

What is meant by Applied Tensile Load

Dependence?

Explain column

Accepted


Clause 6 6.6.7 General

"Seals shall be made from metallic materials or

elastomers that are resilient… external fluid."

Needs to include other materials, such as PTFE

or PEEK since they are not technically

elastomers. Casing connections use PTFE rings as

sealing mechanisms.

Add a term such as "thermoplastics" so that

PTFE and PEEK can be included as a sealing

materialAccepted


Clause 6 6.8' GeneralDrillpipe is not considered and OCTG product.

Referenced as OCTG several times within this

section.

Do not reference drillpipe as an OCTG product

anywhere within the spec. AcceptedWG to review and propose change

Clause 6 6.8.4 GeneralSo do drillpipe landing strings have to be in

accordance to 17G since 6.8.2 is for landing

strings as well?

Specify if drillpipe landing strings have to be in

accordance to 17G AcceptedWG to review and propose change

Clause 6 6-X General

This table is very ambiguous and needs to be

reworked and better explained in regards to

what it's trying to accomplish

Since this is a brand new table from WD4 to

WD5 and there are many issues that would be

difficult to explain, please contact Paul

Beauchamp (NOV) for discussion

Accepted


Clause 6 6-X GeneralThere is full sour service drillpipe, even for the

friction weld

Fix footnote 'a' to reflect thatAccepted



What about drillpipe connections outside of 7-

1?

There are premium drillpipe thread designs that

could be used for these riser joints, so the Table

needs to not limit drillpipe to the thread designs

seen in 7-1. Premium drillpipe connectors also

have metal to metal seals and other features

which can enhance the sealing and torque of

these connections.

Accepted



No drillpipe connections that are manufactured

exactly to 7-1 and 7-2 is suitable for any of these

purposes since there’s not seal designs in those

specs

Acknowledge that premium drillpipe

connections are capable of meeting the seal

design requirementsAccepted



There is full sour service drillpipe right now, so

for the open water intervention mode in H2S

requirements should say NACE MR0175

For the H2S row, include NACE MR0175 to the

open water well intervention mode drillpipe

column, otherwise, this will limit drillpipe

capability

Accepted


Clause 6 6-X GeneralMake-up torque for drillpipe should be 7G or

manufacturer’s specification

Add that manufacturer can specify make-up

torque for drillpipe connectionsAccepted



What’s the difference between mill pressure

test and hydrostatic body test? They’re both

Factory Acceptance Tests

Explain the difference between mill pressure

test, hydrostatic body test, and FAT test.

Confusing here.Accepted


Clause 6 6-X General Drillpipe has own drift requirements Reference drillpipe spec drift requirements Accepted WG to review and propose change

Clause 6(6)

Table 6-1Technical

Applying design factor for normal operations (Df

= 0.67) with metal at design temperature does

not follow the argument that design factors are

a function of factors including consequence.

Test pressure applied from the rig will typically

represent significantly lower consequence, and

temperature will typically be less than max

design temperature.

Include row for in-service pressure testing. Ref

API 17G 2nd edition Table 11.

Evaluate if Df = 0.80 can be acceptable for

pressure testing that will not compromise barrier

element integrity.

Rejected

In service pressure testing is not a governing load case. In

service pressure is equal to RWP and as pointed out

temperature is lower than Normal operating case.

Clause 6(11)

Table 6-7General

Spiders and Bails refer to API 17A Annex K for

design codes. API 7K and API 8C should be

included.

Update to include API 7K and 8C as design codes

for spiders and bails respectively.

Clause 6(12)

Table 6-8Technical

Suggest allowing Structural scaling of Swivels

and Telescopic riser components, as these are

not particularly different from connectors and

flanges from a structural point of view. Sealing

and friction are covered by seal qualification and

"Functional" scaling requirements.

Allow "Structural scaling, column 'a', for Swivels

and Telescopic riser components.


Value for maximum friction coefficient of 0.02 is

to conservative in light of accumulated field

history with connectors with self locking tapers.

Clause 6 6.4.4.2 GeneralRequirement in bullet b) and last note are both

vague as what can be considered small and

sharp are relative.

Rephrase

Clause 6 6-2, Table General

Note B is carried across from previous draft

version, and should be either removed or be

applicable to the two first lines not only second

line.

Apply note B to both first and second line in

table.

Clause 6 6.4.4.4 GeneralHow "first fatigue inspection" and "Following a

succesfull fatigue inspection" relates to

calculated service life is unclear.

Reword to specify that inspection intervals after

the initial service life has been expired should be

based on fracture mechanics.


A number of the items listed must be the

responsibility of the operator/purchaser to

provide; d (partly), f, g, h, l, m, q, r, s

Include statement on requirement for

operator/purchaser to provide required

information, or reference to relevant section in

Annex F

Accepted


e)question applicability of assigning

responsibility for recail analysis with CWOR

supplier, as tension system and top drive is

typically provided by others

Rejected

Scope of clause 6.10.6. is model validation. Resposibiølity is

contractual

Clause 6 6.10.7.5.1 General

Two items listed should be noted to include

operator responsibility;

- system risk review to evaluate accidental load

scenarios

- drift of/drive of limitations should be evaluated

by or specified by operator

Include note on operator/purchaser

responsibility to contribute.

Clause 6(22)

6-19,C110 Editorial

Accronyme ADB is not defined Include definition ADB = Analysis Design BasisAccepted

Clause 6 6.10.8.3.3 General

Responsibilities and limits are not defined in

Note 2. Who evaluates if consequences are high,

and who determines what the allowable limts

are.

Rephrase to define purchaser/end user

involvementAccepted


clause 6.9 and clause 6.10 are the same.

Delete “6.10 Non-pressurized equipment design

requirements” such that title of clause 6.9

harmonizes with clause 6.8.

The clause numbering should now be as follows:

6.8 Specific design requirements – pressurized

equipment

6.9 Specific design requirements – non

pressurized equipment

6.10 Global load and response analysis.

Accepted


Bullet d) example 1, last line "Minimum

hardness may be used to reduce tool marks on

connectors" Minimum hardness will increase

tool marks.

Delete this line The comments do not refer to the latest version (they do not

match paragraph number, bullets, subject…). We addressed all

comments received as a group before sending the clause to you

at the end of February.


Bullet (e) Hydraulic ports and related hole. This

bullet is redundent to bullet (a)

Delete this bullet The comments do not refer to the latest version (they do not





Item e. I have not seen that hydraulic ports are

overlaid. If there are some chemical injection

lines on HH trim the fittings will see the well

fluid( Medium pressure fittings)

Clarify to apply only to those ports which may

see well bore fluids.

The comments do not refer to the latest version (they do not





Line below Table 7-9. Low S, P and B required

for fasteners. Low values shall be for fatigue

critical fasteners.

Add ….seamless pipes, forgings and fatigue

critical fasteners, the following ..






7.4.3.4 requires that the Inspection and Test

Plan shall show the acceptable ranges for

dimensions.

Finish dimensions and their accepable ranges are

proprietary information and will not be part of

an FMC ITP.






Wedge testing requirements and Macroetch

requirements on critical fasteners. What is

critical fasteners, load bearing and or pressure

containing. This requirement can result in delays

in project, fasteners can be long lead items.

Remove or at least be detailed of what is

considered critical. Pressure containing and or

load bearing.





Clause 7

Section 7.0

(and

related

Annexes)

Technical

In our opinion, these sections (and annexes) are

way too long and overly prescriptive. This is

very good information but better suited for a

textbook.

All of Section 7.0 (and all related Annexes)

should be replaced with Section 7, 8, and 9 (and

related Annexes) of API Standard 2RD (2nd

edition, September 2013).




particular order.




















Clause 7

Section 7.0

(and

related

Annexes)

Technical

In our opinion, these sections (and annexes)

should only define requirements, not

procedures. In other words, this document

should focus on the "what" and not the "how".




particular order.




















Clause 7Table 7-5 &

7-9Technical

A class of material that meets API 17G (2006)

needs to be kept in the standard to allow a path

for qualifying existing equipment made to the

present release of 17G. Changes in Table 7-5

and Table 7-9 obsolete all existinng equipment.

If these changes are justified, then does existing

equipement designed to API17G (2006) need to

be de-ratred? If not, then are the material

changes really needed. If yes the change are

needed then how do we go about de-rating

existing equipment made to 17G (2006)?

technical discussion are ongoing

Clause 7 7.6.2(s) Technical

230 HV10 hardness gives tverytight range to

meet 80 ksi minimum yield material. Material

will loose strength after welding and PWHT.

Higher hardness closer to upper end is

necessary to allow for reduction in strength due

to PWHT.

Change: higher hardness for base material is

allowed provided supplier proves through

qualification testing that after welding and

PWHT base material will comply with the

hardness requirements. ET - recommend drop

the 230 maximum all together and permit to 250

HV. WPS can be qualified on like material.

further, essential variable established on girth

welds in table 36 make this restriction not

necessary.

Accepted

Moved to WD6 Comments - need more info - John to

resolve

Valid technical point

Clause 7 7

qualification of titanium seals

Titanium (seals) references should be in

brackets? - see table 7.2 (Grade 1, 2, 28, 29)

tbd

Accepted

The comments do not refer to the latest version (they do

not match paragraph number, bullets, subject…). We

addressed all comments received as a group before

sending the clause to you at the end of February.

Clause 7 7

"assess add'l requirements" - define what that

means (Strain based? Load based vs.

displacement Accepted

The comments do not refer to the latest version (they do

not match paragraph number, bullets, subject…). We

addressed all comments received as a group before

sending the clause to you at the end of February.

Clause 7 7.3.18

remove in entirity, but reference in other

sections - NDT sections (Add statement in NDT

section 7.4.4.2 stating that CTOD’s are used for

identifying min. flaw size and during inspection

for fatigue life of equipment)

remove 7.3.18 - add in 7.4.4.2….. Re-word

Accepted

Moved to WD6 Comments. John to modify (charpy and

lateral expansion….)The comments do not refer to the

latest version (they do not match paragraph number,

bullets, subject…). We addressed all comments received as

a group before sending the clause to you at the end of

February.

Clause 7 7.4.3.4

The use of prolongation may be acceptable

provided that section thickness, degree of

mechanical work, and thermal history are the

same as the critical regions of the component.

needs to be required, look for other

prolongation references throughout doc for

usage Accepted

Moved to WD6 Comments. The comments do not refer to

the latest version (they do not match paragraph number,



February.

Clause 7 7.4.3.4

Change the use of Prolongations … omit the

term "may" use.

Accepted


Review the prolongation usage of the terms in various

locations of the document. -- This should be changed from

the work that John is doing. The comments do not refer to

the latest version (they do not match paragraph number,



February.

Clause 7 7.3.19.1

charpy (combined with Lateral expansion

requirement 0.015 , % shear test) to make sure

your material as Quality Assurance function, and

use the CTOD's for the high strength . Location

should be reworded.

Accepted


Chevron Prevention of Brittle failure: -- Tight Chemistry,

Take the Prolongation (sacrificial forging, Inspection ,

testing at high stress location, etc. --- hydrogen

embrittlement is big issue for low alloy materials. Vote:

Charpy to be used strictly for Quality assurance

Clause 7 7.6.2(s) Technical

230 HV10 hardness gives tverytight range to

meet 80 ksi minimum yield material. Material

will loose strength after welding and PWHT.

Higher hardness closer to upper end is

necessary to allow for reduction in strength due

to PWHT.

Change: higher hardness for base material is

allowed provided supplier proves through

qualification testing that after welding and

PWHT base material will comply with the

hardness requirements. ET - recommend drop

the 230 maximum all together and permit to 250

HV. WPS can be qualified on like material.

further, essential variable established on girth

welds in table 36 make this restriction not

necessary.

Accepted

Valid technical point - Is this ready to go into document? Is

this a cut/paste?

Clause 77.3.18 -

Table 29Technical

Define forging as section wall thickness greater

than 3 inches, otherwise use pipe column

suggestionRejected

Should be added as note - Where does this go? Table 7-

18??

Clause 7 7' General

No reference to friction welds. In order for

drillpipe to be used as a riser, friction welds

MUST be referenced and discussed in Clause 7

Reference friction welds on drillpipe or refer

friction welding back to a drillpipe specification





Clause 7 7' General

Standard ISO 15156 does not apply to friction

welds. It is possible to produce sour service

friction welds for intervention risers.

Add some qualifying statements with regards to

friction welds for use in H2S. Contact Paul

Beauchamp or Lucien Hehn from NOV.






"Girth welds shall have an actual strength equal

to or higher (overmatching properties) that the

actual strength of the adjacent base materials."

With a drill-pipe based intervention riser, the

cross-sectional area at the weld could be around

twice the cross-sectional area of the tube (the

part of the assembly with the lowest cross-

sectional area). If the cross-sectional area of the

weld is is much greater than the tube, there is

no problem with the yield stress of the weld

being lower than of the tube. The stress in the

weld at any time in service will always be far

below that of the tube. Insisting on having the

weld yield stress equal or exceed that of tube

would not be reasonable and would place an

unnecessary severe manufacturing hurdle for

the weld without justification.

The passage should read something like "The

maximum in-service stress of the weld should

always be less than or equal to that of all other

components of the adjacent base metals in the

assembly. In addition, the weld yield stress must

be less than the maximum in-service stress of

the weld"






Who is responsible for the corrosion protection

application? End user

Make end user responsible for the corrosion

protection application, because manufacturer

may not be qualified for this type of application






Are the alloys in Table 7.3.8 suggestions as

written or required? Typically, advanced

engineering companies develop “modified”

alloys that are based off these basic alloys.

These modified alloys have greatly improved

properties over the base alloys they are based

on and hence should not be prohibited from

being used.

The table should give suggested alloys but not

prohibit alloys from being used since they can be

modified to be highly suitable for a given

environment or use.





Clause 7 7.5' Technical

In comment g below the table, the impact test

temperatures for welds are required to be

lowered by 18 F. The required test temperatures

(-4F) are already far lower than the weld would

experience in-service. Lowering the test

temperature another 18 F lower is arbitrary and

serves no purpose. This will only serve to make

manufacturing more difficult and drive costs

higher with no benefit.

Recommend removing this requirement. The comments do not refer to the latest version (they do not




Clause 7 7-8 GeneralPg 215 and 216 are missing. Need to see all

tables

Include pages 215 and 216 and all associated

tables


"Some tools and temporaty applications...". All

intervention equipment is by definition

temporaty (not permanently installed). This

section can be misinterpreted. The exact

equipment/components to which this relaxation

applies shall be clearly specified.

"Non-ISO 15156 compliant materials may be

allowed for cutting inserts and cutting blades."

Rejected

Already permitted exclusion in NACE


NOTE 2 is incorrect. Hardness

requirements/limits do not always apply for all

materials and product forms in ISO 15156-3.

- Remove NOTE 2; or

- Make NOTE 2 specific for carbon and low alloy

steels; or

- Rephrase NOTE 2 to "If applicable, hardness

requirements in ISO 15156 shall apply for

materials used in H2S service.

Accepted

Re-Written

Clause 7 7.3.3 Editorial 7th paragraph: "... shall be allow..." Rephrase to "shall allow" Accepted Re-Written


"... The selected minimum tempering

temperature shall be allow post-weld heat

treatment and still meet the minimum specified

mechanical properties."

This is only required if mechanical tests after

simulated PWHT are not performed. As long as

simulated PWHT, with temperatures and cycle

times equal to any subsequent PWHT, are

performed for each material heat and heat

treatment batch, then this should provide

sufficient evidence that the material is capable

of withstanding the PWHT without negative

effect on the mechanical properties.

It should be noted that tests after simulated

PWHT are addressed in the next paragraph

(same section) and other places throughout the

spec.

Remove this paragraph, or rephrase it to state,

"unless mechanical tests after a simulated PWHT

are performed for every material heat and heat

treatment batch. The simulated PWHT cycle

times and temperature shall be equal to any

subsequent PWHT to be performed on the

material."

Accepted

Removed


"Welding consumables for girth welds and other

pressure-containing welds shall be qualified by

testing during welding procedure qualification

or during welding production. This includes all

wires and wire/flux combinations."

It is not clear if the intention is to qualify each

consumable make (brand name), each batch, or

each AWS/EN classification. The boundaries in

which this requirement apply need to be

clarified.

"Each consumable brand name used for girth

welds and other pressure-containing welds shall

be qualified by testing during welding procedure

qualification or during welding production. This

includes all wires and wire/flux combinations.

This does not apply for solid wire provided

documentation of no change in AWS or EN

grouping and nominal chemical composition."

Accepted


Ref. NOTE in the end of this section. It is possible

to qualify procedures for repair of CRA overlay,

even if the overlay thickness is 3 mm (remaining

thickness prior to welding of 1.6 mm).

Rephrase to state, "unless the manufacturer is

able to document the repair of lower overlay

thicknesses, through welding qualifications. The

remaining overlay thickness prior to welding

during qualification shall be the minimum

remaining overlay thickness used production."

Accepted

Clause 7 7.3.6 Editorial"When it is not feasible to perform test a

sacrificial component..."

Remove the word "perform".Accepted

Clause 7 7-2, Table TechnicalType 22Cr and alloy 825 are also susceptible to

crevice corrosion in seawater

Refer note b also to type 22Cr and alloy 825.Accepted

Table Deleted


50 HBW units difference between ring groove

material and alloy 625 weld overlay cannot be

guaranteed.

Re-write this requirement to:

"The ring groove material, i.e. Alloy 625/725

weld overlay, shall be harder than the BX-type

seal ring."

Alternatively, if a limit must imposed, it should

be a more realistic value, such as 10 or 20 HBW

units. 50 is not achievable.

Accepted


Temperature de-rating factors are provided in

section 6.4.3.6 and Table6-10, but this section

(7.3.12) references ASME Division II, Tables Y-1

and U-1.

Refer to section 6.4.3.6 and Table 6-10, instead

of ASME Division II.Accepted


Ref. NOTE 1. Does the responsibility for

specifying low temperature limits for elastomers

lie with the manufacturer or the end user?

It may not straight forward for either to carry-

out the thermal analysis. While the

manufacturer has the equipment details

(dimensions and geometry), the flow conditions

may not be easy to estimate.

Selecting a conservatively low design

temperature (such as the standard Charpy V-

notch impact test temperature) may be an more

easily achieved.

Specify whose responsibility it is to define low

temperature limits.

Allow for a conservative low design temperature

(defined as the standard Charpy V-notch impact

test temperature), as long as the compound/seal

can be tested to this temperature.Accepted


Coating qualification tests and documentation of

suitability are losely defined. Who is responsible

for defining the requirements of coating

suitability? Manufacturer or end user?

Define documentation requirements and

responsibilities.Accepted

Clause 7 Section 7? Editorial"Valves and Actuators" section is not number. Number "Valves and Actuators" section as

appropriate.Accepted

will get tech writer to update - RC


"For carbon and low-alloy steels, Charpy V-notch

temperature may be adjusted for

locations/sections in components and for

components with low-applied tensile stress in

accordance with Table 7-6."

It doesn't make sense to adjust test

temperature, unless it can be shown that the

component or section within the component is

not exposed to low temperatures. In case of low-

applied tensile stresses, it may be considered to

reduce the impact energy requirement, but the

test temperature should remain the same, as

long as the equipment is exposed to that

temperature.

Add impact energy adjustment factors, instead

of test temperatures adjustments. Replace Table

7-6 accordingly.

Accepted

Removed temperatures adjustments

Clause 7 7-5, Table General

There are impact energy requirements for both

transverse and longitudinal direction. However,

the standard does not define if testing shall be

carried out in both direction, or if only one of

the two is sufficient.

Define if testing is required in both direction, or

if only one testing direction is sufficient.

Accepted

Clause 7 7-5, table Technical

The terms "longitudinal" and "transverse" do

not completely define the orientation of test

samples. The crack plane direction is not

defined, i.e. even if the sample "transverse" to

the direction of the central axis, the direction of

crack propagation can still be oriented in two

different ways.

Define the crack plane directions in foot note f.

Suggest to make reference to ASTM E1823.

Crack plane directions are:

Long = L-T (for rectangular sections) or L-R ( for

bar and hollow cylinder)

Trans = T-L (for rectangular sections) or C-L (for

bar and hollow cylinder)

Accepted

Clause 7 7-6, Table Technical

It doesn't make sense to adjust test

temperature, unless it can be shown that the

component or section within the component is

not exposed to low temperatures. In case of low-

applied tensile stresses, it may be considered to

reduce the impact energy requirement, but the

test temperature should remain the same, as

long as the equipment is exposed to that

temperature. See also comment to section

7.3.17.

Replace Table 7-6 with impat energy adjustment

factors.

Accepted

Deleted temperature adjustments

Clause 7 7-8, Table TechnicalSuggest adding AISI 4130 as riser pipe material Add AISI 4130 for riser pipe.

Accepted

Clause 7 7-8, Table TechnicalFootnote d. Metal plating is not the only

acceptable coating method for self-seating

pressure energized seals.

Add the following to footnote d: "...or

molybdenum disulfide coating if qualified." Accepted


At early design phase (when the materials

selection report shall be prepared), qualification

reports for all materials and manufacturers may

not be available yet. Qualification may be

performed at later stages.

Remove the requirement to have references to

qualification reports in the materials selection

report.Rejected

Even in early design stages, materials that do not have

current documented performance should not be presented

as options in the materials selection report.


Dimensional and surface roughness inspection

are not material requirements.

Suggest moving this clause to section 5

(Functional Requirements), Section 10

(Inspection, maintenance, reassessment and

monitoring), or section 11 (Documentation)

Accepted


Quality system and control (including pressure

measuring devices and personnel qualifications)

are not material requirements.

Suggest moving this to a separate section

altogether.Rejected

Clause 7 Several Technical

The term "Crack-like defects" appears in several

sections throughout the document, but it is not

defined. Whose responsibility is it to interpret if

a linear indication is a "crack-like" defect?

Define "crack-like defects" in section 3.1, or

change the term "crack-like defects" to "linear

indications". Accepted


Ref. sub-item s). SSC tests should only apply if

materials and/or welds are not capable of

meeting sour-service hardness limits or other

limitations imposed in ISO15156.

If material is processed according to ISO 15156

and meets the hardness limits imposed therein,

SSC tests are not needed.

Remove sub-item s) or add statement "if

materials and/or welds do not meet sour-service

hardness limits or other limitations imposed in

ISO 15156."Rejected

Could not find reference

Clause 7 7-11 Technical

Footnote d is not relevant. All materials and

alloys used in critical forged components shall

have material specifications prepared by the

manufacturer. Reference is given to section

7.4.3.2 and 7.6.3.3.

Remove footnote d.

Accepted


"Significant loading (high stress level)" is not

defined. How high do loads/stresses need to be

so that they are defined as "significant loads"?

Define "significant load (high stress)" in section

3.1.Accepted


Guidance note is not relevant. As long as the

material shall be qualified with mechanical

testing after simulated PWHT, the mechanical

properties after PWHT will be insured,

regardless of the relation between tempering

and PWHT temperature.

Remove NOTE.

Accepted


Furnace loading.

It is ok to require a sketch of furnace loading,

but this cannot be part of the heat treatment

procedure. Heat treatment procedures are

normally general documents, whereas a sketch

of furnace loading is typically job specific (it

depends on how many items are being heat

treated together, and their sizes). If this sketch

shall be part of the procedure, then a new heat

treatment procedure shall be created each time.

This is not practical.

In addition, the responsibility to review and

approve the stacking sketch is not specified. Is it

the end user, manufacturer, or supplier who

shall approve this? Or shall this document be

part of the final documentation, but it does not

require formal approval?

Sketch of furnace loading shall be prepared as

part of ITP, or MPS.

Define the responsibilities of approval of

stacking sketch.

Accepted

Approval responsibilities will be the same for MPSs if

drawing is included in MPS


Sketch of heat-treatment facility showing

furnace(s) and quenching bath relative to each

other is not relevant. The actual transfer time

from furnace to quench bath is more important

than the relative position.

Remove this requirement.

Accepted

Clause 7 7-12, Table EditorialThere is no cross-reference to footnote a in the

table.

Cross-reference "Equipment qualification" to

footnote a.Rejected

N/A - not footnotes in this table


"Significant loading (high stress level)" is not

defined. How high do loads/stresses need to be

so that they are defined as "significant loads"?

Define "significant load (high stress)" in section

3.1.Accepted


"The prolongation shall be a full cross section on

the thickest end of the forging if not otherwise

agreed as part of the qualification."

This requirement conflicts with section 7.4.3.4,

3rd paragraph, which states that the

"manufacture procedure shall be derived from

sacrificial components of similar dimensions and

include the specified range of mechanical tests.

The use of prolongation may be acceptable..."

Align both sections. What is the base case,

prolongation or sacrificial? And what are the

conditions for accepting the other?

Accepted

Clause 7 7-14, Table TechnicalFor flat ring forgings, the heat-treated thickness

(T) shall be the smallest between axial length

and radial thickness.

Define T as: "The nominal thickness shall be the

smallest between the axial length and radial

thickness."

Accepted


Footnote c. It is not necessary to measure the

hardness of components to be welded in Vickers

(HV10), as long as weld qualifications are

performed for the same material, using the

Vickers (HV10) method.


Accepted


PMI is not applicable for carbon and low alloy

steels. PMI only applies for stainless steels and

CRA's. If verification of chemical analysis shall be

done for carbon and low alloy steels, it shall be

performed by OES.

Remove this requirement, make it specific for

stainless steels only, or call it "Chemical analysis"

instead of PMI and add a note explaining the

difference between PMI and OES and when each

apply.

Accepted

Clause 7 7-16, Table TechnicalRef. footnote i. All manufacturers produce high-

volume of forgings.

Remove this requirement, remove this note, or

define high-volume.Accepted


"For a production part with a complex shape or

variying cross section, the prolongation shall be

an extension of the largest cross section of the

part."

There is a potential conflict between this

requirement and section 7.4.3.4, which reads

"The use of prolongation may be acceptable

provided that section thickness, degree of

mechanical work, and thermal history are the

same as the critical regions of the component."

The reduction ratio of (degree of mechanical

work) or largest cross section prolongation may

not be the same as the for the critical regions.

Clarify and remove conflict.

Accepted

Clause 7 7-17, Table EditorialFootnote a is not cross-referenced anywhere on

the table.

Cross-reference footnote as appropriate.Accepted

updated


Footnote b, sub-item 4. Testing all forgings (or

two of them as described in this section) is over

strenuous. Before heat treatment, one would

not know which forging will have lowest

hardness and which forging will have higher

hardness. Therefore, all forgings would have to

be designed with prolongations. This would

result in unreasonably high material costs.

Furnace callibrations, sketches of furnace

loading and measuring of transfer time from

furnace to quench bath are measures taken to

avoid large variations. This requirement

becomes overkill


Alternatively, use this method as a fallback

solution for cases where the hardness or

different parts differ more than 20 HBW (ref.

Table 7-16, footnote c)

Accepted


Paragraph describing simulated PWHT is not

prescriptive enough and leaves room for

misunderstandings. It statest that the simulated

heat treatments shall include temperature,

times and cooling rates, but it does not state

what these should be.

Add the following to the paragraph describing

PWHT:

"Simulated PWHT temperature shall be equal to

or higher than the PWHT temperature to be

used on the component during fabrication. Heat

treatment cycle time shall be equal to or longer

than the cycle time to be used during

fabrication. Heating and cooling rates shall be

equal to or slower than the heating and cooling

rates to be applied during fabrication. The

number of cycles applied shall be equal to or

larger than the number of cycles to be applied

on the component during fabrication. The

possibility for future repairs should be evaluated

and, if applicable, additional simulated heat

treatment cycles may be carried to account for

such situations."

Accepted


100% surface hardness by indentation method is

not standard industry practice.

Suggest the following:

"Hardness of 10% of the items per batch (same

heat and heat treatment lot, with no additional

heat treatment cycles) shall be done by

indentation method. 100% of the fasteners

(including those tested by indentation) may be

tested by other methods (such as magnetic

bridge). All items shall be tested by indentation

if:

- there is a difference of more than 2 HRC points

between the measurements by indentation and

the measurements by magnetic bridge; or

- there is a scatter larger than 3 HRC within the

same batch; or

- any of the items within the batch fall outside

the specified acceptance criteria."

Accepted

Clause 7 7-21, Table Editorial

Footnote c reads:

"The tension tests shall be taken from the bar

used in the manufacture of the nuts and used

for impact testing."

This is sentence is confusing.

Rephrase to:

Tension tests and impact tests shall be taken

from the bar used in the manufacture of the

nuts and used for impact testing."

Accepted

updated


Footnote c prevents the use of forged nuts,

since they are not manufactured from a bar.

Suggest adding:

"If forged nuts are used, tensile and impact tests

shall be carried out from a block of the same

material (same heat and heat treatment lot),

which has been forged to the same reduction

ration as the nut it represents. The size of the

separate test block shall be such that it allows

for the machining of all test samples and the

heat treated thickness (as defined in Table 7-14)

shall be at least equal to or larger than the

thickness of the nuts it represents."

Accepted

Clause 7 7.6.5 TechnicalMaterial for metal seal rings does not need to be

forged, but it shall have a wrought structure.

Replace "forged" with "wrought" in the second

paragraph of this section. Accepted


Metal seal rings are normally not exposed to

tensile loads or to impact loads. Especially BX-

type rings, which are loaded only in

compression. Hardness tests are sufficient.

Remove the requirement for impact and tensile

testing of metal seal rings.

Alternatively, remove this requirement for BX-

type rings.

Rejected

Tests are need to insure quality not just fitness for service


Sub-item e) "All welding of components exposed

to wellbore fluid shall comply with the welding

requirements of ISO 15156" is not applicable if

sour-service does not apply, i.e. if the wellbore

fluid is not sour. See also section 7.7.5.5.4

Rephrase to:

"All welding of components exposed to sour-

service shall comply with the welding

requirements of ISO 15156."Accepted


Simulated PWHT: It is a requirement to qualify

the base material with tests after simulated

PWHT. As long as the simulated PWHT

parameters used for mechanical testing of the

component are equal to the paramers used

during welding, the properties of the base

metals are already qualified. There is no value-

added in repeating these tests for the welding

procedure. See also comment above to section

7.6.3.10.

Remove this requirement, or add "if the base

materials to be welded have not been qualified

with simulated PWHT, as described in section

7.6.3.10."

Rejected


Sub-items identifying when no further testing in

simulated PWHT condition is necessary should

be essential variables of the welding procedure,

and not related to simulated PWHT only.

Remove these items from this section add them

to table 7-23 as additional essential variables.Rejected

Editorial


"Time between each layer" is not a relevant

essential variable. Typically, during weld

qualification, the time between layers is longer

than in production welds, due to logging

activities (such as measuring the length of the

weld bead, interpass temperatures, etc.). It is

not practical to repeat this during production.


Accepted


The allowable temperature range cannot be

based upon "nominal temperature". All heat

treatment methods (furnace, heating elements,

induction, etc.) will have built-in temperature

variations. If the allowable range is based upon

"nominal" temperature, then the actual

temperature can be even further than 14°C from

qualified, due to variations within the heat

treating equipment.

The allowable temperature range shall be based

upon actual temperature.

Replace "nominal" with "actual".

Accepted

Clause 7 7.7.5.5.3 EditorialReference is made to "Table 29". This table

doesn't exist.

Correct cross-reference.Accepted

now, table 7-27, updated


Footnotes a and b specify when to use CE(Pcm)

and CE(IIW). However, the "chemical

composition" line references both of them.

Clarify if both are to be used, or only one of

them, as suggested by footnotes a and b.Accepted


Post-weld heat treatment:

There is a conflict with section 7.7.5.2, which

allows a temperature range of +/- 14°C, while

this table allows +/- 20°C.

Correct table to +/-14°C

Accepted

now table 7-21, updated


Post-weld heat treatment:

The unit of heating and cooling rates needs to

be specified. 5% of °F/hour is not the same as

5% of °C/hour.

Specify unit (°C/hour)

Accepted


"The procedure shall identify the essential and

non-essential variables and address the

permissible number of re-heat treatments."

The number of heat treatments in a weldment is

determined by the weld qualification. Addition

or deletion of PWHT is an essential variable

requiring re-qualification.

If the complete weld overlay and HAZ is

removed, then this is accounted as a new weld,

and a new PWHT can be performed, as per

WPS/WPQR. However, the ability of the base

material to withstand the additional PWHT cycle

needs to be verified throug mechanical tests

after simulated PWHT. This is not related to the

WPS/WPQR qualification.

Remove "and address the permissible number of

re-heat treatments."

Accepted


"nominal temperature of +/- 14°C"

Nominal is not sufficient. See also comment to

section 7.7.5.2.

Replace "nominal" with "actual".

Accepted

Clause 7 7.7.7.3.1 Technical

Weld overlay in sealing faces is loaded primarily

in compression. Tensile and impact testing are

irrelevant. They will add a significant amount of

work and effort to the qualification of weld

procedures, in return to very little value added

to the quality of the overlay or seal face.

Remove the requirement to perform tensile and

impact tests for overlay of sealing faces.

Accepted


Number of tests for Charpy V-Notch and for

Microstructural Examination is not specify.

Correct accordingly.

Accepted





Clause 7 7.7.7.3.6 TechnicalMicrostructural examination of solid solution

nickel based alloys should not be required.

Add "except for solid solution nickel based alloy

overlays, where microstructural examination is

not required"

RejectedThe exam is for thickness not microstructure


There is a potential conflict with section 7.7.7.1,

which states that "the minimum overlay

thickness used for the production shall be used

for the welding procedure qualification tests."

If all-weld tensile test samples are to be

machined from the weld overlay, then it may

not be possible to qualify with the minimum

thickness to be applied during production.

Clarify and remove conflict.

Rejected

Clause 7 7.7.8.3 GeneralAWS A2.4 is also a valid standard for welding

symbols.

"Symbolic presentation of welds shall be

according to ISO 2553, AWS A2.4, or equivalent." Accepted

Clause 7 7.7.8.6 TechnicalFCAW (136/137) produce welds of similar or

better quality than SMAW (111).

Add FCAW (136 / 317).Accepted

Clause 7 7.7.8.10 Editorial

There is a confict between this section and

section 7.7.3, which requires PWHT for joints

exceeding 20 mm.

Remove the first paragraph of this section.

Accepted






Heating rate, cooling rate and soaking

temperature shall be specified on the WPS, and

it shall be equal to the parameters used during

qualification. It is not necessary to include this

information also on a PWHT procedure.

Remove sub-items a), b) and c).

Accepted

Clause 7 7.7.8.12 TechnicalProduction tests may not be possible for repairs

and re-certification, due to lack of material

available to run such tests.

"For the fabrication of new systems, a

production test program shall be established..." RejectedIf material is not available, then a wavier can be considered


SSC testing should not be required if both

welding procedure and production tests show

hardness in accordance with ISO 15156.

"SSC testing is required for production if

hardness testing fails to meet the requirements

per ISO 15156."Accepted


Grinding flush of weld root may not be practical

or possible in all locations. Welds located far

from the ends of the riser joints may not be

accessible.

Replace "shall" with "should whenever possible"

Rejected

Accesibility can be assesed at time of issue


Weld overlay in sealing faces is loaded primarily

in compression. Qualifying as a buttweld for this

application is irrelevant. This will add a

significant amount of work and effort to the

qualification of weld procedures, in return to

very little value added to the quality of the

overlay or seal face.

Remove the requirement to qualify weld overlay

which is part of a sealing system as a butt weld.

Accepted

Still required if strength of overlay contributes to design


How should overlay welds be qualified as

buttwelds? Base materials on both sides, with a

groove and overlay material used as filler metal?

This is not representative of the actual weld

configuration.

"When weld overlay strength is considered as

part of the design the clad shall be qualified with

tensile test accross the fusion line, all weld metal

tensile test, and impact test of the weld metal,

fusion line, FL+2mm and FL+5mm. The weld

configuration should be agreed between the

parties involved, and it should be as close as

possible to the actual configuration on the

finished component, but at the same be of a

geometry and size that allows for the machining

of all relevant test samples."

Rejected

If the overlay is included in strenghth calculations, it must

be qualified as a load bearing system. If this is not desired,

don’t include the overlay as part of the strength


"No visible indication, i.e. surface shall be free

from cracks and other linear defects."

Does this mean that rounded indications are

acceptable?

Remove the word "linear".

Rejected

Redundant

Clause 8 8.3.4 TechnicalLock and unlock connector 6 times. 6 cycles is

unnecessary and may cause unnecessary wear.

Lock and unlick the connector 2 times.Accepted

Requirement revised

Clause 8 8.9 TechnicalItem B-5. Testing the Stress joint atop of EDP

can be a challenge and not practical.

RemoveRejected

Requirement remains as stated

Clause 8 8.9 TechnicalItem B-8. Pressure testing before and after

disconnect of EDP can be a challenge.

RemoveRejected

Requirements remain as stated


Bullet b) 4)

Disconnect of EDP under riser load conditions

are not a practical test to perform. High angle

release capability under loads are verified during

qualification, and only a verification that

additional structure doesn't limit the connector

performance could be required.

REMOVE this from SIT as High Angle disconnect

capability is part of Performance Qualification,

not SIT.

Accepted

Requirement revised


Fourth paragraph states that gas testing shall be

performed as part of qualification testing. For

equipment not designed for gas service this is

considered to onerous.

Distance from pipe ends shall be at least 2T or

no greater than 122 (305mm).Accepted

Requirement revised


Consistency required 8.3.1.3 mentions test

pressure but here we mention minimum test

pressure which is correct?

Suggest removal of "minimum"

Accepted

Requirement revised

Clause 8 8.3.1.3 GeneralConsistency required 8.3.1.3 mentions test

pressure but 8.3.1.2 mentions minimum test

pressure which is correct?

AcceptedRequirement revised


Agree with this but 8.3.5 does not exist.

Previous WD2 mentioned testing Riser Joints to

API 6A PSL 3 requirements with the exception

that they could be painted. Is this the intention?

Clause 8.3.5. should read 8.3.2

Accepted

Revised to a NOTE

Clause 8 8.3.1.4 TechnicalWhat about external proof test pressure; 1.1

MWP for control linesRejected

Covered in another referenced standard


Is gas body (leakage) testing required for the

manufacturer to perform? The wording is

slightly confusing in the opening statement.

More clarification.

Accepted

Requirement revised

Clause 8 8.3.2.1 a) Editorial Reference to 8.3.5.2 does not exist. Fix reference. Accepted requirement revised

Clause 8 8.3.2.2 TechnicalJustification for 1.25 x Pd as test pressure? Justification required


Clause 8 8.3.3 GeneralAgree with tests.

Caveat:- Should a separation of the hub faces be

included in the Lock - unlock test?

add a separation of the hub faces be included in

the Lock - unlock e.g. unlock - separate - engage -

lock



Unclear statement on allowable pressure drop

(Jonas to propose)

8.3.1.1 Start of hold periods

Hold periods shall start after pressure and

temperature stabilization has occurred and the

equipment with

a pressure-monitoring device has been isolated

from the pressure source. The time specified for

hold

times shall be a minimum.

Initial pressure shall be between specified test

pressure and 5 % above.

Temperature shall be considered stabilized when

the rate of change is less than 0,5 °C/min (1

°F/min).

8.3.1.2 Acceptance criteria - hydrostatic pressure

testing

The following acceptance criteria shall apply for

all hydrostatic pressure testing:

a) No visible leakage during the hold period;

b) Pressure drop curve should be approaching

zero rate in change;

c) The allowable pressure drop is 3% of the test

pressure per hour.

Note: the pressure during the hold period may

drop below the specified test pressure as long as

the acceptance criteria are fulfilled.

Partially

Accepted

Requirement revised

Clause 8 8.3.2.1 GeneralIncomplete statement of how long minimum

hold times shall be

Complete statementAccepted

Requirement revised

Clause 8 8.3.3.1 GeneralSays that each riser joint must be hydrostatic

tested, but Table 6-X says drillpipe doesn’t need

hydrostatic testing

Fix confusion between 8.3.3.1 and Table 6-X for

hydrostatic testing RejectedNo table in Clause 8

Clause 88.3.2.4 &

8.3.3.2Technical

Pressure testing is 1.5x rwp and 1.25 design

pressure in another place. Needs consistency

Keep the pressure testing consistent. There's

several references to different values and it's

hard to keep straight.



Fourth paragraph states that gas testing shall be

performed as part of qualification testing. For

equipment not designed for gas service this is

considered to onerous.

Rephrase to state that equipment qualified for

gas service shall be qualified with gas.Accepted

Requirement revised

Clause 8(8.3.1.5)

8.3.2.5Editorial

Remove reference to water as test medium for

gas testing.Accepted

Requirement revised

Clause 8 8.3.2.2 Technical#### Justification for 1.25 x Pd as test pressure?

####Accepted

Requirement revised


Bullet b) 3)

Drifting of TSJ and EDP potentially poses

significant HSE risk from working at very high

elevations to get access. Benefit from this test

arguably doesn't provide enough benefit to

justify this as long as a seal arrangement that

can be verified to be driftable is used.

Remove bullet b) 3)

Rejected

Requirement shall remain as stated.


Bullet b) 4)

Disconnect of EDP under riser load conditions

are not a practical test to perform. High angle

release capability under loads are verified during

qualification, and only a verification that

additional structure doesn't limit the connector

performance could be required.

"Connect and disconnect angles shall be

simulated to verify that framework, control

interfaces or other details don't inhibit proper

function of the EDP connector. Interface shall be

pressure tested before and after a

disconnection."

Accepted

Requirement revised

Clause 8 8.3.1.5

A hydrostatic body test shall be performed prior

to any gas testing.

Can the equipment be stripped and dried after

the Hydroststic body test before carying out the

Gas test? There is no suggestion that the hydro

is directly before the gas test only that it has to

be carried out.

Accepted

Requirement revised

Clause 8 8.3.1.5

Water or water with additives shall be used as

the test fluid. Any additives shall be

documented in the test records.

This intimates that the hydro test is directly prior

to the gas test. Gas testing with Nitrogen will

cause any water to freeze. This could be an

issue.

Request addition of strip down and drying of the

tool between hydro and gas testing. OR removal

of this paragraph.

Accepted

Requirement revised


Inspections should include material testing i.e.

HISC

Inspections relating to areas such as the

following may be necessary for subsea well

intervention system components: j) material

degradation (HISC)

Rejected

Methodology to be further discussed and included in the

next WD

Clause 11 11.4.2 b)

b) design criteria with reference to applicable

codes, standards, and regulations for:

- strength and leak-tightness for normal,

extreme, testing, accidental load conditions

based on minimum specified strength/preload

values;

- safe break joints (weak links) based on

maximum specified strength values;

- maximum cyclic peak stress ranges, i.e.,

SCFs/stress distributions for fatigue assessment.

shall be documented. SCFs introduced by the

connector in the connecting pipe girth weld

location (both inside and outside diameter)

without any eccentricity shall also be

documented;

"b)" needs to include minimum breakage value

as well as maximum. This may be project specific

so may not be available until a GRA has been

carried out.

Accepted, see

update

Wording should reflect minimum breakage values, not

maximum:

"b) design criteria with reference to applicable codes,

standards, and regulations for:

- strength and leak-tightness for normal, extreme, testing,

accidental load conditions based on minimum specified

strength/preload values;

- safe break joints (weak links) based on minimum specified

strength values;

- minimum cyclic peak stress ranges, i.e., SCFs/stress

distributions for fatigue assessment, shall be documented.

SCFs introduced by the connector in the connecting pipe

girth weld location (both inside and outside diameter)

without any eccentricity shall also be documented;"

All All General Technical

The term "qualified" is used through the

specification, it has little to no substance unless

it is connected to a related requirement. Such

as: qualified to the requirements of ISO 28781

or the like. See 5.3 g) as an example

Replace the term "qualified" with conforming to

the requirements of…. or validated to the

requirements of ….. In each use

Moved to WD 6 comments

All

All

Section

s

GeneralTerminologies "elastic ideal plastic" and "elastic

perfectly plastic" are used interchangeably,

which may be confusing.

Align terminology. Moved to WD6 Comments

Need input from Finn to resolve

All

All

Section

s

Technical

Reference is made to kill and circulation cap.

This is a specific system reference (FMC?) it

should be defined or explained better

No correction

made


All

All

Section

s

Additionally there is no reference made to single

top tension operations. Not all operations use

riser tensioners. This needs to be allowed for

throughout this section

Accepted


move to technical - Agree with comment

All

All

Section

s

Pull 17B design reference out of the document Accepted


need further clarification - ask Brian

All

All

Section

s

ALL General

reveiw entire annex to remove mention of

applying pressure upstream or down stream of a

valve. Annex is for valves with different primary

seal directions, ie RV only function is to seal

from 'above', where pressure would be applied

from the 'downstream' direction. according to

this annex it would only be tested from the

'upstream' direction.

Replace 'upstream' with 'primary sealling

direction' and 'downstream' with 'secondary seal

direction' Accepted.

Test

procedures

are often

ambiguous.

Technical writer to work with Paul/Ray to clarify intent of

each instance of upstream/downstream. Possible alternate

method would be uniform "above" or "below" relative to

operating position. EG retainer primary sealing direction is

"from above". What is the primary direction for a

lubricator? Pump-through behavior may complicate things.

Accepted to Change throughout doc and add to definitions

Annex B B.4.8 Technical

Larger angles in upper flex joint than in ISO

13628-7

Table B-15 gives recommended values for

minimum ball/flex joint angle tolerance for a

landing string. Depending

on operational region, and water depth, it may

be necessary to design the landing string with

better tolerance,

to achieve sufficient environmental limits. Table

B-15 is difficult to understand. Tolerance is

normally applied to design value. A specified

tolerance without a design valve is has no value.

Tolerance is normally related to measurement

accurracy and therefro shall be constant for load

conditions. What is the definition of "lower" and

and "upper"

Table B-15 shall be revised such that it can be

understood.

Annex C C.6.3.3 GeneralEq. (C.5) would be easier to understand if a

figure was included.

Include figure. Accepted

comment relates to WD 4 numbering. Moved to WD6

Comments

Fk to include figure. Now in section C.6.1.3

Annex C C.1.2 TechnicalReferences 480F when 350F was the highest

possible through Table 6-6

Fix temperature maximumRejected

move to note- limitations on creep only. Does not mean

that section 6 is wrongAnnex C Table C-3 Editorial Update table C-3 to inlcude figures update table Accepted See WD6 Additions folder and replace table

Annex D Table D.1 Technical

States that surface friction exceedance is a

separate failure mode, but it is covered by the

plastic collapse assessment. Unzipping of the

thread will cause a reduction in connection

stiffness, an increase of load to the threads still

in contact and therefore this will be visible as a

drop in the plastic collapse load from the

respective assessment.

Merge the friction exceedance and plastic

collapse modes of failure in the table.Mod - text to

be part of the

analysis

however not a

separate

criteria.

Rejected


Discuss with Team. -- Keep Separate in the Plastic collapse

analysis - Unzipping. Note: No specific criteria for each

failure mode - Need to propose a level.

Annex D D.2, Table Technical

primary & secondary plastic limit is 3x and not

2x. 2x comes from 3x times 2/3 safety factor.

change allowable stress at plastic collapse to 3.0

Rejected


Note: Increase in 50% load capacity from Elastic to Plastic -

Load Limit theory


Limitations on shear and bearing have been

removed they should be reinstated if people are

to be allowed to use linear-elastic method.

Reinstate shear and bearing allowables.

Accepted


Need to add shear and bearing stress allowables.

Annex D D.2 Technical

Remove bullet point f) - contradictory to e). Remove bullet point f). Rejected -

Shear subs are

unique from

speciality


Annex D D.2.3.2 GeneralParagraph 1 - Some components in a tool may

not be applicable for 'plastic collapse capacity'

analysis.

Add better definitionRejected


Annex D D.2.3.2 GeneralSecond sentence in Note 2 refers to "elastic

plastic material" whereas "elastic ideal plastic

material" is meant.

Change "elastic plastic material" to "elastic ideal

plastic material". RejectedMoved to WD6 Comments

Annex D D.2.3.4 GeneralParagraph 2 - What does 'Friction imply also

friction angle due to contacting angle' mean?

Please clarify statement in documentAccepted


Annex D D.2.3.4 C Technical

does not make sense for this feature - by

definition it is self locking and has no effective

exceedence capacity

clarify Accepted -

need to add

Figure D2

(illustration of

the pre-load

exceedance)

However "self

locking"

within a range


Annex D D.2.3.6 Editorial

description of preload exceedence capacity

varies throughout some times exceedence of

preload capacity - confusing. Need to stick to

one title & description throughout standard.

Table D.1 defines as Preload Exceedence, so use

that

Change D.2.3.6 title to "Preload Exceedence

Capacity" Change content G.1, G.2.2 to "preload

exceedence" Made no

change


Move to Technical -- rewording of the statement by

original author required.

Annex D D.2.3.6 Technical

This para needs some clarification but in general

the point is not carried through the rest of the

standard. The seal face preload capacity is

different to the hub face preload capacity. Also

further clarification required in relation to seal

prep separation

Add after "relative displacements at the hub

faces" the sentence "This may give rise to two

preload exceedance capacities - at the seal prep

(inner) and at the hub face (outer), which should

be determined and used as appropriate to assess

connector and seal performance". Alter standard

throughout to add seal prep preload capacity.

D.2.6.2.1 and I.2.2 to be changed to read "hub

face separation at seal preps"

Rejected Add

after "relative

displacements

" "Preload

exceedance

capacities - at

the seal prep

(inner) and at

the hub face

(outer).

D.2.6.2.1 and

I.2.2 to be

changed to

read "hub face

separation at

seal preps"


Annex D D.2.3.7 General

For me it is not clear what shall be calculated

regarding permanent loss of preload.

1. From the first paragraph and the sentence

"The permanent loss of preload is the maximum

load the connector can sustain before there is

reduction in the original preload exceedance

capacity" it seems the permanent loss of

preload capacity is a load, e.g. 4000 kN or 1500

kNm, i.e. the maximum load that can be applied

without loasing preload exceedance capacity.

2. However, from the paragraph after the note

(and Figure D.3) it seems the idea is to calculate

how much preload exceedance capacity is lost

after application of different collapse capacities,

i.e. this would be a number, e.g. 5 % loss or 95 %

remaining preload exceedance capacity.

Clarify

Needs

clarification -


Annex DD.2.3.7,

continuedGeneral

If 2 above is the intention, this is not really a

capacity, rather a number (percentage)

describing the remaining preload exceedance

capacity after various load scenarios. If 1 above

is the intention, the permanent loss of preload

capacity would be a single load, independent of

normal, extreme or accidental load. Ref. also

Table D.4 and D.5.

Clarify

Rejected



Double use of per unit length. Change phrase "...can be 200 N/mm (1150 lbf/in)

per circumferential unit length mm (inch) of seal

contact to provide a gas tight seal" to "...can be

200 N/mm (1150 lbf/in) of seal contact to

provide a gas tight seal".

Accepted


Seal contact stress shall be analyzed as part of the static

analysis to evaluate gas seal tightness for variations

connector load cases as defined in Figure (xx- Preload

exceedance).


Standard has slipped into describing seal design

performance criteria which is not a compete

description and is not guarantee of

performance. The standard should not be

attempting to provide MTM seal design

criterion.

remove paragraph starting Metal-to-metal and

replace. "The performance of a MTM seal is

subject to many parameters and it is outside the

scope of this standard to specify performance

criteria. The seal used should be assessed for

performance in the context of the connection

characteristics e.g. separation at seal preps and

in line with the performance criteria for the seal

in question"

Accepted


The performance of a MTM seal is subject to many

parameters and is outside the scope of API 17G


How do we cover this galling mechanism in

Analysis. Unless some methodology can be

identified, I suggest that this requirement is

moved to the testing.

Either define an appropriate methodology to

consider galling or move to a testing section.

Reject - Galling

is outside the

scope of this

Annex D


Annex D D.2.4 General

Paragraph7 - How do you 'ensure' that for every

tension there is a single collapse moment if

there is load path dependency as stated may the

case in the previous paragraph?

See comment

Accepted with

comments.


The designer needs to perform "load path and sequence of

applied loads will impact calculations to determine the

collapse load limitations..


Linear elastic (e) - How do you have 'plastic

collapse' for a linear elastic analysis?

Please clarify statement or delete Accepted:

Load limit

static analysis

shall include

both elastic

and plastic

collapse


Perhap point is to conduct comparison between elastic and

plastic collapse


Point c) in list states that linear elastic analysis is

not applicable for "cases which requires

separation of stresses into primary and

secondary stresses". This seems to contradict

sec. D.2.5.3 which requires that stresses be

"decomposed into primary and secondary

stresses".

Delete Point "c) … Moved to WD6 Comments

Ref Addition: 2.5.3. note: Impossible to split the stresses

and needs to be summed .


Paragraph above Table D.2 - If permanent

deformation is present, why is elastic stress

analysis allowed?

Line of discussion is wrong and confusing,

consider deleting

Accepted--

need to

review the

2.5.2 with



Is it allowed to perform new analysis in

accordance with the the API 17G 2nd ed. and

still be compliant with API 17G 3rd ed.? Or is the

statement in the NOTE only for existing

analyses?

Clarify

Rejected


Annex D D.2.6 Technical

Note 6 - First sentence about linear element

types is not true for tetrahedral elements.

Remove NOTE 6: -- Discuss with

Team -

Tetrahedral

elements --


Replace to Should ---


no partial threads - might be OK for some

designs but especially large threads need to

consider half a partial thread at each end so

threads are N-1 and not N-2

change "with no credit for partial threads" to "up

to a maximum of one half of a partial thread may

be considered"


Paul to comment

Annex D D.2.6.3.1 GeneralParagraph 1 - Why does one need to find the

'thread load distribution'? How do you report

that as a function of applied load?


Paul to comment

Annex D D.2.7 General

Paragraph 6 - States 'See previous comments

relating to member extensions being added to

the geometry'. Where are the previous

statements? I did not find them.

Rejected


Annex D D.2.7 GeneralWhat is the purpose of adding Note 3? I do not

understand the comments.



Loss of preload capacity too - many load steps -

excessive analysis requirements. No one should

be operating after 90% & 100% loads anyway.

reduce to 67% (working) and 80% (extreme) Reject: Part of

Limit state

design method

to evaluate

load range of

component



As part of the typical load sequence list it is

stated that we must include

"Pressure/temperature cycling of metal seals as

per ISO 10423:2009 F.1.11 or 3 pressure cycles

in cases where thermal effects can be

neglected;". If thermal effects are being

neglected why do we need to perform an

additional 3 pressure cycles after the FAT. These

will not overcome the induced residual stress

state from the FAT.

Reword to "Pressure/temperature cycling of

metal seals as per ISO 10423:2009 F.1.11 where

thermal effects cannot be neglected;".

Accepted


Annex D D.3 Technical(c) - I do not agree with this method for the

stress-strain curve as shown in Figure D.6.

Where does this come from?

AcceptedMoved to WD6 Comments


Point c) in list states "Set onset of plasticity to

sy..." and refers to Figure D.6. However, the

curve in Figure D.6 shows non-linearity prior to

yield.

It should be specified that elastic ideal plastic

models should have a cut off at yield and maybe

give recommendations for elastic plastic curves

with hardenability.

Accepted with

additional

strain and no

strain


Annex D D.3 GeneralPoint f) in list: Should "loss of preload capacity"

be "preload exceedance capacity"?

Consider changingAccepted


Annex D D.3, Figure TechnicalMisses seal prep displacements (as discussed in

D.2.3.6)

add additional line to graph illustrate seal prep

separationAccepted



Friction - zero or artificially low COF can NOT be

used in taper connectors at the dog/cam

interface

Add after first sentence "it is accepted that taper

connectors will need to apply friction at the

cam/dog interface". Rejected


It is accepted that taper connectors will need to apply

friction at the cam / dog interface with very low values to

allow convergence of the model.


The use of worst case dimensions during finite

element analysis will included worst case

(minimum metal) thread dimensions. The

analyst shall consider the effect of other

possible dimensional variations and dimensions

expected to limit capacity shall be modeled at

worst case.

Modify to "The use of significant worst case

dimensions during finite element analysis will

included worst case (minimum metal) thread

dimensions. The analyst shall consider the effect

of other possible dimensional variations and

dimensions expected to limit capacity shall be

modeled at worst case.

Accepted,

update

change


"other dimensional variations are ovality, corrosion loss,

coatings, max/min tolerance conditions, taper

dimensioning tolerance, etc.

Annex D D.4 Technical(e) Where does the equation for the true strain

at failure come from?

Please defineRejected



Too many actuals are required. Some are not

sensitive to capacity

change "elastic-plastic FEA shall be performed

considering the following" by adding "where

these are deemed to be significant"

Accepted

change


Annex D D.6 General

(g) I do not agree that the deformed and un-

deformed shape should be superimposed for

the failure location? What is the purpose

Remove this requirement Moved to WD6 Comments

Annex D D.6 General(h) (8) What is the purpose of showing the

thread load distribution?

Remove this requirement Moved to WD6 Comments

Annex D D.6 General (i) This comment is overly prescriptive. Remove 'shall'. Moved to WD6 Comments

Annex D D.6 General(j) Why is the principle stress direction needed?

Which principle stress?



"Therefore, strain gauges shall be located to

obtain

results due to primary loading, and to avoid

results due to secondary and peak effects."

Strain gauges can not sensibly be put at key

sections and attempts to do so will alter results

due tio modifications (grooves/holes) and/or the

results are meaningless due to the size of gauge

Therefore, strain gauges shall be located to

obtain

results due to primary loading, and to avoid

results due to secondary and peak effects. Add

"where this is not possible, then analysis and

correlation of results is required".Accepted


Annex DEquation

D.7General

Pc in equation D.7 is not defined. Give definition of Pc in list above equation Shift to

definition -

need to add -

"Collapse

Pressure"


Annex D Figure D.1 General

Terminology of Figure D.1 is not aligned with

terminology in Table D.1 and text in general.

This applies to several places in Annex D where

"Loss of hub separation" and "Hub face

separation capacity" is used instead of

"Permanent loss of preload capacity" and

"Preload exceedance capacity"

Align terminology of Figure D.1 with terminology

in Table D.1 and text in general.

Accepted


Annex D Figure D.3 GeneralTerminology of figure not aligned to general

terminology, ref. comment to Figure D.1

Align terminology of Figure D.3 with terminology

in Table D.1 and text in general.


Annex D Figure D.5 Technical

Why does the 'elastic-plastic without strain'

utilize plasticity up to the offset yield? I do not

know of anywhere else that this is used.

I.e. include the use of strain-hardening into

analysis

Rejected : this

is part of limit

state design

and captured

in the Design

Factor.


Annex D

In

particular

sec. 6,

Annex D,

ALL

SECTIONS

Technical

The use of plastic collapse as structural criterion

with a design factor of 2/3, 0.8 and 1 (0.9) in

normal, extreme and accidental operation

respectively may give a considerably increased

structural capacity compared with the previous

edition of API 17G. The pipe example in Annex E

gives an increase of 32 %, ref. Table E.1. Is this

intended? Also, in accidental mode this will

actually allow the part to collapse unless the

capacity is limited by a functional criteria. For

reference ASME VIII Div. 2 Part 5 (2011) is using

a safety factor of 2.4 against plastic collapse, see

Table 5.5 of ASME. In addition, ASME has a local

failure criterion that needs to be satisfied, which

would limit local plastic strains, ref. ASME sec.

5.3.3.1.

Consider adjusting design factors and

introducing local failure criterion, in particular

when elastic-plastic material with strain

hardening is used.

TBD


Annex D

Note 2

below fig

D.6

Technical

Can we not simply use the ASME Sec 8, Div 2….

Curve?

This should have limited impact, since we

typically limit the designs to around 2% strain

limits, not run this all the way to break

Reject : Design

methods are

based on limit

load analysis.


Annex D Table D.1 General

Progressive plastic deformation is not included

in the table although it is include in Table 17 and

treated in sec. D.2.3.5

Include structural failure mode "Progressive

plastic deformation". To include racheting


Update table to include racheting as a structural failure

mode

Annex D Table D.3 GeneralGeometry - What imperfections 'shall' be

included?

Either add specifics or delete comment from

table.


Annex D Table D.3 GeneralDetermination of capacity - What is meant by

'analysis increment scheme'?

add additional information Moved to WD6 Comments


Exceedance of surface friction. Capacities for

exceedance of surface frication will

automatically be evaluated in the plastic

collapse

analysis.

Exceedence of surface friction poorly defined.

Should instead be named: "Unlock resistance"

Accepted -

need to add

Figure D2

(illustration of

the pre-load

exceedance)

However "self

locking"

within a range


Annex D D.7 General Move section to Annex I Moved to WD6 Comments

Annex D D.2.6.2 TechnicalReconsider making 3D FEA required for

threaded connectors.

Make 2D axisymmetric FEA required for thread

connectors and 3D optional.Rejected

Requirement is clear and consistent

Annex D D-4' GeneralIs this table for FEA or for physical testing? What

is its purpose? Is this related to Annex I?

Specify what this table is forRejected


Annex D D-5' General Explicitly state that this table is for FEA See comment Rejected Requirement is clear and consistent

Annex E E.3.3 General

The use of a pipe as analysis example raises the

question of whether it is allowed to use FEA

(elastic plastic with strain hardening) to

determine pipe capacities. This is especially so

considering the statement that "It is further

seen that there are large reserves in plastic

collapse capacities determined by elastic-ideal

plastic analysis compared with capacities

determined by elastic-plastic analysis as

required by API 17G". What does "as required by

API 17G" refer to, i.e. exactly what is the

requirement in API 17G? My impression before

reading Annex E was that we could freely choose

between elastic, elastic ideal plastic or elastic

plastic with strain hardening for components in

general, but that the formulas in sec. 6.5 are to

be used for pipe.

Clarify Moved to WD6 Comments

Finn to re-write

will not be addressed in WD6 - Annex placed on hold

Annex E E.3.4.2 Technical

It is stated that "The analysis is performed with

linear elastic material." This is combined with

the HS curve. But according to sec. C.9 point b)

1) an elastic-plastic material model shall be used

in combination with the HS curve. If a linear-

elastic model is used, it shall be combined with

B1 curve. As the objective of Annex E is to

illustrate calculation of cyclic capacities (ref. E.1

b)) it is strange to not follow the requirements in

Annex C.

Clarify Moved to WD6 Comments

Finn to address


Annex E E.3.4.2 General

Just after Figure E.7 it is stated that "The elastic-

plastic material model with strain hardening has

been applied in the analysis." Earlier in this

section it is stated that a linear-elastic material

model is used, ref. comment above. It is unclear

exactly where the elastic and the elastic-plastic

material model has been used.

Clarify


Finn to address


Annex E E.3.4.2 General

The Local Stress Max values in Table E.3 are not

found in the corresponding Figure E.8.

Correct Moved to WD6 Comments

Finn to address


Annex E Figure E.4 General

Sy and Su are incorrect. Change labels Sy and Su to "elastic ideal plastic"

and "elastic plastic with material hardening"

respectively.Accepted

click on figure, go to chart tools, see "example pipe 3" on

Excel spreadsheet, and update columns AD and AJ - will

need to resize the chart and legend


Annex F F Technical No mention of Flow Spool/Flow Head Added Flowhead Accepted Requirement is revised

Annex F F TechnicalNeed to clarify Subsea tree should this be SSTT? None

RejectedRequirement is clear

Annex I I.5.2.2.5 Technicalapproaching zero - lacks clarity Use acceptance standards per 6A & 17D

Acceptedleakage criteria is linked to annex 8 though I.5.3 (What

needs to be changed?? (Emailed Paul, 9/16)

Annex I I General

Must all test samples come from the actual

production string? For instance, if the connector

is machined from bar stock or forgings, could

the bar stock or forgings be used to perform the

external load testing, seal/ gasket testing, etc?

These samples would not include any welds

connecting the connection to the pipe body as

would be done in the production string, but

these samples would be able to be tested much

more easily. Having only test production order

samples to perform all of the testing would

mean that the production order would have to

to already been completed before testing could

even begin. This is not advantageous for the

manufacturer.

Allow the use of bar stock or forgings of the

same material, chemistry, grade, etc. into the

tests.

Rejected

Annex requirement is clear and consistent.

Annex I I General

If Annex I only covers qualification of connectors

(and welds between the connectors and pipe)

then there's no part of 17G which covers

qualification of the tubes.

Add some qualification of the tubes. Only reason

why this is brought up is because for drillpipe,

the mode of failure in fatigue testing most

oftenly occurs in the pipe rather than the

connection or weld

Rejected

Annex is clear and consistent. Tubular qualification is

addressed in Clause 6.24

Annex I I.1.2 GeneralDrillpipe, or rotary shouldered, connectors are

missing from the EXAMPLE

Add drillpipe or rotary shouldered connectors

into the EXAMPLERejected


Annex I I.2.3.1 General

Manufacturer may not fully understand end

user’s full scope of performance and

simultaneous loading so end user must play a

bigger role in the testing/ load schedules. A

connector could go through several load cycles

before leaking could occur, so it's critical that

the end user specifies more specific loading

sequencing rather than the just the final loads.

End user must be held accountable in their

specification of loading conditions to the

manufacturer/ testing facility, because

depending on the sequence of loading (i.e.

pressure before tension or tension before

pressure) there could be different results.

Rejected



Could seal/gasket testing and static load testing

be combined to have load, pressure,

temperature simultaneously? Also since the

riser string typically sees it's highest stress at the

top and bottom of the string, shouldn't these

two areas be highlighted within the load

schedule/ testing?

Combine the two test types for a load schedule

or test which combines bending, tension,

pressure, and temperature, because that's a

more accurate depiction of the actual loading

conditions of the string. For a reference of how

this load schedule/ test could look, see the load

schedule associated with ISO 13679 Cal III Series

A, B, or C. Although that specification is meant

only for casing and tubing, it could be modified

to accomodate all types of connectors.

Rejected

Annex requirement is intentional, clear and consistent.


Mimicking the load sequence during

qualification inherently asks the end user to

determine the loads for the manufacturer

because the manufacturer doesn’t know the

load sequence or intended use completely.

Need more end user input for load sequencing

and testingrejected

Annex requirement is clear and consistent. Reference

Annex D. Load sequence should be considered


Although Cal IV or III of ISO 13679 is used for

casing and tubing, the specification could maybe

be modified to test all connectors used within

the 17G.

ISO 13679 could be used as a baseline for a test

schedule instead of the seal/ gasket and static

load testsrejected

Annex requirement is intentional, clear and consistent.

13679 should be a reference

Annex I I.3.1 GeneralIndependent verification is required for what

parts?

The independent verification/ witnessing

statement is vague and needs to be more

specific

AcceptedWG will review and revise for clarity

Annex I I.3.2.2 Technical

Temperature range shall not exceed +/- 1.0% Maybe open up the percentage error for

temperature, because when using a

thermocouple, the two ends won't always be the

same distance apart when tacked into place on

the samples

Annex I I.3.3 Technical

Increase the scan rate for digital data systems Increase the scan rate from one every 15

seconds to at least one every 5 seconds. Big

changes in axial load and pressure can happen

very quickly so need a higher resolution on data

acquisition. Temperature can have lower

resolution but load, pressure, etc. needs higher

scan rate

Accepted

WD will review and clarify the Annex requirement

Annex I I.3.3 TechnicalChange pressure load rate Pressure load rate should be an actual pressure/

min. Ex. 15,000 psi/ min not stress rate increase AcceptedWD will review and clarify the Annex requirement


Each individual load type needs 5 mins to

gradually remove load or all loads combined

needs 5 mins?

Be more specific in unloading time

Accepted



Also, when the load needs to be removed over

the course of 5 minutes, what if the load is only

10 kips? That should take 5 minutes to remove

the load and so should removing a load of 2,000

kips.

Propose a max rate of removal in load

Accepted


Annex I I.3.4 General

It says that "for welded connectors strain gauges

shall be located at the girth weld…" What about

friction welds i.e. the welds on drillpipe risers?

Include friction welds and other types of welds

Accepted


Annex I I.3.4 TechnicalHow many gages and what type of gages at each

weld?

Specify number and types of gages at the weldsAccepted


Annex I I.3.6 TechnicalLoading sequencing could conflict with loading

explained in I.3.3

Use consistent loading sequencing throughout

Annex IAccepted



Says that the seal shall not be greased or

lubricated, what if the metal-to-metal seal is

part of the connection and always lubricated

with thread compound? What’s the difference

between greased, lubricated, and oiled? Oil is a

lubricant. What about thread compound?

Be more specific in the lubrication and areas of

lubrication. Metal to metal seals on casing and

rotary shouldered connections typically will

require thread compound in order to prevent

galling

Rejected

Annex requirement is clear and consistent


Need specifics as to what would be on the tick

off and sign off sheets. Who signs or ticks off on

procedure completion?

Provide an example sheet for tick off and sign off

boxes for individual procedures that requires

this verification. End user maybe should specify?


What’s considered “each step in the

procedure”? how specific?

Need more specifics on what's "each step" and

need a table provided in 17G. Each step to the

end user, manufacturer, and testing facility

could be considered different things. End user

maybe should specify?

Annex I I.4.3 TechnicalMinimum preload can't be +/- 5%. Inherently

incorrect

Correct to say minimum preload + %, can’t be

below minimum preloadAccepted


Annex I I-1 General

For make/break test, a) says that the connector

needs to demonstrate that it can be stabbed/

landed and made up in the field . This would

require the manufacturer or testing facility to

acquire field machines in order to determine

this criteria. Realistically, an Iron Roughneck or

power tongs will not be the machine used for

make and breaks at a testing facility. In order to

provided proper preload for a threaded

connector, the testing facility will probably use a

continuous turn or ratchet-style torque unit

Modify this purpose to include typical make and

break machines such as a continuous turn or

ratchet-style torque unit.

Accepted


Annex I I-1 Technical

For burst testing, typically the manufacturer

doesn't know if the connector can maintain a

pressure that's equal to or greater than the pipe

burst capacity without testing the connector.

Structurally it may stay together but the

manufacturer won't know if it would leak.

Make the burst testing required and test the

connector to 1.0 of the pipe burst capacity or to

a value that would be close to the pipe's burst

capacity. Inherently with this test, the connector

would have to be welded onto a stronger tube

or machined onto the end of bar stock or thick

walled tube that's of the same chemistry and

mechanical properties as the connector to be

used in the field

Accepted

WG to revise Table for clarity to include stabbed conditions

and wordng to include there be some verification of the

compressive force on the couplings

Annex I I.5.2.2.3 Editorial"The time specified for hold times shall be a

minimum." Not complete

Complete the sentenceAccepted


Annex I I.5.2.2.5 TechnicalWhat's the manufacturer's/ testing facility's

course of action if there's a leak during testing?

Need a contingency for if the sample leaks. Is the

test restarted or are changes required? AcceptedWD will review and clarify the Annex requirement

Annex I I.5.2.2.6 TechnicalWhat's the manufacturer's/ testing facility's

course of action if there's a leak during testing?

Need a contingency for if the sample leaks. Is the

test restarted or are changes required? AcceptedWD will review and clarify the Annex requirement


Check the Eq. 2 to ensure that it's correct. It

seems that the Rp,c and Rmax,test need to be

swopped. Also, throughout the spec, the letter

"p" has been used to denote pressure, why is it

"R" now? Confusing…

Check equation and change R to p

Accepted


Annex I I.5.2.5 GeneralWho specifies if testing will do the survival

fatigue testing or fatigue to failure testing?

Specify when survival and failure fatigue testing

are involved. When is one chosen over the

other? It's confusing

RejectedAnnex requirement is clear and consistent


Where does the M-N curve, or the calculated

fatigue capacity come from? Does it come from

the small scale testing mentioned in Annex C.6.2

NOTE 3?

Mention that the M-N curve can come from

small scale fatigue testing.Rejected


Annex I I.5.2.5 GeneralIs there only one acceptance criteria for survival

fatigue testing?

If so, then no need to letter a), but there should

be more than one acceptance criteria anyway

Annex I I.5.3 GeneralThe goal of each test isn't explicitly stated Each test needs a paragraph at the beginning of

its section providing a scope of why the testing is

being completed

RejectedAnnex requirement is clear and consistent


"Connectors shall be made-up using tools typical

of those in the field." That statement implies

that threaded connectors can only be made up

with iron roughnecks, power tongs, etc. These

types of tools are typically used in testing

facilities or by the manufacturer

Re-write the statement so that continuous turn

or ratchet-style torque units can be used to

perform make and breaks on these test samples

Accepted



Connection will be completely cleaned after

every break-out? Threaded connectors need to

have thread compound fully removed after each

break-out?

This doesn't necessarily happen in the field, so

no need to fully clean the surfaces of the

connection until that every 5th break-out for

photographs

Rejected


Annex I I.5.3.2 GeneralWho determines whether the connection needs

leak-tightness testing after every 5th break-out?

Specify who determines whether leak-tightness

testing is required after every 5th break-out RejectedAnnex requirement is clear and consistent

Annex I I.5.3.2 GeneralThe minimum make-break tests required for

temporary threaded connectors is 10. Does this

include threaded riser connectors?

Be more specific with the threaded connector

that's also a riser connector RejectedAnnex requirement is clear and consistent


If individual seals and then the complete seal

arrangement are to be tested, then if there are

2 seals that means there needs to be 3 tests? (1

test for the 1st seal, 1 test for the 2nd seal, and

a 3rd test for both seals) If so, for rotary

shouldered connections, the torque shoulder is

often considered a seal but it should not have a

pressure rating. For rotary shouldered

connections, should these shoulders be

bypassed to only test the seals that will have a

pressure rating?

Be more specific on the number of tests required

per the number of seals in the connection. Also,

be more specific on what constitutes as a seal

(aka a seal should have some sort of pressure

rating and that all other contacting surfaces

which may contain pressure but do not have a

pressure rating should be bypassed during

testing of the pressure rated seals)


Does it make a difference that the ISO 10423

Annex that's used for the seal/gasket test is an

Informative annex and not Normative?

Comment on the fact that it's an Informative

section, possiblyRejected



Is Seal/ Gasket Test only for installable metal-to-

metal seals or does it apply to metal-to-metal

seals that are machined into the connection i.e.

for casing and drillpipe connections?

Specify the type of metallic seals

Rejected



Do non-metallic seals that are only being used as

environmental seals (and are not meant to seal

against well fluids) still need to be tested to ISO

10423 F.1.13?

Specify that non-metallic seals which are not

meant to see or seal against well fluids only need

to be tested to ISO 10423 F.1.11 and not F.1.13Rejected



Without tension, compression, or bending

during this test, it does not seem to hold as

much merit as it could

Incorporate some tension, compression, or

benidng, because leaks might not occur until the

connection is under external load. Either modify

ISO 10423 F.1.11 or incorporate a some sort of

modified ISO 13679 Series C type load schedule

Rejected



The manufacturer doesn't know if the

connection can hold more pressure than the

pipe until the connection is tested.

Propose a change to weld/ machine the

connection onto a stronger pipe or bar in order

to test the connection to a pressure equal to 1.0

of the pipe burst pressure or to a high pressure

Accepted

WD will review and clarify the requirements in Table I-1


For the situation where the connector is

stronger than the pipe, in order to test the

connection, the connection would need to be

welded onto a pipe other than the pipe that

would be used for the actual riser string or it

would have to be machined onto the end of a

bar with sufficient bore back and turned down

OD but of the same chemistry as seen in the

production order. Does this mean that these

two methods would be the acceptable methods

for this test? In this case the actual pipe that

would be used in the string would not be tested

nor the weld

Specify methods in which the external load test

can be completed where the riser pipe and

possibly the weld connecting the riser to the

connection would not be tested. Additional

testing may come of this…

Rejected



The end user must specify if the load will be

tension or bending, because manufacturer does

not know the loading sequence that the

connection will see

Make it the end user's responsibility to specify

more detailed loads and load scheduleRejected


Annex I I.5.3.5 GeneralIt says that both tension and bending must be

performed, so no external load can’t just be one

or the other as previously stated

Fix the inconsistency between tension and/ or

bending to performed in the test RejectedAnnex requirement is clear and consistent


It says say that normal is 0.67Fd and extreme is

0.80Fd, but in 6.8.11.1 & 6.8.11.2 casing

connections and drillpipe connections both

specify normal is 0.50Ty and extreme is 0.60Ty.

Fix the design factor references due to the

specified design factors of casing and drillpipe

connections Accepted

Review for clarity against Clause 6

Annex I I.5.3.5 TechnicalWhat stress level is 0.10 fatigue damage

accrued? Low, medium, or high?

Specify which bending moment/ stress level to

be used for the fatigue damage prior to the load

testing

RejectedWG will review for clarity.


Is bending moment/ tension increased when the

pressure goes from Design pressure to Low

pressure during the Normal and Extreme cycles?

Specify what happens to the bending moment/

tension when pressure is decreased.Rejected

Annex requirement is clear and consistent. WG to consider

placing a NOTE for guidance.


Gow are temperature effects tested here? How

will the seals hold at higher temperatures? How

is the reduction in yield strength due to

temperature tested?

Basically, this load schedule needs to be more

thorough and extensive. Ex. See ISO 13679 Cal III

Series C for loading, cycling, temperature, etc.

for an example of an extensive load schedule. A

modified ISO 13679 load schedule could be a

good model going forward

Rejected



Where the test sequence explains to make-up

and perform hydrostatic pressure test, is that an

additional pressure test to I.5.3.1 or are they

one in the same?

Be more specific in the hydrostatic test in the

I.5.3.5 mentioned in the test sequenceRejected



f) needs better description. What is bending

moment 1? Where is bending moment 1 seen in

the load schedule see in Table I-2? Is the

bending moment capacity based on the

expected pipe failure point or is it based on the

connection failure point? “Cycle down to low

pressure and back?”

Reword and be more descriptive in the test

sequence of the I.5.3.5 test

Rejected


Annex I I.5.3.5 Technicalg) three additional cycles or a total of three

cycles?

Clarify the number of normal and extreme cycles

performed in the load scheduleRejected


Annex I I.5.3.5 Technicali) Fd does not equal 1.00 for drillpipe and casing

according to 6.8.11.1 & 6.8.11.2, it equals 0.75.

Fix the design factor references due to the

specified design factors of casing and drillpipe

connections

AcceptedReview for clarity against Clause 6 (design factors to be

deleted)

Annex I I.5.3.5 Technical j) 2-300psi Should say 200-300 psi Accepted WG to revise the requirement


Mean stress representative of the riser in

operation at what location? Who specifies the

mean stress and how it's applied? How does the

mean stress affect the expected fatigue life if

the M-N curve was based on samples that did

not have a mean stress during testing?

Need more description of where this mean

stress is in the riser string, who specifies the

mean stress, and how it will affect the fatigue

life, possibly Rejected

Clarification is provided in Annex C as stated in the

document


Are the fatigue to failure tests on small scale

samples as per the specs referenced in C.6.2

NOTE 3? If so, please reference. What if the

connection isn’t what fails in fatigue, but instead

the pipe? Ex. drillpipe typically has fatigue

failures in the pipe and not in the connector or

weld. Many joints from production would have

to be used to determine an M-N curve for the

failure location on the production pipe before

Annex I testing could even begin? It would also

be very expensive

Be more specific of how the M-N curve can be

generated using DNV-RP-C203 because that RP

references several methods. Reference small

scale testing to correlate back to stress

concentration at the expected fatigue failure

location in the string. Also, discuss what the

contingency is for riser strings where the fatigue

failure isn't expected to occur in the connection

or weld. Even though Annex I is "qualification of

connectors", this needs to be discussed

Rejected

WG will review for clarity referencing requirements in

Annex C

Annex I I.5.3.6 GeneralAre the fatigue to failure tests the same tests

reference in I.5.2.5?

Cite I.5.2.5 if soAccepted

WG to review and clarify


f) is the cyclic loading continued until 20% past

the expected fatigue life as mentioned in

I.5.2.5?

Cite I.5.2.5 if so

Accepted



Don’t need internal pressure to determine that

there is a fatigue crack in the sample. If the

strain gages are location on the sample and they

are anywhere near the fatigue crack location,

the strain gages will show that a crack has

developed.

Specify that real-time strain gage data can help

determine if a fatigue crack has occurred

Rejected



What if the connection, weld, and pipe are

qualified one time via Annex I and then the

connection, weld, and pipe are needed for

another end user, location, etc. but the loading,

temperature, and pressure are not as severe as

the original qualification? Do the connection,

weld, and pipe need to be qualified with these

less extreme loading conditions? Because in that

case, could the connection, weld, and pipe

complete Annex I testing one time at its

absolute peak capability so then it will be

qualified for all loading conditions within the

peak capability envelope?

Specify if the connection, weld, pipe, material

grades, etc are all tested one time to a very high

stress level and pass the qualification testing,

that the string does not have to be requalified to

if the string will be used for a less severe

application

Rejected



The wording in the 'EXAMPLE' may be

interpreted as structural and fatigue testing

shall be performed to failure, whereas

alternatives to testing to failure exists.

Rephrase

Rejected

Example is offered as a NOTE only


Wording of last paragraph has come out wrong.

It states that the replacement interval can be

twice the tested endurance of the gasket,

should be half the tested endurance.

Rephrased to be in line with equation (1) in same

subsection:

"Gaskets and seal rings may be reused if agreed

upon with the end-user. The replacement

interval of gaskets and seal rings should not be

more than one half of the number of successful

make-break tests before any leakage occurs."

Accepted

WG to review and revise requirement


The definition of factor 'c' is impresise and

incomplete. The definition is a fragment not a

sentence "c is the factor (...)."

The factor represents the DNV SN curve

providing a 2 standard deviation probability of

survival.

Rephrase with reference to probability of

survival of reference SN curve.

Accepted


Annex I I.5.5 GeneralSubsea replacement of seals should be included

as an alternative for batch completion. RejectedAnnex requirement is clear and consistent this is

qualification not operational

Annex I(I.5.9)

I.5.3.5General

Bullets a) through l) do not match Table I.2 Update bullets to reflect sequence in Table I.2Accepted



It is specified that 100 cycles to verify loosening

should be used. A design factor for this is

already presented in Table 7. Testing should

allow the manufacturer to select number of

cycles provided the design factor in Table 7 is

adherred to.

Accepted



Text is vague/unclear which specific tests are

associated with Annex K;

Current text: "SSTT latch testing shall comply

with the requirements in Annex K"

Add additional verbiage to clarify:

SSTT latch make/break testing shall comply with

the requirements in Annex K.

Rejected

Annex is clear and consistent

Annex J J.2.1 Editorial 17G is now a specification, not a proposal change proposal to specification

Annex J J.3.4.b Technical"after installation" needs a stipulation stating

this is only performed not to in danger well

operations.

after installation in a agreement with operations

risk assestment. RejectedRequirement is clear and consistent. Risk assessment is

covered in safety strategy

Annex J J.3.4 Technical

last paragraph in this section needs to be

removed or reworded because the operations

will not be on stand-by in an emergency

situation.

If a control station is not functional, then a risk

assestment with the operations shall be

conducted to identify contengency plans for

operations until the control station is operable

again.

Rejected

Requirement is clear and consistent. Language may be

modified to say "or required" within the requirement

Annex J J.5.2 Editorialfirst paragraph, reference to "subsection 11.3" I

could not locate. Check refernce numbers. acceptedComment in WD6 J.6.2 references now ok

Annex J J.1, Table General

There is no reference to the SSTT in the "Barrier

Implementation Table"

Suggestion to include SSTT and change the order

so that it reflects the order in which the barriers

would be placed in reality.

Rejected with

comment


See new proposed table J-1.

Annex J

Update crew drils and clarify the link with RP 96

, , controls performance to (Validation) to the

well control operaitons. … accepted


ray working with Tore on crew drills

Annex J J.1 Editorial

Recommend that we not use the term "leak"

unless we are talking about the ability to

physically observe some leakage. The term leak

test is frequently used, when we really mean a

pressure test and observe for a loos/gain in

pressure. Most of the time we are not "looking

for a leak."

First incidence is J.1 in the NOTE. Replace detect

leaks with verify integrity. This is also consistent

with the existing J.3.1

NOTE: Pressure testing is the periodic

application of pressure to verify integrity in a

well barrier, well barrier

element, or other objects that are designed to

confine pressurized fluids (i.e., liquid or gas). Rejected

Referenced comment is not a requirement.

Annex J J.2.1 Editorial

3rd paragraph. Reword last half of the sentence

for clarity. We should have no unacceptable

risks. Not say that we'll manage unacceptable

risks.

These systems shall be installed, maintained,

tested, and operated in a manner that ensures

safe well control

during well operations and to ensure there are

no unacceptable risks to personnel health and

safety and the environment.

Accepted

WG to revise and clarify the requirement

Annex J J.2.1 EditorialFourth paragraph, last sentence. Include "and

tested/verified" in addition to just identifiying

the barriers.

All barriers shall be identified and tested/verified

before commencing any well operation... AcceptedWG to revise and clarify the requirement

Annex J J.2.2.2 Technical

First paragraph after (b). Next to last sentence.

Not sure I understand, and therefore not sure I

agree, that the fluid barrier "cannot be included

in the list of testable barriers once well

intervention operations commence."

Fluid barriers are classic example of "inflow

tested." The well is continuosly monitored to

ensure it is not taking, or giving up, fluid. And

periodically, we do a "flow check" which is really

an "inlfow test" to ensure the hole stands full

and static.

Especially if you are running a system like Fig 3-

1, without a SSTT, fluid is the primary barrier.

Delete:

"...and cannot be included in the list of testable

barriers once well intervention operations

commence."

Accepted

WG to review and clarify the requirement.

Annex J J.2.2.3 Editorial

Second Paragraph. I don't think it is a "shall"

statement to have barrier schmatics. The

information can be convey satisfactorially with a

table. The schmatic are a big help, but are not

required to the level of "shall." Suggest using

should.

Suggest replacing shall with should.

"Well intervention barrier schematics should be

developed as a practical method…"Rejected

the requirement is clear and consistent

Annex J Table J-2 EditorialLet's not use the term BOP when talking about

"WL BOP" as for the next to last entry in the

table.

Change WL BOP to WL PCE. PCE is Pressure

Control Equipment and is more representative of

the equipment than BOP.

acceptedComment draft was sent out without change will amend

for final.

Annex J J.3.2 Editorial

As mentioned above, lets not use the term

"leak" unless looking for a leak.

(d) change leak to pressure:

" d) reasons for the performance of pressure

testing shall be in accordance with Annex J.3.5."

(g) delete word leak:

"acceptance criteria shall be in accordance with

Table J-3."

Accepted

WG to review and clarify requiremnt

Annex J J.3.2 General

The word "leakage" is accurate in paragraph 4

because we are looking for a leak as stated in

the last sentence.

I will recommend to use the term "deviation" for

table J-3 for consistency.

Add "or deviation":

"...provided that no detectable leakage or

deviation occurs during the specified pressure

hold periods of the test."

Rejected

The requirement is clear and consistent

Annex J J.3.2 EditorialBullet e) add specified by manufacturer "Typical cleanliness levels are SAE AS4059, Class

6B-F through Class 8B-F, but shall be specified by

the manufacturer."

AcceptedWG to review and clarify requirement

Annex J J.3.4 GeneralBullet d). I don't understand why we include

"and interventions" here.

delete "and interventions" and just say after

repairsAccepted

WG to review and clarify requirement

Annex J J.3>5 General

Title says :Pressure Testing," but first sentence

says, "Leak testing…"

In this case, we are, indeed, describing

PRESSURE testing. As mentioned above, let's

not call a pressure test a leak test.

Change first word of first sentence from "Leak"

to Pressure.

Pressure testing of well barriers or well barrier

elements shall be performed.

Accepted


Annex J J.3.5 Technical

Include "General Testing Considerations"

consistent with API 53, section 6.5.3.8

API 53 6.5.3.8 has 9 subparts. Recommend to

simply copy and past 6.5.3.8.1 - 6.5.3.8.6. These

are safety related topics for high pressure

testing.

Rejected

The requirement is clear and consistent. The WG will

review for revision.

Annex J J.3.5.1 Technical

Since I suggest eliminating J.3.5.1.1 (belwo),

then we should upgrade last sentence in

J.3.5.3.1

or by

:…both flow directions. If well control can be

maintained in the event of test failure of the

barrier being tested, then an inflow test or

negative pressure test may be considered.

Accepted


Annex J J.3.5.1.1 Technical

I'd recommend that the document not suggest

that the hydrostatic barrier is "disabled" in order

to test another barrier. I suggest we remove

this section and just go with the definition given

in J.3.5.1

Delete J.3.5.1.1 and just go with J.3.5.1 only

Accepted



Confusing leak test and pressure test. Suggest first sentence read:

"The high-pressure test shall as a minimum…"

And the last sentence read:

"During high-pressure testing, the test pressure

value…"

Accepted



Table J-3 uses a good term (deviation). Let's be

consistent and use it instead of leak in the text.

The first paragraph recommends a way to

identify physical leaks, so that is fine. But the

main purpose (as stated in the title to the

section) is PRESSURE test criteria.

First 2 sentences should read:

"The pressure test shall be conducted such that

pressure acceptance can be veried according to

Table J-3 and leaks can be identified. An

acceptable test shall be "no

detectable leak observed and no detectable

pressure deviation, unless specified otherwise."

Rejected

WG to review and clarify to ensure consistency throughout

the document


Sentence before table J-3 should be consistent

with the section title and not use "leak."

Sentences should read:

Pressure test acceptance criteria shall be in

accordance with Annex J.3 or in accordance with

national regulations.

Test pressure and test frequency shall be in

accordance with Table J-4.

Accepted


Annex J J-3 EditorialTitle should no read Leak Pressure, only

pressure

Chagne title to:

"Pressure Test Acceptance Criteria"Accepted


Annex J J-3 Editorial

Column 4 (Test Acceptance Criteria) should use

the term "deviation" as described in the

superscripts at the end of the table, not

"leakage."

Note that none of the guidance given at the end

of the table (superscripts) has any description of

what to look for as "leakage." This is fine. We

are doing a "Pressure Integrity Test" and the

parameters are give for such a test.

Change column 4 to read:

"No detectable deviation.

Rejected


Annex J J-3 Technical

Not sure I understand what all the references

are to these "inflow tests."

We have "small volumes" and "large volumes"

but use exactly the same text in columns 2 - 4?

If we are doing an inflow (or negative pressure)

test, then superscript 'c' about a "decreasing

trend" is completely wrong.

In addition, to suggest we only take 150 psi off

the SIWHP as sufficient contradicts the very first

statement of Clause J.3 "to pressure test to the

expected differential pressure in the

direction of flow..."

Just have one entry in column 1 for Inflow /

Negative Pressure Test. Column 2 is "Installed

barrier elements." Column 3 is " Test pressure

shall be to the expected differential pressure in

the direction of flow, or to a differential pressure

as near as practically attainable." With

superscript d. Time is 30 minutes minimum.

Column 4 is "No flow or no pressure buildup"

with superscript c.

Accepted

WG to review and clarify the requirement and table J.3


Remove reference to Straddle. No need to treat

a single equipment with a specific reference.

Remove the next to last 2 rows about

a"straddle." Accepted

WG to review and clarify the requirement and table J.3


Remove reference to row for "Inflow test for

final well handover." This is obvious that those

tests are to be done "according to requirements

for wells in operation." Let API 17G focus on the

"temporary equipment" used during the

intervention. Some other guidelines should

cover the permenent equipment left on the

well.

Remove the last row about "final well

handover."

Rejected

Agreed that this may be outside the scope - however WG

considers it to be needed for completeness and clarity.

Annex J J.3.5.1.1 Technical

As a result of my previous comments, I suggest

putting J.3.5.1.1 back in with the title changed to

"Inflow Testing and Negative Pressure Testing"

The guidelines listed below are intended to

provide guidance for the user to develop

detailed procedures for the barrier to be tested.

Inflow and negative test procedures will vary

depending on the barrier being tested and

wellbore conditions. Appropriate risk

assessment shall be completed before finalizing

the test procedure.

Rejected



Clean up some text in the "comments box" at

the end of the table.

Replace leak with pressure. The 3rd sentence

should read:

"...the initial pressure test of the BOP

components…"

The last sentence should use the same language

as previous table:

"In general, test acceptance criteria are "no

detectable deviation...".

accepted

Completed

Annex J J.2.2.2

Well barrier element design, selection, and

construction principles

f) its physical location and integrity status of the

well barrier element is known at all times when

such monitoring

is possible.

Section states "shear any tool that penetrates

the well barrier and seal the wellbore after

having sheared the tool"

This statement is missleading as it implies that a

CWOR system should be of shearing through a

tool which is not possible.

Please revise the statement to distinguish

between BOP and open water systems

Accepted


Annex J J.3.2

Pre-deployment deck test Clarify that para 5, e) refers to the control fluid.

Pervious points discuss procdution bore fluid

which may lead to confusion.

Proposed change - Revise statement as follows:

"Fluid cleanliness checks of control fluid shall be

conducted after adding fluid and at function test

times. Typical cleanliness levels are SAE AS4059,

Class 6B-F through Class 8B-F."

Accepted


Annex J J.3.4 Functional testing of well barriers Add additional bullet:

f) as required by the Safety Stragety, 4.13Rejected


Annex J J.5.1 Scope Please clarify who the 'responsible party' is Accepted WG to revise and clarify the requirement.

Annex K K Editorial Cross refence in annek K are incorrect Review and revise cross references Accepted All references corrected in redline

Annex K K.1 General

Introduction provides scope of testing covered

in Annex K (i.e. FAT and Qualification) and makes

reference to Subsection 8.9 for SIT. Suggest that

references to applicable sections for in-field

maintenance (10.5) and in-service barrier testing

(Annex J) requirements would be appropriate

here.

After "NOTE System Integration Testing (SIT) is

covered by Subsection 8.9" add further:

"NOTE Field Redress testing is covered by

Subsection 10.5"

and...

"NOTE Operational Testing Requirements are

covered by Annex J"

Accepted

Added to redline

Annex K K.2.5.1 Technical

In table K-1 distinction between requirements

for Safety Function Class and Normal Operation

Class is unclear and/or contradictory

e.g. Size - Section K.2.5.3 says scaling is allowed

for Normal Class but not for Safety Class - table

K-1 states the reverse. Columns appear to be

reversed

Review Table K-1 and reverse contents of Safety

Function and Normal Operation class columns to

be consistent with subsequent sections

referenced therein.

Accepted

Noted in redline


Table L. 1— Scaling rules for well control devices

Scaling rules mixed up for Normal and Safety

operation class?

Review and revise Table K-1

Accepted

Noted in redline


Table K-2: Rules for the effects of design change

for SSTTA

Design change rules mixed up for Normal and

Safety operation class? Incorrect references.

Review and revise Table K-2

Accepted

Noted in redline


Drift test procedure does not permit horizontal

orientation of valves being drifted. For longer

assemblies this may be impractical and limited

by available test facilities.

Change 3.3.2.a) to "Open the valve;"

Change 3.3.2.c) to "The drift shall pass freely

while being passed through the valve in both

directions;"

Rejected

Horizontal drifting requires pusher poles and does not

adequately mimic field conditions. Test facilities for

FAT/qualification should be able to suspend tools in

upright position.


K.3.3.4.c) implies that it is permissible to apply

close assist pressure during the seat test, at the

manufacturer's discretion. This is contrary to

Section 5 where, for example, 5.8.f) requires

that SSTT valves shall contain pressure from

below without the application of close assist

pressure.

Append K.3.3.4.c) with "NOTE Close assist

pressure may not be applied for upstream seat

tests of valves which are required to contain well

bore pressure without the application of control

line pressure, ref. Subsection 5"

Accepted

Point noted in redline to clarify that this only applies to

valves/directions designated as requiring close-assist

pressure (ie valves which are not used to comply with

section 5.8f)


K.3.3.5.e) does not prohibit the application of

close assist pressure during seat test on valves

which have a requirement to contain well bore

pressure from below without the application of

close assist pressure.

Append K.3.3.5.e) with "NOTE Close assist

pressure may not be applied for upstream seat

tests of valves which are required to contain well

bore pressure without the application of control

line pressure, ref. Subsection 5"

Accepted

Note added to start of procedure in redline

Annex K K.3.4 Technical

"The SSTT shall be tested with the valve bore

vertically disposed..." does not permit testing in

horizontal orientation. For longer assemblies

this may be impractical and limited by available

test facilities.

Delete K.3.4 paragraph 4

Rejected

Test facilities for FAT/qualification should be able to

suspend tools in upright position. Procedure does not

specify full SSTTA must be tested as one piece, so the

lengths involved are not unreasonable.


Pressure drop (the lesser of: 5% of test pressure

per hour or 500psi) is stated as an acceptance

criteria for the test. With gas as test medium,

this allows for significant volumetric leakage

within allowable pressure drop.

Table K-3 does not apply to non-room

temperature tests.

Throughout steps reference is made to ""if

leakage rate is greater than acceptance criteria

stated above" but it is not clear what this refers

to.

Likewise, it is stated "if body joint leakage is

detected... the test fails" however with gas as

test medium during a controlled temperature

test it is not practical to monitor for body joint

leakage within environmental chamber.

Clarify whether there are volumetric as well as

pressure based acceptance criteria for controlled

temperature test when gas is the test medium.

Rejected

Table K-3 title has been updated in redline to remove

"room temperature"

Due to difficulty achieving perfectly stable temperature in

large assemblies, and difficulty performing bubble

detection in environmental chambers, the pressure change

criteria for high/low testing are intentionally looser than

room temperature testing.

Likewise for post-shear testing -- the 5% pressure drop per

hour figure is deliberately permissive. The volumetric

leakage criteria of 30 cm3 per inch of valve bore is

mentioned elsewhere in Annex K.


K.3.5.9.c) it may be impractical to submerge a

valve which has been cooled to very low

temperatures without either freezing the liquid

in the test bath or transferring heat from the

valve assembly to the cooled fluid in the bath

and thus lowering the test temperature. I am

not aware of any test facilities with this

capability.

In K.3.5.9.c) remove: "submerge the valve in a

liquid bath such that detection of gas leakage

from body joints is possible."

Rejected

The design temperature range for SSTTs generally does

not extend below 32F, so an ice bath is suitable for this

purpose. Chilled glycol is available as an alternative for

extending the temperature range if desired.

Annex K K.3.5.11 General

Acceptance criteria are given for gas testing pre-

and post-cutting, however criterion for post-

cutting is pressure based. Should there be a

volumetric criterion also?

Note, point 2) contains "hydrostatic"

erroneously.

Consider inclusion of a volumetric acceptance

criterion for post-cutting tests.

Reword K.3.5.11.2) to remove "hydrostatic". Accepted

Replaced pressure-based criteria with volumetric criteria,

as agreed in 17G sub-committee workshop session

Annex K K.3.5.11 General

What are acceptance criteria for gas leakage

after cutting?

"Acceptance criteria across the cutting device

for gas testing pre- and post-cutting tests are:

1. Pre-Cutting: The equipment shall show no

visible leakage under the test pressure during

the 15-minute

holding period.

2. Post-Cutting: The hydrostatic shall be

acceptable if the pressure change observed on

the pressure

measuring device is less than 5% of the test

pressure or 3,45 MPa (500 psi), whichever is less

during

15-minute pressure-hold period."

Speciy acceptance criteria

Accepted

Replaced pressure-based criteria with volumetric criteria,

as agreed in 17G sub-committee workshop session

Annex K K.3.11 GeneralCutting test record

gas test missing?

Inlcude requirement for gas test recordAccepted

Replaced "liquid" with "gas" in redline

Annex K K3.5.10 TechnicalThese requirements latch/coupler debris testign

should also appy to the THRT / TH inerface

Change scope of section to include both SSTTA

Latch and THRT / TH RejectedTHRT/TH interface is out of scope for 17G. This would fall

under 6A

Annex K K3.5.17 Editorial 2nd paragraph, …well control devise.. change devise to device Accepted Noted in redline

Annex K K3.6b1 TechnicalRetainer valve is part of SSTTA, not SSTT per 17G change SSTT retainer valve to SSTTA retainer

valveAccepted

Noted in redline

Annex K K.2 Editorialmultiple areas of the text do not reference the

correct table. For example, in section K.2.2 Table

8 I could not find.

AcceptedReferenced corrected in redline

Annex K K.2.2.5 Editorial...the safety strategy for the system… reference

to Subsection 4.12 is for safety principle

...the safety principle for the system…Rejected

Reference to 4.12 was incorrect, should have been 4.13

Annex K K-1 Editorial

Is this figure an example or is it manditory

program which has to follow the order exactly?

After Latch & Coupling Test - do you have to

redress?

Rejected

No change specified in comment. The order is planned to

mimic representative field service conditions.

Annex K K.3.3.1 GeneralNeed to add statement that all testing are

performed in ambient temperature (60F - 90F) Rejected"ambient temperature" is to be defined by design load

cases, per section 6

Annex K

K.3.3.3,

K.3.3.4.e,

K3.3.5.d

Technicalneed to spell out how long do you monitor for

leakage.

montior for leakage for 5 minutes.Rejected

No section specified; can't tell what this is in reference to


5th paragraph of CFD analysis needs to be a

recommendation instead of a "shall" statement

because you call for a physical test to be

performed.

CFD modelling is only as good as the model

assumptions are because too many variables are

present.

A computational fluid dynamics (CFD) analysis

should be performed as a screening tool to assist

with optimization of the design and parameters.

Rejected

Intent is to use physical testing to validate/calibrate the

CFD model. Then the CFD model is used to extrapolate

physical test conditions outside the range of the test

facilities. This is required.

Annex KK.3.5.4

letter Editorial

Letter bullets references to Annexes and tables

are missing references.Accepted

References corrected in redline

Annex K

K.3.5.5.b,K.

3.5.5.d,K.3.

5.5.g,K.3.5.

Technicalneed to spell out how long do you monitor for

leakage.

montior for leakage for 5 minutes.Rejected


Annex KK.3.5.9.c,K.

3.5.9.gTechnical

need to spell out how long do you monitor for

leakage.

monitor for leakage for 5 minutes.Rejected


Annex K K Technical

Create an Equivilant to Table L.6 within Annex K

which shows the overall composition of tests to

conduct.

Rejected - SSTT

valves have

less diversity

than EDP/LRP

rams and all

have similar

requirements


Ask group? May want to break out cutter modules as

separate from valves

Minimal value added by table for SSTTs

Annex KK,1,5.xx/

ALLTechnical

Check Sand Testing Valve cycles between K & L

to insure valve cycle counts are same. (see

L.3.4.2.2)

correct for entire document

Accepted

check sand testing valve cycles on Annex L and update K

. Cycle counts do not match Annex L.

Corrected to match cycle counts to L.

Annex KAnnex K/

ALLGeneral











direction'

Accepted.

Test

procedures

are often

ambiguous.








Accepted to Change throughout doc and add to

definitions

Added notes that "upstream" refers to primary sealing

direction.

Annex KK.1.5.4 4th

paragraphTechnical

Direct hydraulic control to modest depths of

3000 ft may increase closing times to 30+

seconds. Test facilities may not be able to flow

at these rates that long. Closing a valve on clean

nitrogen in 3 seconds or 30 seconds has little

variance in valve performance.

Delete use of any orifice or state 3, 5 or 10

seconds closing time so test facility has sufficed

flow capacity. Accepted


Orifice plate references not included in latest draft

Annex KK.1.5.6 (l) &

(q)Technical

Failsafe close; Pressure to close & exhaust

pressure should mimic intended control system

design.

Add language to suitRejected -

control system

behavior is not

included in

sand slurry

testing


Purpose of test per WD5 section K.3.6.7 para 2 is to

demonstrate the ability of the valve to "open, close and

seal" -- timed performance with specific control system is

not necessary for qualification.

Referenced section does not exist in latest draft


Gas Testing text needs to be modified similar to

L.3.2.3

Zero gas leakage when new (FAT), with some

leakage tolerance after debris testing (akin to

API 6A Annex L)Rejected -

necessary info

is captured in

test

procedures


Phrase "unless otherwise noted" and test procedure

instructions capture testing requirement.

Gas test criteria have been clarified in latest draft redline

Annex KAnnex K/

ALLGeneral











direction'

Accepted.

Test

procedures

are often

ambiguous.








Accepted to Change throughout doc and add to

definitions

Notes made to clarify upstream/downstream

Annex K K.3.5 Technical

Figure K.7 requires overhaul to be relevant to

SSTTs (currently copy/paste from Annex L)

References to gate valves and actuator stems

should be struck and replaced with terms

appropriate to ball valves and flapper valves.Accepted


Joe to redo table. Need to define "no detectable leakage"

in main document definitions

Table wording fixed in redline

Annex K K Technical

Create an Equivilant to Table L.6 within Annex K

which shows the overall composition of tests to

conduct.

Rejected - SSTT

valves have

less diversity

than EDP/LRP

rams and all

have similar

requirements

Ask group? May want to break out cutter modules as

separate from valves

Duplicate with above

Annex K K.3.5.4 Editorial

10 seconds is not a resonable closure time and is

not consistent with API STD 53.

Use 30 seconds closure time to be consistent

with RP 53. The sentence after bullet 3 should

read:

"Unless specified otherwise, the maximum

closure time for a single well control device shall

not exceed

30 seconds."

Rejected

SSTT closure sequence timing is specified by end-user in

safety strategy. This has been noted throughout Annex K.

SSTTs must often complete primary well control function

(eg shearing) prior to execution of BOP shear ram closure,

and utilize much smaller operator piston volumes, so the

shorter closure time requirement is appropriate.

Annex K Title Editorial

The title of Annex K is misleading. It needs to

include a verb “Testing” as used in Annex L

Annex K

(normative)

Testing of subsea test tree assemblies and

associated accessories

Accepted

Submitted by Tony on 11/5 - Sent to Tech Writer on 11/5

(RC)


Need to change verbiage in NOTE, points at

section in Annex I that does not exist.

Correct to be more prescriptive on what tests

within Annex I should be performed.

Change "as-follows";

NOTE: The latch also comes under the

classification “connector” and therefore the

general philosophy of this document shall be

applied with regards to design by analysis (Annex

D) and verify by test (Annex I) for this type of

component. See Annex I for seal/gasket test,

static load test, and cyclic load test.

Accepted

Added to redline in markup

Annex L L.1 General

What is required design "validation" and how to

establish? Verification is OK when the

requirement are known.

Refer to clauses for relevant required design

validation. Also provide a guidance if the given

requirements are not sufficent for suitability for

intended use. Accepted

New definitions for equipment and system verification and

validation will included in the 6th WD. It is not possible to

provide a prescriptive list of validation criteria for all

equipment. A verification and validation basis shall be

established in accordance with clause 4.20. Tables in

Clause L.3.6 and L.3.5 give guidance on verification and

validation for EFAT and SIT.

Annex L L.2.2.1 Editorial Table reference in line 1 incorrect. Change to "Table 6-4" Accepted Already updated in API 17G WD5.2

Annex L L.2.2.2 Editorial Spelling error in line 3 "devises" Change to "devices" Accepted Marked up in API 17G WD5.2

Annex L L.2.2.2 Editorial

Paragraph following Table L-1 not required "For

open-water intervention systems, the

temperature ratings for valve and ram actuators

and non-metallic

sealing materials for ram elements are given in

Annex L.2.2.2."

Delete paragraph

Accepted

Already updated in API 17G WD5.2

Annex L L.2.2.3 Editorialcorrect table reference to 5-1 Nominal bore size and drift class of well control

devices should be selected from Table 5-1 or as

specified by the end user.

AcceptedAlready updated in API 17G WD5.2

Annex L L.3.2.3 Technical

2nd paragraph is in conflct with Table L-4.

States acceptable if no sustained bubbles are

observed, while Table lists "No detectable

leakage".

Refer to API 6A, Annex F.1.6.3 and Table F.1.

Explicity define alowable leakage rates.

Accepted

2nd para to be replaced with ""Gas leakage acceptance

criteria for gas pressure testing at room temperature,

during and on completion of each stage of qualification

testing shall be in accordance with Table L-4." and Table L-

4 shall refrence Clause 8.3.2.3 for accptance criteria.

Annex L L.2.2.3 Editorial Incorrect table reference Change to table 5-1 Accepted Already updated in API 17G WD5.2

Annex L L.2.2.5 EditorialIncorrect Section reference in second last

paragraph

Change from Subsection 4.12 to Subsection 4.13Accepted

Marked up in API 17G WD5.2

Annex L L.2.2.5 Editorial Incorrect Annex reference in last paragraph Change from M.1.2.30 to M.1.2.16 Accepted Marked up in API 17G WD5.2

Annex L L.2.2.7 Editorial

Final list split into "a)" & "b)", should be one

statement "a)"

a) shearing valves or rams in the production bore

of the WCP that allows for running of work-

strings and multiple strings of wireline and coiled

tubing.

Accepted



Shear valves for annulus access should be

adresses separatly. This is often forgotten in the

industry.

Set requirment for cut and seal. Space-out for

working string should be taken into account. Accepted

Space out is not with the scope og Annex L. This is an

opetational and WCP functional requirement. Item be as

been modfied with "any bore (e.g. annulus and

production)"


Table L-2 for fluid class normal operating

reference is made to L.2.5.6. This claus is missing

Include clause L.2.5.6

Accepted

Marked up in API 17G WD5.2L.2.4.6

The standard test fluid rating validated by the test product,

shall validate all products of the same product family and

material properties as the test product in accordance with

API 6A:2011 F.1.14.3.4

Annex L L.3.1 EditorialIncorrect subsection referenced in paragraph 1 Change from 4.19 to 4.20

AcceptedMarked up in API 17G WD5.2

Annex L L.3.1 TechnicalRetainer valve is often used as a lubcricator

valve. Dropped object testing should be

required.

Include dropped object test in Figure L-1.Accepted

Annex L L.3.2 TechnicalLeak direction requirments should be defined. Include a table of valves and rams where main

direction of sealing is shown. Some valves have

to seal from above.

RejectedUnidirectional and bidirectional sealing requirements are

specified in te detailed FAT and qualification procedures

Annex L L.3.2.1 EditorialIncorrect subsection referenced in paragraph 1 Change from 8.3.1.1 to 8.3.2.1






Annex L L.3.3.1 Editorial Spelling error in sentence 1 of paragraph 3 Change from assemble to assembled Accepted Marked up in API 17G WD5.2

Annex L L.3.3.2 EditorialIncorrect subsection number Change K.1.1.1 to L.3.3.2.10 and update all later

subsection numbers and references accordingly AcceptedAlready updated in API 17G WD5.2

Annex L L.3.3.2.1 Editorial

Table L-5 has missing references Add references as follows:

Actuator operational test: L.3.3.2.17

Hydraulic circuit pressure test: L.3.3.2.18

Actuator Seal Test: L.3.3.2.16

Hydraulic actuator compensation circuit test:

L.3.3.2.19

Accepted


Annex L L.3.3.2.1 EditorialTable L-5 has missing row Add row for "Actuator hydrostatic body test"

and apply subsection requirements to every

column as L.3.3.2.15

RejectedCross reference is included in Actuator colum

Annex L L.3.3.2.2 EditorialIncorrect subsection referenced in paragraph 1 Change from 5.3 to 5.2


Annex L L.3.3.2.6 Editorial Erroneous character (square) in "a), 10" Delete character Accepted Marked up in API 17G WD5.2

Annex L L.3.3.2.9 Editorial Erroneous character (square) in "a), 8" Delete character Accepted Marked up in API 17G WD5.2

Annex L L.3.4.1 Editorial Paragraph 2, ref missing Change to "Annex L" Accepted Marked up in API 17G WD5.2, Annex L.3.4

Annex L L.3.4.1 EditorialFigure numbering incorrect Correct numbering (numbering needs continued

from previous figures)Accepted


Annex L L.3.4.1 EditorialSpelling error in paragraph prior to Table L-6 Change "manufacture" to "manufacturer"


Annex L L.3.4.1 EditorialIncorrect subsection reference in table L-6 for

sand slurry testing

In every row for sand slurry, replace L.3.4.6.3

with L.3.4.6.4Accepted


Annex L L.3.4.1 EditorialError in "Figure L-2 Sand Class II and Class III

qualification tests"

Change in "Sand Service Class III Test" flow

diagram wording in first process box from "As

class III test" to "As class II test"

AcceptedNow Figure L-7

Annex L L.3.4.6.1 EditorialTable L-7: Requirements for "Low-pressure seat

test at minimum rated temperature" are

inconsistent with rest of table

delete " at mimimum rated temperature" Marked up in API 17G WD5.2

Annex L L.3.4.6.1 EditorialTable L-7: Subsection reference in "c" at end of

table incorrect

Change from "F.2.2.2.1" to "F.2.2.2.2.1"Accepted


Annex L L.3.4.6.1 EditorialTable L-7: notes at end, lettered list should not

have "d". Content is subset of "c".

Delete lettering "d" whilst retaining content and

format accordinglyAccepted


Annex L L.3.4.6.5 EditorialProcedure step "v)" has incorrect sub-section

reference

Change "L.3.3.2.8" to "L.3.3.2.9"Accepted


Annex L L.3.4.6.6 EditorialProcedure step "v)" has incorrect sub-section

reference

Change "L.3.3.2.8" to "L.3.3.2.9"Accepted


Annex L L.3.4.6.8 Technical

Understand the rationale stated in this section

but the number of cycles seems excessive and

seems to assume no redress/repair within the

certification period. Can the increased

endurance hours be achieved in practice, i.e. is

this practical?

There is no clear instruction on which endurance

cycling is the requirement, with or without

safety factor. The alternative proposal is to

make the non-factored values the standard

minimum value for endurance cycling and to

make the safety-factored values optional. The

rationale for this is that the non-factored values

represent an improvement over 17D therefore

providing a greater level of confidence than

existing values without being overly onerous. It

should be up to the manufacturer or enduser to

decide if the safety factored approach is

necessary, we do agree with having an approach

identified in the standard for this but it should

be clear that this is optional.

Accepted

Safety factor and reference to API 17N has been removed.

Annex L L.3.4.6.8 Technical

Table 25. Normative requirement to life time

(endurance) is not pratical as life time relaibility

modesl are not well estblished and API 17 N

Annex D is an over simplification

Annex L to specify the minimum number of

cycles for temporary applications. Actual life will

depend on the inspection/redress frequency.

Actual cycles should be monitored and

compared with qualification cycles to provide

input for inspection planning.

Accepted


Annex L Table L-10 TechnicalNumber of cycles required for Pipe rams, pipe

slip rams & slip rams is the same with and

without the safety factor

Change to 700 cycles to include safety factorAccepted


Annex L Table L-10 Technical

The requirement is not clear regarding safety

factor. Is the minimum requirement with or

without safety factor? Both rows state

"Minimum number of required…" Footnote

states that other confidence levels can be

chosen which will change the SF.

Delete "minimum" in 2nd row. Replace with

"Example: Number of required endurance cycles

with safety factor based on 90% confidence

level". If this was the intent. Manufacturer

needs to know

Accepted


Annex L L.3.4.6.9 EditorialIncorrect subsection referenced in dynamic fluid

closure test, process step l

Change from 8.3.1.2 to 8.3.2.2Accepted

'Marked up in API 17G WD5.2

Annex L L.3.4.6.9 EditorialIncorrect subsection referenced in dynamic gas

closure test, process step j

Change from 8.3.1.3 to 8.3.2.3Accepted


Annex L L.3.4.7.5 EditorialSection "a)", reference to Table L-7 incorrect Change to Table L-1


Annex L L.3.4.7.6 Editorial Spelling error in paragraph 1 Change "devises" to "devices" Accepted 'Marked up in API 17G WD5.2

Annex L L.3.4.7.2 EditorialAdd requirement for tensile test properties in

line with test procedure below)

Reword "h)" by inserting ", ultimate tensile

strength" after yield strengthAccepted


Annex L L.3.4.7.8 EditorialIncorrect subsection reference in last

paragraph/number lst

Change L.3.3.2.7 to L.3.3.2.5Accepted


Annex L L.3.5.1 EditorialIncorrect sub-section reference in paragraph 2 Change 4.19 to 4.20

Accepted'Marked up in API 17G WD5.2

Annex L L.3.5.2.3 EditorialIncorrect sub-section reference in paragraph 2 Change 5.12.1 to 5.21.1

Accepted'Marked up in API 17G WD5.2

Annex L L.3.5.2.3 Editorial Incorrect Annex reference in paragraph 2 Change D.12 to D.1.2 Accepted 'Marked up in API 17G WD5.2

Annex L L.3.5.2.9 EditorialIncorrect reference in "c)" Delete "c)" which is located at en of first

sentence in "c)"Accepted


Annex L L.3.5.2.10 Editorial

Correct spelling of Disconnect: Discount testing

with combined bending and tension loads in

accordance with Subsection 5.5.19 k) shall be

performed prior to performing this

disconnect/reconnect test.

Disconnect testing with combined bending and

tension loads in accordance with Subsection

5.5.19 k) shall be performed prior to performing

this disconnect/reconnect test.

Accepted


Annex L L.3.5.2.10 Editorial Incorrect reference in paragraph 2 Change 5.5.19 k) to 5.19 Accepted Marked up in API 17G WD5.2

Annex L L.3.5.2.10 Editorial Spelling error in paragraph 2 Change discount to disconnect Accepted Marked up in API 17G WD5.2

Annex L L.3.5.2.13 Editorial Incorrect API reference Change 17N to 17H Accepted Marked up in API 17G WD5.2

Annex L L.3.6.1 EditorialIncorrect subsection reference in paragraph 3 Change 4.19 to 4.20


Annex L L.3.6.2.2 Editorial Incorrect Annex reference in f) Change from M.4.4.3 to M.4.4.2.2 Accepted Marked up in API 17G WD5.2

Annex L L.3.6.2.2 Editorial Incorrect Annex reference in g) Change from M.1.3.11 to M.1.2.16 Accepted Marked up in API 17G WD5.2

Annex L L.3.6.2.2 Editorial Incorrect Annex reference in g) Change from M.1.3.15 to M.1.2.16 Accepted Marked up in API 17G WD5.2

Annex L L.3.6.2.2 Editorial Incorrect Annex reference in h) Change from M.1.2.25 to M.1.3.24 Accepted Marked up in API 17G WD5.2

Annex L L.3.6.2.4 Editorial Incorrect figure referenced Change from Figure 5-15 to Figure 5-5 Accepted Marked up in API 17G WD5.2

Annex L L.3.6.2.5 Editorial Incorrect Annex referenced in NOTE Change from M.1.3.16 to M.1.2.17 Accepted Marked up in API 17G WD5.2

Annex L L.3.6.2.5 EditorialIncorrect Annex referenced in numbered list

item 1) & 2)

Change from M.1.3.15 to M.1.2.16Accepted



item 3)




item 4)



Annex L L.3.6.2.5 EditorialIncorrect Annex referenced in bullet list on page

610

Change M.1.3.21 to M.1.2.21Accepted



610




610

Change from M.2.4.2.1 to M.4.4.2.2Accepted


Annex L L.3.6.2.5 EditorialIncorrect Annex referenced in 2nd last

paragraph



Annex L L.3.6.2.5 EditorialIncorrect Annex referenced in last paragraph Change from M.1.3.15 to M.1.2.16


Annex L L.4.3 Editorialk) is incorrect, it should be continuation of j) not

new item

Correct as requiredAccepted

Annex LL.3.4.6.9

section h)

can't stabilize gas flow due to working with a

finite gas volume

strike "Stabilize the gas flow test rate??"

sentence.Rejected

satbilisation of gas is not specified in WD5.2 of API 17G for

the dydnamic closure test only for liquid part of the

procedure (i.e. stabilisation liquid flow raste not gas)

Annex L L.2.2.3 Editorial Incorrect table reference Change to table 5-1 Accepted Already updated in API 17G WD5.2

Annex L L.3.4.1 EditorialError in "Figure L-2 Sand Class II and Class III

qualification tests"

Change in "Sand Service Class III Test" flow

diagram wording in first process box from "As

class III test" to "As class II test"

Acceptedsame as comment above

Annex L L.3.4.7.8 EditorialIncorrect subsection reference in last

paragraph/number lst

Change L.3.3.2.7 to L.3.3.2.5Accepted


Annex L L.3.5.2.10 Editorial Spelling error in paragraph 2 Change discount to disconnect Accepted Marked up in API 17G WD5.2

Annex L L.3.2.1 Generalcontains a reference to non-existing subsection

8.3.1.1Accepted


Annex M M EditorialMCP is used instead of MCS. Change MCP to MCS.

AcceptedChange all MCP to MCS. Make sure the reference is

appropriate in context

Annex M M.1.1 General

There is also a third system solution to All-

hydraulic and electro-hydraulic which is All-

electric system. This is a system with no

hydraulic in umbilical but with subsea pumps,

reservoir etc located in the subsea stack. This

should also be covered in this chapter. A short

decription of the three is missing and a detailed

decription of the all-electric

Add new section after section 1:

There typical three IWOCS systems solutions:

1. All-hydraulic: All subsea hydraulic functions

direct controlled from topside (Only hydraulic

hoses in umbilical)

2. Electro-hydraulic: Subsea hydraulic functions

mainly controlled by subsea control module

(Hydraulic hoses, power and interface cables in

umbilical)

3. All-Electric: All subsea function controlled

from subsea control module together with

subsea pumps and reservoir (Only power and

communication cables in umbilical)

Selecting the right IWOCS solution depends on

parameters like cost, water depth, system

flexibility and response time.

Rejected

First sentence has been changed to the following with

comments provided.

"Multiple aspects like economics, technical solutions and

system operation dictate whether to choose an all-

hydraulic or electro-hydraulic system. "

Annex MM 1.1

Section 3General

Section 3:

Project economics i not the only one dictating

whether to choose AH or EH system, but also

operational and technical requirements like

responce time, number of function (umbilical

size) water depth etc.. It is not not given that a

DH system always is cheaper.

Section 2 add sheapest in the first sentence:

.... are generally the least complicated, sheapest

and the most reliable subsea ....

Section 3 delete first sentence:

Project economics dictate whether .... Rejected

Agreed with comment however first sentence reworded to

" " as stated in line 443

Annex M M.1.1 Technical

The statement in second paragraph about

reliability is not correct and should be deleted.

Correction:

Direct hydraulic systems are generally the least

complicated subsea control system, but they

have a limited capacity for sequenced and logic

automation of functions.

Rejected

Agreed with comment however first sentence reworded to

" " as stated in line 443

Annex M

M.1.1

Paragraph

3

Technical

The first sentence in paragraph is not correct

and should be corrected.

Correction:

Multiple aspects like economics, technical

solutions and system operation dictate whether

to choose an all-hydraulic or electro-hydraulic

system.

Accepted

"New Text for second paragraph:

""Multiple aspects like economics, technical solutions and


hydraulic, electro-hydraulic or all electric system. All

hydraulic systems typically are relatively slow to respond,

compared to electro-hydraulic or all electric systems, and

have limited capability for providing data telemetry from

the subsea system. Electro-hydraulic or all electric systems

also enables sequencing and logic automation of system

functions such that the operator can focus on operational

aspects more than focusing on detailed system monitoring

and control. The specific needs of each application should

be carefully considered, particularly with respect to data

needs and speed of response."""

Annex M

M.1.1

Paragraph

3

Technical

Add important aspect when choosing EH-

systems.

Add sentence:

... data-telemetry devices. This system design

also enable sequencing and logic automation of

system functions such that the operator can

focus on operational aspect more than focusing

on detailed system monitoring and control.

Electrohydraulic systems are ...

Accepted

"Accept in principle. New paragragh 3 text:

Paragragh 3 to be deleted and this additional changed

added to the second paragrgh. Refer to line 443"

Annex M

M.1.1

Paragraph

8

Technical

Last sentence need to include human error

aspects as an factor when select system

architecture.

Correction:

Based upon a variety of risk factors highlighted

in the Safety Strategy, including how system

design affects the probability for human error,

should prevail when selecting of one system

over the other.

Rejected

Not a Technical Comment. Annex is clear and consistent.

Annex M

M.1.1

Paragraph

10

Technical

Add equipment examples in first sentence after

table.

Correction:

An intervention workover control system can be

direct-hydraulic consisting of a HPU, reeler and

umbilical or a complete electro-hydraulic (E-H)

system, composed of Operator station, HPU,

hydraulic distribution unit, reel, umbilical, and

subsea distribution.Accepted

New text "An intervention workover control system can be

direct-hydraulic consisting of a HPU, reeler and umbilical or

a complete electro-hydraulic (E-H) system, composed of

operator station, HPU, hydraulic distribution unit, reel,

umbilical, and subsea distribution. Regardless of the scale

of the system, the functionality can be broken down into

sub systems which correspond with the structure of this

document and shall be used as a reference for system

design. The major subsystems are as follows:"

Annex MM 1.1

Table M-2General

Add relevant products under Surface Power

Generation.

Add:

- Subsea Power & Communication Unit (SPCU)

- Alternator Rejected

There is no subsection of this name in the document to

add here.

Annex MM 1.1

Table M-2General

Add relevant products under Distribution. Add:

- Hydraulic Distribution Unit (HDU)

- Reel Deck Jumper

RejectedThere is no subsection of this name in the document to

add here.

Annex MM.1.1

Table M-2General

Correct name on sub-system Subsea Power

Accumulation and add relevant product.

Correct:

Correct name to Subsea Power Generation and

add Subsea Electric Systems

RejectedRefer to line 519, tile now ""Subsea Hydraulic Power

Generation and Storage"

Annex MM.1.1

Table M-2General

Add relevant product under Subsea Power

Storage and establish name consistency Subsea

Power Storage vs. Subsea Power Accumulation

throughout the document.

Add:

Subsea Uninterruptible Power SupplyRejected

"Refer to line 519, tile now """"Subsea Hydraulic Power

Generation and Storage""

Subsea Uninterruptible Power Supply is not added as there

is no subsection of this name"

Annex M M.1.1 EditorialDelete text after table M-2 since this duplicates

table and text higher up.

Delete text between table and next section.Accepted

Delete text

Annex M M.1.1.1 Technical

Add clarity to requirement. Correct:

The thru/BOP-riser intervention mode system

shall provide the means to control all functions

on the subsea test tree assembly, tubing hanger

running tool, and completion hardware including

subsea tree system during the following phases

and operations:

Accepted

New text "The thru/BOP-riser intervention mode system

shall provide the means to control all functions on the

subsea test tree assembly, tubing hanger running tool, and

completion hardware including subsea tree system during

the following phases and operations."


Add clarity to system differences. Add sentence after first paragraph sentence:

Electro-hydraulic control system also enables

predefined functional logic, while direct

hydraulic systems often require the operator to

manually process and execute the same

functional logic.

Rejected

"Paragraph after the bullet should now read:

""Dependent upon the required speed of subsea valve/ram

actuation and risk assessment considerations either a

direct hydraulic control system or electro-hydraulic control

system should be selected as the intervention and

workover control system. An Electro-hydraulic control

system enables predefined functional logic, while direct

hydraulic systems often require the operator to manually

process and execute the same functional logic. This

selection process is clearly defined as part of the Safety

Strategy; clause 4.12."""

Annex M M.1.2.1 TechnicalApply consistency. Correct:

k) PSD/ESD/EQD sequences and timing;Accepted

add "PSD" to k)

Annex M

M.1.2.2

Paragraph

1

Technical

Delete first sentence since this is an open

requirement that adds no value.

Delete first sentence.

Accepted

New Text for 1st Paragraph

"The IWOCS basic system design shall allow for full

functionality of envisioned existing infrastructure and

intervention scenarios. The following elements shall be

considered during system engineering:"

Also add

"l) ROV Interfaces

m) control fluid & process fluids compatibility"

Annex M

M.1.2.2

Paragraph

1

Technical

The term "consider" is used in multiple locations

throughout the document. A requirement to

concider something can be justified regardless

what has been done and is as such an open

requiremement that adds no value to the

document. As a minimum the term should be

followed by a requirement to justify and

document the outcome of a consideration.

Add the following definition of "consider" in

section 3.1

consider

or any gramatical variation of it shall be

understood as a requirement to also justify and

document the outcome of a consideration

or

correct the use of consider throughout the

document.

Accepted

"The changes per word document.

Affects, M1.2.6, M1.2.8, "

Annex M M.1.2.10 TechnicalApply consistency. Add to item b)

... conditions requiring PSD, ESD or EQDs;Accepted

add "PSD" to b)


Loss of control station can be just as critical as

loss of power.

Add requirement for contingency control, ref.

comment to M.1.2.18.

Correct:

The IWOCS shall be designed to render the well

intervention packages to a fail-safe status upon

loss of power and/or operator control. Upon

restoration of power and operator control, the

fail-safe status shall not be effected or changed.Accepted

WG to revise Annex requirements. Accept in principle

however it does not have to be all electric system to be

affect by loss of electrical.

Next Text:

"The IWOCS shall be designed to render the well

intervention packages to a fail-safe status upon loss of

hydraulic or electrical power and/or operator control.

Upon restoration of power and/or operator control, the

fail-safe status shall not be affected or changed."

Annex M

M.1.2.15

Paragraph

1

Technical

Add more clarity to requirement. Correct:

... push buttons. In the case of interlocks,

justified and documented considerations shall be

given to the possibility of overriding these

interlocks at any time. In general, most

interlocks should be possible to override.

Accepted

New text after ….push Buttons. "In the case of interlocks,

justified and documented considerations shall be given to

the possibility of overriding these interlocks at any time. In

general, most interlocks should be possible to override."

Annex M

M.1.2.16

Paragraph

3

Technical

Add clarity. Correct:

The safe state for each safety function in the

different operational modes shall be determined

and specified in a safety requirements

specification by the end user. Safety-related

functions shall as far as practically possible be

independent to non-safety functions such that a

failure in non-safety systems shall not adversely

affect intended safety functions. A further aim

shall be independence between the different

safety functions. The safety strategy shall govern

and define how much of the safety function's

functional chain that shall be independent, e.g.

independent control valves and upstream

functional elements but common final functional

element like a valve, ram or connector.

Accepted

WG to determine the placement of the proposed change

within 17G. Proposed intent is accepted. WG to revise and

clarify the Annex. Add additional text

Annex M

M.1.2.16

Paragraph

4

Editorial

Correct grammar. Correct:

This can be achieved in the form of safety

integrity levels (SILs).Accepted

New Text "This can be achieved in the form of safety

integrity levels (SILs) or any other equivalent method. "

Annex M M1.2.18 Technical

Delete this section because it is redundant to

section M.1.2.12 Fail-safe philosophy.

Requirement for restoring the system is

proposed added to M.1.2.12.

Delete entire section and included the following

into Clause M.1.2.12 "Upon restoration of

power, the fail-safe status shall not be effected

or changed."

Accepted

This section is for contingency where the system can

establish safe state.


Add clarity to requirement. Add after last sentence:

If the response time verification is done in

atmospheric pressure (i.e. on land) the test

results shall be verified against

calculation/simulation with atmospheric

pressure as ambient. Based on actual test data a

calibration or update of the

calculation/simulation model shall be done, test

cases shall be re-established and validated

against the project's requirements for response

times.

Accepted

"Agree in Principle. New Text for entire section:

""Response time testing using actual equipment shall be

carried out to ensure that the response time projected for

the control system meets the system objectives. This can

be conducted as part of system integration testing, or

standalone tests. The actual response time shall be

validated against the projected response time in M.1.2.22,

if carried out.

If the response time verification is done in atmospheric

pressure (i.e. on surface) the test results shall be verified

against calculation/simulation with atmospheric pressure

as ambient. Based on actual test data a calibration or

update of the calculation/simulation model shall be done

and validated against the project's requirements for

response times."""

Annex MM.1.3.1

item f)Technical

Avoid technology limiting formulations. Correct:

f) control module; the control module may be

split in two or more physical units where the

method of control typically may be piloted-

hydraulic hydraulic, electro-hydraulic or electric

control system, the control module is the unit

that, upon command from the MCS, directs

hydraulic fluid or any other energy carrier to

operate subsea functions.

Accepted

"Agree in Principle. New Test for f)

""control module; may be split in two or more physical

units where the method of control typically may be piloted-

hydraulic, electro-hydraulic or electric control system, the

control module , upon command from the MCS, directs

hydraulic fluid or other means of energy to operate subsea

functions. In an electro-hydraulic or electric system, the

control module also gathers information and transmits the

information to the topside facility"""


The list on page 609 does not match figure M.1

and Table M.2

Update list, figure and table.

Rejected

"Table M.2 should be as per the section titles.

No list on page 609 and Fig M.1 has been marked up on

other comments"

Annex M M.2 General

Design Clause for Surface Software states TBA Update.

Accepted

"Accept in principle, however this should be one section

for all software.

Create new Section M.4 With the information in the

M4.4.1.3 with a title Surafce / Subsea software"

Annex M M.1.3 TechnicalThe list should contain requirements about

uptime and spouriosly EQD

Add: System uptime and spouriosly shut down

requirementsRejected

This is covered in M.1.2.1

Annex M M.1.3.1 General

The meaning of this chapter is unclear. It lists

flexibility areas (as electrical load), operational

optimization (as downhole chemical injection)

but also qualification erquirements (as

robustness, water ingress and material

compability). And there is a lot missing like XT

hydraulic / electric interface, rig interface etc..

Split this chapter into one flexibility and one

optimization chapter, and clearly define what

within this areas that should be considered

during system engineering, and the focus should

be on what gives the operator/costumer

operational flexbility and optimization. OR this

section could be deleted.

Rejected

Refer to As per API 17G WD6 Ballot 10_3_13 line 455. &

API 17G WD6 Ballot 10_14_13 line 173 for comments to

this section.

Annex M M.1.3.11 Technical, this is achieved by bleeding off hydraulic supply

pressure. SSTT close assist need applied

pressure in shutdown.

Change to; this is achieved by bleeding off or

adding supply pressure. RejectedCan not find the comment in WD5.2.

Annex M M.1.3.14 Editorial

It shall only be possible to operate the

equipment from one site at any one point in

time. This line is under a part describing

shutdown panels, but I think it referes to MCP -

RCP.

Clarify.

Accepted

"The text is in securing measures. Site to be changed to

location. Added to ensure if multiple operationg systems

are used then one is the master.

New Text.""With the exception of PSD, ESD, and EQD

functionality, it shall only be possible to operate the

equipment from one location at any one point in time. """

Annex M M.2.3 TechnicalList I missing interface for info received on the

rig PA system.

Update.Rejected

Annex M M.2.4.1.1 Editorial

Top text says: Topside Electronic Module (TEM).

First column says topside electric unit, and next

collum says communication unit. If this is the

same part, it would be good to use the same

name.

Update.

Accepted

New Text" The following electronic module parameters

against the subsea located unit should be monitored by

the MCS.

Annex M M.2.4.1.1 Technical


The following communication unit parameters

against the subsea located unit should be

monitored by the MCS:

1. input voltage to subsea located unit(s);

2. input current to subsea located unit(s);

3. applied umbilical voltages/currents;

4. line/wire insulation (optional).

Accepted

"New Text:

The following electronic module parameters against the

subsea located unit should be monitored by the MCS:

1. input voltage to subsea located unit(s);

2. input current to subsea located unit(s);

3. applied umbilical voltages/currents;

4. line/wire insulation (optional).

"

Annex M M 2.4.1.6 f) EditorialMaster Control Panel Change to Master Control Station

AcceptedNew Text "flanged high level switch connected to the

Master Control Station"

Annex MM.2.4.1.6

item f)Technical


f) flanged high level switch connected to the

Master Control Panel



Annex M

M.2.4.2.1

Paragraph

1

Technical


The hydraulic power unit shall include redundant

pumps, high and low pressure accumulators,

supply and return tanks, flushing/filtering

facilities, and local control/alarm panel. Accepted

"Flushing/filtering should also be removed for clarity as

clause M.1.2.28 allows this to be a separate unit.

New Text in 1st paragragh ""The hydraulic power unit shall

include redundant pumps, high and low pressure

accumulators, supply and return tanks and local

control/alarm panel. Flushing/filtering facilities shall be as

per M.1.2.28."""

Annex M M 2.4.1.6 f) EditorialMaster Control Panel Change to Master Control Station




Unitended operation of connectors during

running shall not be possible. We need to run

these functions during operation, so an

unintended operation will still be possible.

Unintended operation of connector during

running shall be prevented by adding satety

rated functions such as…Accepted

not sure the revision of document reviewed as current

wording is "Unintended operation of safety critical

functions during running shall not be possible. Safety rated

functions such as unlatch shall be protected by interlocks,

protective covers, or isolation of the dedicated control

lines."


The MCP shall consist of the following sub items:

topside Electronics Module, subsea Power Unit,

subsea Communications Unit. This is unknown

names to me. Is it TEM, UPS and SPCU?

Need to clearify.

Accepted

Communications unit has been removed. Electronics

module is detailed above 2.4.1.2 and the power unit is the

HPU.


Info missing. Add: Failure on one panel shall not influence the

possibility to activate shutdown from the other

panels. Rejected

This is already covered in the existing text "

Disconnect/Failure on one panel shall not influence the

possibility to activate shutdown from the other panels."

Annex M M.2.4.1.6 TechnicalIt is stated that the gass tank shall be gas tight.

On our tanks we have a air filter and gas sensor.

Consider an update.Rejected

This was removed in WD 5, current WD 5.2 has reworded

this per previously submitted comments.


reservoir drain pump connected to the hydraulic

power unit motor starter. We have an air driven

pump that is operated on the dirty drain tank.

This is field proven.

Remove this line.

Rejected



Annex M M.2.4.1.6 General

After M.2.4.1.6 there is missing a chapter

adressing the topside software.

Update.

Accepted

"Accept in principle, however this should be one section

for all software.

Create new Section M.4 With the information in the

M4.4.1.3 with a title Surafce / Subsea software"


The same type of fittings shall be used for each

pressure class throughout the system. Unclear

what is ment be type. Pressure rating,

manufacturer, threads?

Clarify.

Accepted

"This was removed in WD 5, current WD 5.2 has reworded

this.This was removed in WD 5, current WD 5.2 has

reworded this per previously submitted comments.

Please note type is manufacturer i.e. swagelock, Autoclave

etc as well as connection i.e. MP, HP, NPT etc"


All other monitiring points if equipped should be

controlled by the MCP and should be sent via

dual communication link to the MCP. I find the

text unclear.

Clairfy.

Rejected



Annex M

M 2.4.2.1

Section: If

the

IWOCS…

Technical

This section asks for a volume of 1 hour. This will

produce discussions. Also it is not clearly stated

that this volume is in addition to the required

closing volume.

Increase the safety factor on the open and close

calculations to 28% or 30%. Delete the 1 hour

part. If 1 hour statement is kept, clearifie that

the 1 hous is an additional volume.

Rejected

The 1 hour is stated such that upon loss hydraulic power

there requires to be enough time to estabish the required

barriers, taking into account any loss of fluid due to system

design

Annex M

M 2.4.2.1

Section: In

the case...

Technical

Unclear: , the HPU shall be able to bleed down

hydraulic power to subsea.

, the subsea hydraulic power supply shall be bled

of at the HPU.Accepted

new Text "In the case of bleeding down hydraulic pressure

as part of a function, the HPU shall be able to bleed down

the subsea hydraulic power supply"

Annex M

M 2.4.2.1

Section:

The

hydraulic

Editorial

The last sentence. connections its lowest point. connections at its lowest point.

Accepted

Missing "at". New Text "The drip pans should include

drainage ports/connections at its lowest point."

Annex M

M 2.4.3.1

Section: If

the

IWOCS…

Technical

a one-hour supply of energized fluid. Increase the safety factor on the open and close

calculations to 28% or 30%. Delete the 1 hour

part. Rejected

The 1 hour is stated such that upon loss hydraulic power

there requires to be enough time to estabish the required

barriers, taking into account any loss of fluid due to system

design

Annex M

M.2.4.2.1

Paragraph

18

Technical


The start/stop set points should, within design

boundaries, be able to be changed via the HMI.Accepted

new text "The start/stop set points should within design

boundaries be able to be changed via the HMI."

Annex M

M.2.4.2.1

Paragraph

23

Technical

It is bad workmanship to leave burrs and not

clean tubing properly.

Correct:

... No burrs shall be allowed, and each section of

the tubing shall be blown through and cleaned

before assembly to ensure that no

contamination (debris) enters the system during

manufacturing and assembly.

Accepted

new text "No burrs shall be allowed, and each section of

the tubing shall be blown through and cleaned before

assembly to ensure that no contamination (debris) enters

the system during manufacturing and assembly."


The uninterruptible power supply shall supply

electrical power to the subsea power unit,

topside electronic unit and the MCP. Is the

subsea power unit the SCM and topside

electronic unit the SPCU?

This text should be rewritten so that it defines

what Functions the UPS shall power, not witch

modules.. Accepted

Change first paragragh to "The uninterruptible power

supply is required to ensure safe and reliable electrical

power to the IWOCS."

Annex MTable M-3.

7.2.5.4Technical

It states: IWOCS umbilicals are not required to

comply. Then e) states: may be required.

Delete the first text and add it into e).

Accepted

Delete first sentence and e) now reads "Insulation

materials for IWOCS umbilicals are not required to comply

with the requirements of lEC 60502-1 and IEC 60502-2,

however, depending on voltage rating, insulation material

and thickness, nonmetallic conductor and insulation

screening may be required, as specified in IEC 60502-1 or

IEC 60502-2."

Annex M

Table M-3,

section ref.

API 17E ref

EditorialError in 1st column Change "ISO API 17E Section Reference " to "API

17E Section Reference" Acceptedmake changes per proposed change

Annex M

Table M-3,

section ref.

API 17E ref

6.3.5

Technical

I´m questioning why a VIV analysis is applicable

for a free hanging (clamp-less) umbilical? To be

evaluated.Rejected

API 17E section explains the evaluation

Annex M

Table M-3,

section ref.

API 17E ref

. 7.2.5.3

Technical

Added ...copper and copper + insulation. Added

and impedance for signal.

The minimum nominal cross-sectional copper

area for power and copper + insulation area for

signal conductors in IWOCS umbilicals shall be

selected such that it is suitable tor the system

voltage and current requirements and

impedance for signal requirements.

Accepted

Refer in line 503, not added copper etc as specific

Annex M

Table M-3,

section ref.

API 17E ref

. 7.2.5.4

Technical

This Section seem to be inconsistant with

regards to the IEC 60502-1 referance. The first

paragraph states that this standard is not

applicable for insulation materials, while it is

referenced in item e)??

Accepted

as per line 494

Annex M

Table M-3,

section ref.

API 17E ref.

7.2.6.1

Technical

Nominal to be replaced by calculated For IWOCS umbilicals the direct current

resistance for each conductor shall not exceed

the calculated resistance per unit .....Accepted

new text "For IWOCs umbilicals the direct current

resistance for each conductor shall not exceed the

calculated resistance per unit length for the specified

conductor based upon the conductor dimensions and the

applicable material resistivity."

Annex M

M-3,

section ref.

7.2.9.3 and

7.2.10.4

Editorial

These sections to be merged into one section

(both are about direct current conductor

resistance). Some of the text is replicated. Rejected

They match API 17E references

Annex M

Table M-3,

section ref.

API 17E ref

. 8.2 a)

Technical

For applications where the umbilical is run inside

the marine riser, is is usually required to use an

ultra slim-line termination head due to space

constraints. The terminated SWL for ultra slim-

line terminations is normally less than the

umbilical SWL due to physical limitations.

a) design principle is that the end termination

shall meet the same functional requirements as

the umbilical, except for terminated SWL for

ultra slime-line terminations. Ultra slim-line

terminations may be required due to very

limited space if the umbilical is routed inside the

marine riser.

Accepted

add text in proposed change

Annex MTable M-3.

7.2.6.1Technical

For IWOCS umbilicals the direct current

resistance for each conductor shall not exceed

the nominal resistance per unit length for the

specified conductor based upon the conductor

dimensions and the applicable material

resistivity.

How can I deliver according to this? Clarify.

Rejected

No proposed change. Text has been modified per line 498

Annex M Table M-3 Technical

Add clarity. Correct line 6.3.6:

Only applicable in open-water intervention

mode if the umbilical is in close proximity to

C/WO riser or vessel (e.g., pontoons, moonpool)

without being clamped to the C/WO riser or

pod/guide wire.

Accepted

add text in proposed change

Annex M Table M-3 Technical

At smaller cross sections mechanical strength in

conductors are equaly important.

Correct:

The minimum nominal cross-sectional area for

power and signal conductors in IWOCS umbilicals

shall be selected such that it is suitable for the

system voltage, current and mechanical load

requirements.

Accepted

New Text "The minimum nominal cross-sectional area for

power and signal conductors in IWOCS umbilicals shall be

selected such that it is suitable for the system voltage,

current, impedance for signal requirements and

mechanical load requirements."

Annex M

M.3.3.3

Paragraph

1

Technical


The umbilical reel should have drum capacity to

spool up (store) the complete fluid-filled

umbilical length plus a surplus length of 10%.

Accepted

New Text "The umbilical reel shall have drum capacity to

spool up (store) the complete fluid-filled umbilical length

plus a surplus length of 10%."

Annex M

M.3.3.3

Paragraph

7

Technical

Add clarity and avoid technology limiting

formulations.

Correct:

For reels powered by air or hydraulic sufficient

filtering, lubrication, and pressure regulation of

the power supply shall be provided on the reel

to protect the motor and power train from

excessive wear or damage. For reels powered by

electricity equivalent means shall be provided to

ensure that electric supply do not cause

excessive wear or damage.

Accepted

New Text "For reels powered by air or hydraulic pressure,

sufficient filtering, lubrication, and pressure regulation of

the power supply shall be provided on the reel to protect

the motor and power train from excessive wear or

damage. For reels powered by electricity equivalent means

shall be provided to ensure that electric supply do not

cause excessive wear or damage."

Annex M

M.3.3.3

Paragraph

11

Technical


Without having the reel's topside deck jumper

connected the reel should have facilities to allow

for selected umbilical lines to be isolated and

pressure-maintained

during deployment and retrieval.

Accepted

New Text "Without having the reel's topside deck jumper

connected, The reel should have facilities to allow for

selected umbilical lines to be isolated and pressure-

maintained during deployment and retrieval. All functions

should be mounted in an isolating/monitoring panel on the

reel. "

Annex M M.3.1 Editorial

The scope of clause M.3 is limited to the use of

umbilicals for the distribution subsystem. Find

the part " use of umbilicals " unclear.

The scope of clause M.3 is limited to umbilicals

for the distribution subsystem, and must fulfill

the following requirements.Rejected

This was added in WD 5, current WD 5.2 has this wording

already as per previously submitted comments.


The umbilical termination… The umbilical topside end termination...

Rejected

This was added in WD 5, current WD 5.2 has this wording

already as per previously submitted comments.


A multi-quick connector function should be

designed for make-up and break-out by hnad if

only topside operation is intended. We need to

use hand tools for make-up.

Change from should to can.

Accepted

New Text "A multi-quick connector function can be

designed for makeup and break-out by hand if only topside

operation is intended. "


The reel should be equipped with a transverse

reciprocating… We use a diamond screw for our

spooling device.

Change from should to can.

Accepted

"Accept in principle. New Text

""The reel shall be equipped with a guidance system to

evenly spool the umbilical on the drum during re-

spooling."""


The reel drum diameter shall be designed to the

umbilical minimum STATIC diameter, not

DYNAMIC.

The reel shall have a drum diameter eaqual to or

greater than twice the minimum static bend

radius or as ....Accepted

new text "The reel shall have a drum diameter equal to

twice the minimum static bend radius or as otherwise

agreed with the umbilical supplier."


The reel shall also have a locking pin system for

securing the reel drum during transport and

when the topside deck jumper is connected.

Remove: and when the topside deck jumper is

connected. The clutch is holding the drum.Accepted

new Text "The reel shall also have a locking pin system for

securing the reel drum during transport. "

Annex M M.3.6 Editorial

couplers extra? Unclear.

Accepted

"New Text for M.3.6

""The umbilical shall be pressure tested, in line with

maintenance schedule periods, after replacement of any

defective connectors and if being operated beyond the

operational limitations."""


The reel drive system also include a gear box

which is sitting adjacent to the drum. Please

note, that during deployment and retreieval of

the umbilical, the brake is not engaged. The

umbilical is then protected by the slip clutch.

The clutch shall be directly adjacent to the input

end of the gear box, which again shall be

adjacent to the drum. The brake shall be located

...Accepted

new text for M3.7, 3rd paragraph "The clutch shall be

directly adjacent to the input end of the gear box, which

shall be adjacent to the drum and the brake shall be

located between the motor and the clutch"

Annex M

M.4.3.1.2

paragraph

2

Technical

Because a requirement for independency on

safety functions is system related and not

specific for the WOCM a rephrased version of

this paragraph is moved to M.1.2.16 Safety

functions, while this paragraph is deleted.

Correct:

Safety-related functions in the workover control

module, including ESD and EQD sequences, shall

be independent as defined in the safety strategy.Accepted

new text for M3.7, 3rd paragraph "The clutch shall be

directly adjacent to the input end of the gear box, which

shall be adjacent to the drum and the brake shall be

located between the motor and the clutch"

Annex M

M.4.3.3

Paragraph

2

Technical

Add clarity and consistency. Correct:

Subsea power storage for Thru/BOP – Riser

Intervention Modes the safety functions shall, as

defined by safety strategy, be segregated from

power storage to non-safety functions such that

stored energy for safety functions is available at

any time. Further, independence between the

different safety functions shall be as defined by

the safety strategy.

Accepted

"new text ""Subsea power storage for Thru/BOP – Riser

Intervention Modes the safety functions shall, as defined

by safety strategy, be segregated from power storage to

non-safety functions such that stored energy for safety

functions is available at any time. Further, independence

between the different safety functions shall be as defined

by the safety strategy.

Sufficient capacity for the respective functions for one (1)

close or unlock operation, together with a 10% margin"""

Annex M

M.4.3.3

Paragraph

3

Technical

Add clarity and consistency. Correct:

Subsea power storage for Open Water

Intervention Modes the safety functions shall, as

defined by safety strategy, be segregated from

power storage to non-safety functions such that

stored energy for safety functions is available at

any time. Further, independence between the

different safety functions shall be as defined by

the safety strategy.

Accepted

"new text ""Subsea power storage for Open Water

Intervention Modes the safety functions shall, as defined

by safety strategy, be segregated from power storage to

non-safety functions such that stored energy for safety

functions is available at any time. Further, independence

between the different safety functions shall be as defined

by the safety strategy.

Sufficient capacity for the respective functions for one (1)

close or unlock operation, together with a 25% margin """

Annex MM.4.4.1.3

item i)Technical

Time stamping is required if retreived data shall

be placed in correct timeframe.

Correct:

... This storage and delayed transmission of data

are acceptable only if they are time stamped and

none of the data in question is lost or

overwritten; Accepted

new text "in specific operational modes a large amount of

data might not be possible or appropriate to relay to the

MCS in real time. Temporary storage of this data are

acceptable, provided the stored data are subsequently

relayed to the MCS in a timely manner. This storage and

delayed transmission of data are acceptable only if they

are time stamped and none of the data in question is lost

or overwritten"


Correct heading. Correct:

Subsea power generationAccepted

"new title ""Subsea Hydraulic Power Generation and

Storage""

This change also affects figure M.1"

Annex MM.4.4.2.2

item d)Technical

BS 7201-1 is absolite wording is not logic. Correct:

d) design of accumulator shall comply with ASME

Boiler and Pressure Vessel Code, Section VIII,

Division 1, BSI BS EN 14359 + A1, ISO 10945, or

the applicable code or regulation which applies;

Accepted

WG to revise and clarify the requirement. Should state

"with either"



The IWOCS shall interface with the surface tree,

lubricator valve, SSTTA, BOP spacer joint, tubing

hanger and tubing hanger running tool to

provide the necessary control to function these

equipment.

Accepted

WG to revise and clarify the requirement.


Interfac between….shall be defined in Annex F.

Annex F does not address questions concerning

air quality on rig supplied compressor air, or

quality of the el. supply. Do the system need air

drier and alternator?

Consider an update.

Rejected

This is not a comment for Annex M, but should reviewed

by Annex F to determine if valid to add. (Ask James Pate)


Seksjon M.7

M.7.1 Safe system design

“…Safety instrumented systems shall be

designed in accordance with the reliability

principles for minimizing the probability of

failure on demand as defined in IEC 61511:::”

3.1.157 safety instrumented system

“instrumentation and controls installed for the

purpose of taking the subsea intervention

system to a safe state

NOTE 1 Safety instrumented systems may

include electrical, electronic, pneumatic,

mechanical, and hydraulic systems.

NOTE 2 Safety instrumented systems do not

include instrumentation and controls installed

for non-emergency shutdowns or routine

(normal) operations”

Comment: M.7.1 warrants SIL requirements as

mandatory to e.g. PSD, ESD and EQD, together

with the definition 3.1.157. This is in conflict

with Section 1.1 and 4.13, where such is

optional for the IWOCS only.

Comment: M.7.1 warrants SIL requirements as

mandatory to e.g. PSD, ESD and EQD, together

with the definition 3.1.157. This is in conflict

with Section 1.1 and 4.13, where such is optional

for the IWOCS only.

Accepted

"Annex M is to be left as is and Section 4.13 to have

""NOTE: A SIL rating number is not a requirement on the

safety instrumented systems, unless specifically stated in

the safety strategy."" added.

Section 1 has also been re-written"

Annex M M.8.2.3 b) Technical

To do a test where you spool of all of the

umbilical, could be 3000m, is a huge process.

The result we get, do not defend the amuont it

will cost us.

Change to 20% of the umb.?

Accepted

"Annex M is to be left as is and Section 4.13 to have

""NOTE: A SIL rating number is not a requirement on the

safety instrumented systems, unless specifically stated in

the safety strategy."" added.

Section 1 has also been re-written"


The list of tests is missing EFAT with SCM,

WOCM or RCM.

Consider an update.

Accepted

"Clause 8 needs to be added to take into account SIT and

EFAT. New Text:

""In the case that an IWOCS control system (or subsystems

it consists of) is planned to be used in an application for

which it was not originally designed, then a change in any

one of the following variables shall require that an integrity

assessment and additional testing performed in

accordance with the relevant subsections of Annex M &

Clause 8:"""

Annex M M.9.2 TechnicalThe list of markings on the IWOCS is missing

Weight marking

Update.Rejected

Bullet g) defines weight if applicable



Operation and maintenance history, inclusive of

software revisions, shall be available in the

IWOCS control container or easily accessible on

site through a digital system.

Accepted

as per proposed change



A detailed log of maintenance, reliability, and

operational history shall follow the IWOCS at all

times.Rejected

"wording is already as proposed however this shall change

to the following new text.

""A detailed log of maintenance, reliability, and

operational history shall be available for the IWOCS at all

times. """

Annex M

M.11.1.1

item b),c),

d)

Technical

When equipment is rented it may not be the

manufactorer/vendor that owns the equipment.

Correct:

b) maintenance documentation shall be

maintained by the system/equipment owner;

c) modifications, upgrades, and repairs

documentation shall be maintained by the

system/equipment owner;

d) condition résumé shall be maintained by the

system/equipment owner.

Accepted


Annex MM.11.1.1

item j)Technical

Add claity. Correct:

j) software installation procedures for

programmable devices shall be provided to

cover all scenarios of software installation. These

procedures shall not compromise the software

supplier's requirements to revision,

documentation and competency control.

Accepted


Annex M

M.11.7

paragraph

1

Technical

Correctness of manuals has in general an

improvement potential.

Add to first paragraph:

The manuals should as far as practical possible

be verified through actual use on the system

and its equipment.

Accepted

"New Text to end of 1st Paragraph:

""The manuals shall as far as practical possible be verified

through actual use on the system and its equipment."""

Annex M M.11.2 k) Technicalanalysis. Is this the hydraulic analysis for the

accumulators?

ClarifyRejected

any analysis carried out, accumulors, reponce times etc

Annex M M.11.3 Editorialmanufacture and in should… Update.

Acceptednew text "Design analysis shall be prepared prior to

manufacture and should include as a minimum:"

Annex M M.11.4 EditorialBlank page. Update.

Rejectedno blank page in document

Annex M M.11.7 b) Technical

inspection, maintenance and repair procedures

for each component, including sub components.

This puts on the producer to deliver a

inspection, maintenance and repair procedure

for all items consisting of two parts or more. Do

the produceres commit to this today?

Consider an update.

Rejected

require to provide inspection, maintenance and repair

procedure for all items to ensure equipment is in optimal

condition

Annex M M.8.2.3 b) Technical

spooling on and off the complete umbilical

length

Change to: spooling on and off the usable

umbilical length. Rejected

Changed to 20%, as you still may have to pull out possibly

2500m, however this is only to prove the spooling

mechanism is correctly aligned

Annex M M.1.2.4 Technicaladd reference to where the 15 tons value comes

from to determine "heavy lift operations

offshore"

RejectedWording has been modifed per other comments

Annex M

M.1.3.2,

M.1.3.3,

M.1.3.4

Editorial

will the references section numbers always

remain the same in another API document. For

example, the "API 17F, Section 5.4.2" currently

referenced in this draft could it be changed by

the API 17F committee to another section

number like 7.2 thus voiding the reference.

Rejected

As per Table M.3, these references are required for clarity.

If API 17F is revised then concideration to this document is

required.


Paragraph 17 last sentence states, "The MCS

shall only control the hydraulic power unit

pumps when in automatic mode." - Remove

sentence because HPU can have a CPU to run in

automatic mode and the MCS is read-back only.

When the hydraulic power unit pumps have

automatic mode capability the CPU can be

located at the HPU or MCS.Accepted

new text at end of sentence "When the hydraulic power

unit pumps have automatic mode capability the CPU can

be located at the HPU or MCS."

Annex M M.4.4.2.a Technical

statement conflicts with text in M.4.3.3

accumulator volume capacity margins.

…shall be based on the requirements for subsea

power storage as outlined in Annex M.4.3.3.Accepted

New text "subsea power generation and storage sub-

systems shall be based on the requirements for subsea

power storage as outlined in Annex M.4.3.3.; "

Annex M M.4.4.2.c Technicalfirst sentence which states "shall" conflicts with

the second sentence which allows for variations

to the first sentence.

each hydraulic function line should have dual

redundant pressure transducer… AcceptedNew Text "each hydraulic function line should have dual

redundant pressure transducers"


Paragraph 8, first sentence states "design shall

be according to a standard commonly accepted

by the industry." Either change statement to

"should" or call out specifically what standard is

commonly accepted by the industry.

MCS layout and HMI design should be according

to a standard commonly accepted by the

industry.

Accepted

New paragragh 8 text "Master control station layout and

human machine interface design should be according to a

standard commonly accepted by the industry. Layout and

functionality shall be optimized to reduce operational

errors, both during normal operation and during

alarm/emergency operations."

Annex MSection

M.7.1Technical

There is no mention of management of change

for SIL compliance. This should be treated the

same as any design change

Suggest adding a note on verification of SIL

compliance when changes are made to exsisting

certified SIFs. SIL rating is specific to SIF so any

changes/modification tosequence of events,

hardware elements or software code from

original certified SIF may require recertification.

Rejected

This is Management of Change and not just the SIL

compliance. Therefore should not be added to specifically

to this section. There are numerous points within the

standard to highlights that if changes are carried out then

these shall be reviewed to ensure they to don't conflict

against existing documents / qualification


Interface between….shall be defined in Annex F.

Annex F does not address questions concerning

air quality on rig supplied compressor air, or

quality of the el. supply. Do the system need air

drier and alternator?

Consider an update.

Rejected


This is not a comment for Annex M, but should reviewed

by Annex F to determine if valid to add. (Ask James Pate)

Annex M M

Acoustic primary control systems -- for

operaiton of the well barriers -- Need to write

into the code the acoustic telemetry as primary


need to add and cross check in the document this issue

Annex M M.1.1

Introduction Para. 3, statement "Project economics dictate

whether to choose an all-hydraulic or electro-

hydraulic system". Economics is only part of the

selection process.

Suggested Change:

Remove "Project economics dictate whether to

choose an all-hydraulic or electro-hydraulic

system"

Rejected

First sentence has been changed to the following with

comments provided.

"Multiple aspects like economics, technical solutions and


hydraulic or electro-hydraulic system. "

Annex M M.1.1.1

Thru/BOP-riser intervention mode system Para. 3, "Typically electro-hydraulic…." is

unnecessary

Proposed changed: Remove paragraph

Accepted

Remove paragragh.

Annex M M.1.2.2

General

The IWOCS shall allow for flexibility and

optimization. The basic system design shall allow

for full functionality of envisioned existing

infrastructure and intervention scenarios. The

following elements shall be considered during

system engineering:

The statement 'flexibility and optimization' adds

no value.

Proposed change:

Remove first sentence

Add the following bullet points:

m) ROV interfaces

n) Material compatibility with process fluids

(NACE / ISO 15156)

Accepted

New Text for 1st Paragraph

"The IWOCS basic system design shall allow for full

functionality of envisioned existing infrastructure and

intervention scenarios. The following elements shall be

considered during system engineering:"

Also add

"l) ROV Interfaces

m) control fluid & process fluids compatibility"

Annex M M.1.2.4

Size and mobility of modules

Consideration shall be taken to avoid heavy lift

operations offshore, which typically imply lifting

loads above 15 tons.

Some units must be larger than 15 tonns, eg

Deep water umbilical reelers. Giving a difinitive

weight may cause confusion.

Proposed change:

Remove statement " which typically implies

lifitng loads above 15 tons"

Accepted

next text for last sentence:

"Heavy lift operations offshore shall be reviewed and

where practical avoided, however if they cannot be

avoided then offshore risk assessments shall be

performed."

Annex M M.1.2.12

Fail-safe philosophy

The IWOCS shall be designed to render the well

intervention packages to a fail-safe status upon

loss of power.

The definition of power need to be clarified.

Does this refer to topside electrical power?

Subsea electrical Power? Hydraulic Power?

Proposed solution:


intervention packages to a fail-safe status uppon

loss of hydraulic power or, in an all electric

system, loss of electrical power"

Accepted

Accept in principle however it does not have to be all

electric system to be affect by loss of electrical.

Next Text:


intervention packages to a fail-safe status upon loss of

hydraulic or electrical power and/or operator control.

Upon restoration of power and/or operator control, the

fail-safe status shall not be affected or changed."

Annex M M.1.2.13

Consideration shall be given in the design to

early detection of failure, ability to test while in

hole, and redundancy for critical components,

which cannot be designed according to this

principal.

"..ability to test" must be clarified. Please define

what tests are requrired.

Accepted

Text should not be to consider, therefore with the

comments new wording is required.

New Text "An overall objective shall be to design the

system to ensure that no single failure will cause a total

system shutdown or prevent the ability to secure the well

or force the system into an unsafe state. The system shall

have the ability to detect failure or the ability to perform

tests while in hole to determine the cause of failure, and

shall have redundancy for critical components, which

cannot be designed according to this principal."

Annex M M.2.2

General Requirements Add additional statement:

Design shall also consider environemental

conditions such as ambient temeratures, direct

sunlight, saliferous environment, etc

Rejected

This is taken into account to further sections.

Annex M M.2.4.1.2

Master control panel

...All functions related to pressure testing shall

be monitored.

This statement reads as if all system pressure

tests (seal tests, plug tests, etc) need to be

directly monitored by the MCS. Is this the

intent? If so it may be useful to define exactly

what 'pressure tests' are included. Proposed

rewording:

'All functions related to pressure testing shall be

monitored. Relevant pressure tests included ....'

Accepted

New Text:

"All functions controlled by the IWOCS shall be

monitored."

Annex M M.2.4.1.3

Remote control panel

A cable monitoring system shall be included to

notify the operator of cable failures both locally

on the remote panel and on the MCS. In case of

remote control panel cable failure the safety

function(s) shall not be activated and the master

control panel shall automatically be activated.

A potential solution to the Remote control panel

is to have a KVM extendor wherein the RCP is

only a monitor and a mouse (all 'brains' in the

MCS). In this situation, it is not pissible to raise

an alarm locally at the RCP if the comms link is

broke

Proposed solution:

Revise the clause to state that only an alarm

should be raised at the MCS.

Alternatively, if a local alarm is required, and

additional statement should be added stating

that the RCP design should not utilize a KVM

extender.

Rejected

This is a solution not a comment for the standard. The

monitoring system maybe an alarm or othe identification

Annex MM.2.4.1.6

b)

pressure discharge system shall be dimensioned

to avoid over pressure;

The term 'dimensions' is not descriptive enough.

A definitive design standard for the relief system

should be reference.

Proposed solution:

Change text to the following "pressure discharge

system shall designed i.a.w. API 520 parts 1 and

2"

Accepted

No reference required to a design standard as the design

might not be a pressure releving device, Change

dimensioned to designed. New Text

"pressure discharge system shall be designed to avoid over

pressure;"

Annex MM.2.4.1.6

d)

flanged hydrocarbon gas detector connected to

the host facility fire and gas system;

This satement is too perscriptive. The gas

detector will typically be connected to the HPU

PLC which then may be tied back to the host

facility or to the MCS and then onward to the

host facility.

Proposed change:

Revise statement to say

flanged hydrocarbon gas detector connected to

the host facility fire and gas system either

directly or via IWOCS

Accepted

new text "flanged hydrocarbon gas detector connected to

the host facility fire and gas system either directly or via

IWOCS;"

Annex MM.2.4.1.6

e)

welded connections armored glass sight level

gauge for local indication of fluid level;

The statement 'armoured glass' is not descriptive

enough. Specific specification should be

referenced.

Proposed solution: sight level guages for local

indication designed i.a.w. BS 3463, Specification

for observation and gauge glasses for pressure

vessels.

Accepted

new text "sight level gauge(s) for local indication of fluid

level shall be in accordance with BS 3463:1975,

Specification for observation and gauge glasses for

pressure vessels; "

Annex M M.2.4.2.1

If the IWOCS requires hydraulic power to

operate critical functions related to well control,

then the system shall maintain a 1-hour supply

of energized fluid, giving the operator time to

establish well barriers in the event of system

failure. The volume of the 1-hour supply shall be

based upon consumption rates to establish the

required barriers and shall take into

consideration system designed leakage. This

fluid can reside within or be distributed among

the HPU, the Surface Accumulator System,

and/or Subsea Accumulators.

The first paragraph is not descriptive enough,

specificall the statement '...system shall maintain

a 1-hour supply of energized fluid' A '1 hour

supply' is fully dependant on what operation will

be done over that hour.

The clause should be revised such that a

definitive accumulator volume is given.

Suggested proposal:

Remove the paragraphs starting with "If the

IWOCS requires hydraulic power to operate

critical functions ..." and "For last closing

functions, there shall be sufficient pressure

capacity..."

Rejected

The paragraph states "The volume of the one-hour supply

shall be based upon consumption rates to establish the

required barriers and shall take into consideration system

designed leakage" therefore the 1 hour supply allows this

operation to take place at any point.

Annex M M.2.4.2.1

Accumulators shall have sufficient capacity

between the valve actuators and connectors’

maximum and minimum operating pressures

without assistance from the hydraulic pumps,

for the following operations:

a) Lower workover riser package and connectors

through one (1) close and unlock + 25% close

and unlock margin.

b) C/WO riser or landing string high set

lubricator valves through one (1) close + 25%

close margin.

c) Surface tree valves through one (1) close /

open / close sequence + 25% close margin.

d) Lower workover riser package or landing

string valves and connectors through one (1)

close and unlock + 25% close and unlock margin.

e) Downhole package capacity shall be defined

by end user.

Statement should be added:

Quantity of accumulators shall be N+1 where N

is the number of accumulators to meet stored

accumulator volume.

Rejected

Theer is no requirements for 1 extra accumulator, if the set

to the margins stateed.

Annex M M.2.4.2.2

CIU Currently no requirements for integration with

the ESD system

Add statement:

CIU shall integrate with the ESD system as

required by the Safety Strategy; clause 4.13

Rejected

This will be defined in the safety strategy and as such can

be added to the system.

Annex M M.2.4.3.1

Surface accumulator system Please define the specifications that the surface

accumulators must adhere to.

Add statement:

Accumulators shall be designed in accordance

with ASME Boiler and Pressure Vessel Code,

Section VIII, Division 1

Accepted

add the following text

"design of accumulator shall comply with ASME Boiler and

Pressure Vessel Code, Section VIII, Division

1, and BS EN 14359 and ISO 10945, or the applicable code

or regulation which applies."

Annex M M.3.7

Safety Philosophy M3.3.4 states Fsheave,swl >Tumb,break

Equation M.2 states:

Treel,brake >Treel,slip < Fsheave,swl

<Tumb,break

These sections contractict each other.

Proposed solution:

If the philosophy is that the umbilical should

break before the sheave, then ammend equation

M.2 to be: Treel,brake >Treel,slip <Tumb,break <

Fsheave,swl

If the philosophy is that the sheave should break

before the umbilical then update section M.3.3.4

to state Fsheave,swl <Tumb,break

Accepted

ammend equation M.2 to be: Treel,brake >Treel,slip

<Tumb,break < Fsheave,swl

Annex M M.4.4.1.2

Subsea intervention control module design

g) hydraulic supply line flow should and function

line flow can be internally monitored by

flowmeters;

The specification should not have 'can'

statements as the purpose of the document is to

state the requirements not the possibilities.

Proposed change:

Removed '..and function lines flow can be

internally monitored by flowmeters'

Rejected

This is for guidance. New Text however due to error.

"hydraulic supply line flow should and function line flow

can should be internally monitored by flowmeters;"

Annex M M.4.4.2

Subsea power accumulation The section title seems incorrect. Suggested

section title:

'Subsea Hydraulic Power Generation and

Storage'

Accepted

new title "Subsea Hydraulic Power Generation and

Storage"

This change also affects figure M.1

Annex M M.4.4.2.2

Subsea power storage

d) design of accumulator shall comply with

ASME Boiler and Pressure Vessel Code, Section

VIII, Division 1, and BS 7201-1 and ISO 10945, or

the applicable code or regulation which applies;

BS 7201-1 has been superseeded by BSI BS EN

14359 + A1

Accepted

new text "design of accumulator shall comply with ASME

Boiler and Pressure Vessel Code, Section VIII, Division

1, and BS EN 14359 BS 7201-1 and ISO 10945, or the

applicable code or regulation which applies; "

Annex M M.5.3.2

Interface to C/WO riser system – thru/bop riser

intervention mode

The IWOCS shall interface with the surface tree,

lubricator valve, SSTTA, BOP spacer joint, tubing

hanger and tubing hanger running tool to

provide the necessary hydraulic control pressure

to function these equipment.

Revise statement to state 'provide the necessary

hydraulic pressure to function and monitor these

equipment'

Accepted

new text "The IWOCS shall interface with the surface tree,

lubricator valve, SSTTA, BOP spacer joint, tubing hanger

and tubing hanger running tool to provide the necessary

hydraulic control pressure to function and monitor these

equipment."

Annex M M.8.3

Pre-operational testing

A pre-operational test procedure shall be

developed

Please clarify the meaning of 'pre-operational'.

During the review some engineers read this as

test prior to initial operation, i.e. EFAT. Other

read this as a test that must be performed prior

to every operation, i.e before being deployed

subsea.

Accepted

change "Pre-Operational" to System Integration"

Annex M M.9.2

Marking

All major components of the IWOCS that meet

the requirements of this standard shall be

marked with “API 17G.”

Clarification: Can this stamp be self - certified or

do you need a third party to verify? May be

useful to clarify this point within the document. Rejected

Statement has been removed as this wil lbe dicated by the

final ratng of the standard.

New First sentence "All major components to shall be

supplied with permanent marking that includes the

following: " Annex M M.10.2 Inspection and maintenance There is no content in this section Accepted As per line 195, section 10.3 title is an error

Annex M M.10.3 General Section title a repeat Accepted The title should be deleted.

Remove the folllowing sentance as not appliable

to the functionality of a landing joint and API

Colour issue.

"A control umbilical(s) may be used to provide

hydraulic supply and electrical signal/power to

the subsea tree, SSTTA, and tubing hanger

functions. Suitable umbilical clamps shall be

installed to attach the umbilical(s) to the riser

joint at specified intervals."

delete "A control umbilical(s) may be used to

provide hydraulic supply and electrical

signal/power to the subsea tree, SSTTA, and

tubing hanger functions. Suitable umbilical

clamps shall be installed to attach the

umbilical(s) to the riser joint at specified

intervals."

Accepted

Documents

Section Review Comments Section Section # Comment ... · 2. Subsea battery system Accepted Item g) revised as proposed. (included in mark-up) Clause 1 Fig 1-1 New in WD5 and requires