Template for comments and secretariat observations...NACE, SAE Add these Accepted American Petroleum Institute, 1220 L Street, North West Washington, DC 20005-4070, USA. ASME International,

Template for comments and secretariat observations Date: 2004-05-18 Document: ISO DIS 13628-7.2 1 2 (3) 4 5 (6) (7)

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Clause No./ Subclause No./

Annex (e.g. 3.1)

Paragraph/ Figure/Table/

Note (e.g. Table 1)

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

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

page 1 of 52 ISO electronic balloting commenting template/version 2001-10

BR 1 1st paragraph ed The first symbol quotation should come with its

explanatory full writing terms We suggest “… subsea completion/workover (C/WO) riser…”

Accepted

BR 2 14th paragraph

ed “ISO 9712, Non-destructive testing, qualification …” The word “qualification should begin with a capital letter “Qualification”

Accepted

BR 2 p. 3 - 11th paragraph

ed ISO 15156 “- Material for use in H2s -..” It should be “- Material for use in H2S -..” Accepted

BR 3.2 Whole Clause

ed Several abbreviated terms are quoted on Clause 3.1 which are explained several pages ahead

We suggest re-locating Clause 3.2 before 3.1 Not accepted, Present order of clauses is to ISO Directives Part 2

BR Several Several sketches

ge It has been a recurrent problem not providing clear sketches in the ISO documents, several variables have to been read using magnifiers or trying interpret them through the provided tables

We suggest improving sketches before distributing documents for being analysed. This will not be acceptable in a FDIS document

Note Figure quality and format is controlled by ISO CS. At DIS figure are png format. At FDIS stage and later they will be in dwg format. Comment to ISO CS: Ensure that figures are full page.

BR 5.5.7 1st paragraph of p. 74

te “Fluid reservoirs shall be made from stainless steel …” It seems that is missing the true subjective of the sentence

Accepted Change "Fluid containers" to "Hydraulic fluid tanks"

BR 7.3.4 1st paragraph ed “… such as support- and protective structures …” We suggest correcting word separators Accepted 1st para: "Structural items such as supports and protective structures …."

BR Annex C Table C.1 ed Last sentence on the bottom ‘… monitoring and inspection/ replacement intervals”

We suggest “inspection/replacement” Accepted

BR Annex H H.2, p. 235, 6th

paragraph

ed “Metal seals may be coated to improve the performance of the seal. Typically zinc … possibility of galling, sliver

coating may be…”

Shouldn’t it be silver coating? Accepted Replace "sliver" with "silver"


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FR F Title ed change the French title from:

Industries du pétrole et du gaz naturel — Conception et exploitation des systèmes de production immergés —

Partie 7: Systèmes de colonnes montantes «workover/completion»

to :

Industries du pétrole et du gaz naturel — Conception et exploitation des systèmes de production immergés —

Partie 7: Systèmes de liaison surface/fond de mer pour reconditionnement/complétion

Accepted in principal

Changed to:

Partie 7: Systèmes de liaison surface/fond de mer pour completion/reconditionnement

NL Ge Because of its sheer size, the following is still a pretty long list of mostly minor editorial/typing corrections, and also a few cross-references and technical queries/corrections. The large size is partly caused by the document's style, which is wordy. Some texts, especially in the annexes, give it the character of a tutorial on for example structural design and fatigue analysis. However it is not proposed to make changes to this style at this stage.

If voted 100% positive, NL would not object this document skipping FDIS, if the following comments are considered. This is because they are almost all general/editorial.

Noted

NL Foreword 6th para Ed Still to be adapted Amend to reflect this edition. Accepted


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NL Foreword Ed Titles of Parts to be checked/amended. Part 2: insert “Unbonded” before “flexible”. Part 10: delete “Specification for” and insert “flexible” before “pipe”. Part 11: delete “riser”.


ISO 13628-2 title is correct the new DIS version 2004 has changed its title to Unbonded flexible pipe systems for subsea and marine applications. Therefore Unboned will be inserted in the foreword and in the the normative references

Accepted

ISO/DIS 13628-10 is called "Bonded flexible pipe"

Accepted

ISO/DIS 13628-11 is called "Flexible pipe systems for subsea and marine applications

ISO/DIS 13628-5 is called "Subsea umbilicals"

NL Foreword Last para Ed This statement not necessary acc. to Directives Part 2 Delete Not accepted

This text is common to all parts of ISO 13628

NL Introduction 1st sentence Ed Syntax “system” should be “systems” Accepted

NL Introduction 3rd para Ge API RP 17G nowhere listed Add to Bibliography Not accepted

API RP 17G is not referenced else where in the standard.


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NL 2 Norm Refs

Ed Typos ISO 13535 thru 14693: “Pe” should be in italics. EFC no.16: “Containing Environment” should be “containing environment”.

Accepted

NL 2 Norm Refs

Te Should API RP 17B be replaced with ISO 13628-10 ? Check/amend. Not accepted

ISO 13628-10 is at DIS stage. API RP 17B will reference until part 10 is issued.

NL 2 Norm Refs

Ed No reference found in document to IEC 60079. Insert reference at appropriate place or delete. Not accepted

IEC 60079 if referenced in 5.5.6 10th para.


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NL 2 Norm Refs

Te NACE MR 0175 can be replaced by ISO 15156 in both clause 2 and where used in the text. If wished add NACE MR 0175, following dual reference recommendation in ISO/TC67 N435. This also applies to API Spec 16A (ISO 13533)

Check/amend

According to ISO/TC 67 N 435 Rev 5 Oct 2003

IF ISO 15156 and NACE MR0175 are equivalent

Dual reference options are:

1) then reference ISO 15156 and included note "For the purpose of this provision NACE MR0175 is equivalent to ISO 15156.

2) reference ISO 15156 (NACE Standard MR0175, see Clause 2). Include the following Clause 2 Conformance " In this International Standard, certain ISO and non-ISO standards provide the same technical result for a particular provision. In the running test the provision is written in the form "…. In accordance with ISO xxxx (non-ISO yyyy, see Clause 2).

If ISO 15156 and NACE MR0175 do not provide the same technical result, but both results are acceptable then reference ISO 15156 or NACE Standard MR0175.

Accepted

NACE MR0175:2004 is equivalent with ISO 15156-1:2001, ISO 15156-2:2003 and ISO 15156:3:2003

It has been decided not to use dual references.

NACE MR0175 shall be replaced ISO 15156

Accepted

API Spec16A will be replaced with:

ISO 13533 :2001, Petroleum and natural gas industries - Drilling and production equipment – Drill-though equipment

Reference to EFC public. No.16 has been deleted as the necessary technical results are covered by ISO 15156

7.4.5 last para."Welding consumables for girth welds that produce a deposit containing more than 1% Ni are acceptable after successful weld sulphide stress cracking qualification testing in accordance with ISO 15156-2, Annex B.


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NL 2 Norm Refs

Ge Issuing addresses for non-ISO standards missing (MSS, NACE, SAE

Add these Accepted

American Petroleum Institute, 1220 L Street, North West Washington, DC 20005-4070, USA.

ASME International, Three Park Avenue, New York, NY 10016-5990, USA.

American Society for Testing and Materials, 100 Barr Harbor Drive, West Conshohocken, PA 19428-2959, USA.

BSI British Standards, 389 Chiswick High Road, London W4 4AL, UK.

European Federation of Corrosion, available from The Institute of Materials, Minerals and Mining, 1 Carlton House Terrace, London SW 1Y 5DB, UK [ISBN 0-901716-95-2].

European Committee for Standardization, 36 rue de Stassart, B - 1050, Brussels, Belgium.

International Electrotechnical Commission, IEC Central Office, 3, rue de Varembé, P.O. Box 131, CH – 1211 Geneva 20, Switzerland.

Manufactures Standardization Society of the Valve & Fitting Industry, 127 Park Street, N.E., Vienna, VA 22180, USA.

NACE International, 1440 South Creek Drive, Houston, Texas 77084-4906, USA.

SAE International, 400 Commonwealth Drive, Warrendale, PA 15096-0001, USA.

NL Throughout Ed For consistency in spelling Ensure that are written as ONE word: wellhead, wellbore, wireline, bullheading, padeyes, guidelines, upset

Accepted

NL 3.1.3, 3.1.66

Ed Typo, also in 3.1.120 More space after word “NOTE”, “EXAMPLE” resp.

Accepted

Also 3.1.119


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NL Throughout Ed For consistency in hyphenation in text and figures Place hyphen where missing in: project-specific, flow-induced, lock-down, post-weld, worst-case (if adjective), leak-tightness, through-bore (if adj.), shear-and-seal type, multiple-bore (if adj.), break-out, low-friction (if adj.), over-pull, vibration-resistant, skid-mounted, fluid-filled, 100-year, 10-year, thruster-assisted, shut-in (if noun), bleed-off (if noun), station-keeping, cross-section, quasi-static, component-specific, current-induced, gas-tight, set-up (if noun), pressure-energised, full-size, hydrogen-induced, post-heating, manufacturer-supplied, make-up (if noun), moon-pool, hang-off, sea-state, elastic-plastic (D.2, I.1.2), non-integral (F), non-external (H.1/2), fatigue-critical

Accepted

NL 3.1.28 Ed Typo NOTE should be in smaller font Accepted

NL 3.1.75 NOTE Ed THRT and SSTT are not explained in 3.2 Explain (write out in full) here Accepted

NL 3.1.75 NOTE Ed Syntax “be comprised” should be “consist” (twice) Accepted

NL 3.1.80 Ed Syntax “simultaneous” should be “simultaneously” Accepted

NL 3.1.81 NOTE Ed Syntax “of thereof” should be “thereof” Accepted


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NL 3.1.89 Te/Ed Is manufacturer responsible for design? See 3.1.31 Check/amend Accepted

Manufacturer is normally responsible for design but this task may be subcontracted as defined in 3.1.89. The definition is as per EN standards for pressure vessels

Definition 3.1.89 will change as follows:

"individual or organisation that is normally responsibility for the design and manufacture of the C/WO riser and its conformance with this part of ISO 13628"

5.4.12.1 change supplier to manufacturer

NL 3.1.91 Ed For alphabetical sequence Should be “mean static offset (of vessel)” Accepted


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NL 3.1.79 etc. Ed Familiar terms do not need definition. Avoid “motherhood” !

Check whether following definitions are really necessary or should be deleted: 3.1.79, 3.1.121, 3.1.125, 3.1.170, 3.1.179

Not accepted

The definition of "load effect" includes the term load and for completeness it is required to which refers to load and definition of load is therefore required.

Definition of user and/or operator required to implement requirements of 4.18

Definition of work required to implement requirements of 4.14.

Definition of seamless pipe required to implement requirements of 7.3.2

For some analysts the term rotary table may be unknown

NL 3.1.95 Ed Typos “Annex C and” should be “Annex C);” delete closing bracket after “parts”

Accepted

NL 3.1.97 NOTE Ed Typos “verity” should be “verify”. “subsea-shut-in” should be “subsea shut-in”

Accepted

NL 3.1.100 Ed Typo “manufacture’s” should be “manufacturer’s” Accepted

NL 3.1.103 Ed For alphabetical sequence Should be earlier in 3.1 Accepted

NL 3.1.103 EXAMPLE Ed Typo Delete second period at end Accepted

NL 3.1.105 NOTE 1 Ed Typo “plastisification” should be “plasticification” Accepted

NL 3.1.110 Ed Typo “partly of” should be “partly or” Accepted

NL 3.1.114 Ed Syntax “prevents” should be “preventing” Accepted


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NL 3.1.117 Ed Syntax “in the ends” should be “at the ends” Accepted

NL 3.1.168 Ed Syntax / legibility Place comma after “strength” Accepted

NL 3.1.178 Ed Typo, also in 3.2, for consistency with 5.4.11 etc. “wireline coiled” should be “wireline/coiled” Accepted

Also in:

Table 2

Fig A.1

NL 3.2 Ed API, ASTM, BS, EFC and NACE are not necessary once issuing addresses are added in 2. ISO not necessary, defined in Foreword.

Amend Accepted in principal

The following shall be deleted:

API, BS, EFC, IEC, ISO NACE

ASTM and EN shall remain as they are used 7.2.8 in a none-normative reference context.

NL 3.3 Ed Nine pages of symbols ! Normally in an ISO one or two pages. And all symbols are explained in the text where they appear (except a few in annex C, see below)

Therefore suggest to delete, also to economise on length. Replace with “Symbols used in this part of ISO 13628 are explained where they are used.”

Noted

Due to large number of equations, symbols are have been defined in the text based on the principal of first time use to aid readability but to limit repeated symbols list below equations. This has therefore resulted in the need of a symbols list defining all symbols.


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NL 3.3 A5 Ed Typo in definition? Should “A5 (“ and “)” be deleted? Accepted in principal

Table 15: include "for gauge length, Lo= …"

3.3: Change to …gauge length, L0= 5,65 …"

NL 3.3 ni Te/Ed What is meant with “bin I”? Check/amend Noted

Common expression used in fatigue analysis for combination of number of cycles and stress range

NL 3.3 pid Ed Used in 6.3.2.2 but not defined there Definition added in 6.3.2.2 for consistency Not accepted

Equation symbols are defined in the text based on the principal of first time use to aid readability but to limit repeated symbols list below equations.

NL 3.3 po Te/Ed In Fig.10 this is called “operating pressure” Presumably wrong in Fig.10. Check/amend Accepted

Change po to pio

Pio is the internal operating pressure.

NL 4.3, 4.7.1 NOTE Ed Necessary? “typical” is always informative Delete this NOTE Accepted

NL 4.5 Ge Cross-ref to 5.5.6 is not correct, response times not mentioned there

Should be to 5.5.5 Accepted in principal

A requirement for hydraulic/electrical response analysis is specified in 5.5.6, 10th para.

Reference shall be given to 5.5.5 and 5.5.6


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NL 4.6.2 Ed Second hyphenated item duplicates first one. In NOTE 1, “human” appears superfluous (marine life health is environment).

Delete 2nd hyp’d item. Delete “human”. In NOTE 2, 6), “operation” should be “operations”.

Accepted

NL Table 1 Title Ed Typo Delete period at end Accepted

NL Figs 3-7 Ed Legends in figures barely legible Print larger Noted

Figure quality and format is controlled by ISO CS. At DIS figure are dwf format. At FDIS stage and later they will be in dwg format.

NL 4.9 3rd para Ed Syntax in 2nd sentence “that the C/WO” should be “the C/WO” Accepted

NL 4.10 a) Ed Syntax “reasonable” should be “reasonably” Accepted

NL Throughout Ed Conditional statements “where” or “when” should be “if” in: 4.10 c), 4.10 last para, 5.3, 5.4.7, 5.4.12.3 12th para, 5.4.15 1st para and last two hyp’d items, 5.4.16 1st para, 5.4.18 15th para, 5.4.24 2nd para, 6.3.2.3.3 (2x), 6.3.2.3.5, 6.3.2.3.6, 6.3.2.3.8, 6.3.4.1 5th para, 6.3.4.5, 6.4.6 para above Table 10, 6.4.9 5th para, 6.5.3.2 para above NOTE 1 2nd sentce, 7.2.3 3rd sentce, 7.2.7 1st sentce, 7.2.9 2nd sentce, 7.2.10.2 4th para (2x), 7.2.10.3 c) d), 7.4.3 2nd para, 7.4.5 3rd para, 7.4.9 5th para, 7.5.3 d), 8.6 3rd hyp item, 11.5.2.3 2nd hyp item, C.1.4 3rd para (2x), C.1.5 1st para, C.2.3 2nd para, D.2.2 4th para, D.2.3 4th para, G.2.4 2nd para, I.1.4 9th para, I.1.6, I.1.7, I.1.11

Accepted

NL Table 2 Footnote b) Ed Typo “10432 ,any” should be “10432, any” Accepted

NL Table 2 Footnote e) Ed Typos “13628-7” should be “13628” and “equipments” should be “equipment’s”

Accepted


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NL Table 2 Footnote e) Ge In last sentence, “the part” Should presumably be “the corresponding part” Accepted in principal

Change "the part" to "this part"


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NL Throughout Ge Many references to normative documents listed in 2 state also the year of issue, which is not consistent with 2 where no years of issue are given. Also these references state a particular clause, which may not be practical since most such documents are revised periodically.

Check whether such detailed references are meaningful or whether 2 may need amendment; see Table 2 footnote e), 5.4.2, 5.4.11, 5.5.6, 6.3.2.2, 6.3.2.3.7 NOTE 1, 6.7.3, 7.3.3.2, 8.3.3, 8.3.4, 9.2, 9.3, H.3, I.3, I.9

Table 2 ISO 13628-4:1999 5.0, API 16A:1997 4.4 rated working pressure

5.4.2 ISO 13628-4:1999 5.1.3.7 padeyes lifting

5.4.11 API 16A:1997 4.5 , qualification testing, 7.5.8.6 proof testing

5.5.6 ISO 13628-6:2000 7.3.1.3 hydraulic piping

6.3.2.2 ISO 13628-4:1999 5.1.2.1.1 pressure test

6.3.2.3.7 API RP 2SK:1996 vessel offset

6.7.3 ISO 13628-4:1999 4.1.3.7 padeyes, lifting

7.3.3.2 ISO 11960:2001 6.2.10 hardness testing

8.3.3. ISO 13628-4:1999 gas testing

8.3.4 ISO 13628-6:2000 11.2.1 pressure testing

9.2 ISO 13628-4:1999 5.6, shipping storage and marking

9.3 ISO 13628-6:2000, Clause 12 and 12.1, shipping storage and marking

H.3 ISO 10423 Guidance of testing of non-metallic seals in ISO 10423:2001 F1.13

I.3 ISO 10423 Qualification should be performed in accordance with ISO 10423:2001 F.1.11 and F.1.13 for metallic and non-metallic seals

I.9 ISO 10423 Guidance on pressure and temperature cycle testing can be found in ISO 10423:2001 F.1.11

Noted

This issue was checked in the last revision and issuing dates removed when possible. In cases where reference is given to specific section then issuing dates are required in order to be auditable.

The following changes have been made to Clause 2:

ISO 10423:2003

ISO 11960:2001

ISO 13628-4:1999

ISO 13628-6:2000

ISO 13533:2001

The following changes have been made in main text:

Table 2 , ISO 13533:2001 5.4

5.4.11 ISO 13533:2001 5.5 , qualification testing, 8.5.8.6 proof testing

H.3 10423:2003F1.13

I.3 10423:2003 F.1.11 and F.1.

I.9 ISO 10423:2003 F.1.11


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NL Throughout Ed Syntax: “considerations” should be “consideration” in 4.13.2, 6.3.2.2 EXAMPLES, 6.4.11.2, 7.2.1, 7.2.14, B.3.4 last para

Accepted

NL Table 3 Ge No IMO document listed in this ISO Add to Bibliography Accepted

International Maritime Organisation (IMO)

IMO circular 645, Guideline for vessels with dynamic positioning systems, 6 June 1994

NL 4.9 Is7 sentence Ge To keep Annex B informative replace "and Annex B." by "and the guidance given in Annex B." Accepted

NL 4.14 Te/Ed Motherhood; this applies to any engineering project Suggest to delete Not acceptable

Important contractual relevance.

NL 4.17, 7.2.10.3

1st para Ed British English used throughout this ISO “program” should be “programme”, also in 8.5, 11.9, I.1.2

Accepted

NL 4.19 1st para Ed Typo “manufacturers” should be “manufacturer’s” Accepted

NL 5.3 5th para Ed Typo “drift-sizes” should be “drift sizes” Accepted

NL 5.4.2 10th hyp item Ed Typo “purchasers” should be “purchaser’s”. In last two hyp’d items, “Bolted” should be “bolted”

Accepted

NL 5.4.3 7th hypd item Ed For consistency Delete “shall” Accepted

NL 5.4.4 5th para Ed Typo Insert comma after “However” Accepted

NL 5.4.4 6th para Ed SSTT not defined in 3.2 “SSTT” should be “subsea test tree” Accepted

NL 5.4.6.1 1st sentence Te/Ed Error? Should “tubing/tree” be “tubing hanger” ? Accepted

NL 5.4.11 Last line Ed Typo “purchaser” should be “purchaser’s” Accepted

NL 5.4.12.1 7th para Ed Typo “used; consideration” should be “used, consideration”

Accepted


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NL 5.4.12.2 Para 4 & 5 Ed Typo First “design” should be “designed” Accepted

NL 5.4.14 5th para Ed Typo Insert space after “umbilical(s)” Accepted

NL 5.4.16 1st para Ed For clarity “over length” should be “extra length” Accepted

NL 5.4.18 12th para Ed Word missing “design the” should be “design of the” Accepted

NL 5.4.20 4th para Ed Syntax Move “based on…analysis” to after “determine” Accepted

NL 5.4.20 12th para Te/Ed What is meant with “man rider”? typo? Check/amend

utility

Accepted

Man-riser winch is the trade name for a personnel lifting winch. To be more general man riser winch will be changed to:

"personnel lifting winch"

NL 5.4.21 8th para Te/Ed Error? “design” should presumably be “swivel” Accepted

NL 5.4.22 1st para Ed First sentence, word missing Insert “be” after “may” Accepted

NL 5.4.26 Last para Ed Typos 4th sentence, “design” should be “designed”. Last sentence, insert “in” after “be”

Accepted

NL 5.5.4 2nd sentence Ed LRP, SSTT and THRT not defined in 3.2 Write these out in full. And “wire” should be “wireline”

Accepted

NL 6.2.4 NOTE 1 Ed Typo “formulae’s” should be “formulae” Accepted

NL 6.2.4 6th para Ed Typo “valves” should be “values” Accepted

NL 6.3.2.2 1st, 2nd sent Ed Word missing / word too much Insert “of” after “one”. Delete “to” after “than” Accepted

NL 6.3.2.2 2nd para Te/Ed For clarity/consistency, p subscript id to be defined Insert “p subscript id” after “design pressure” Accepted

NL 6.3.2.2 Equation (3) Te/Ed In the line above it is a typo. Below it the definition of density is missing.

“ro subscript I” should be “p subscript I” (pressure). Add below “where”: “ro subscript I is the density of the internal fluid”

Accepted

NL 6.3.2.3.1 Ed Word too much Delete “of” after “account” Accepted


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NL 6.3.2.3.7 d) Ed Syntax “lines” should be “line” Accepted

NL 6.3.3 h) 2) Te/Ed What is meant with “rucker wire”? typo? Check/explain Accepted

It is only required to refer to the tensioner. The term "rucker wire" shall be deleted.

NL 6.3.4.1 6th para Ed ISO terminology and syntax “are expected to” should be “should” and “particular” should be “particularly”

Accepted

NL 6.3.4.2.2 NOTE 2 Ge Morison equation: no reference document required?. (Accepted that this is a well known equation.)

Check/amend Noted

NL 6.3.4.4 b) Te/Ed Error? Should “vessel intended” be “vessel-induced”? Accepted

"vessel-induced"

NL 6.4.1 1st para Ed Syntax Insert comma after “Table 2” Accepted

NL 6.4.4 2nd para Ed Syntax/legibility Insert comma after “surfaces” Accepted

NL 6.4.8 3rd para Ed Words missing Insert “given in” after “factors” Accepted

NL 6.4.8 NOTE Ed Syntax “given” should be “taken” Accepted

NL Fig.10 Table Te/Ed Po “operating pressure” should be “external pressure” acc.to 3.3

Check/amend Accepted in principal

Change po to pio

Revise Figure 10

Revise Key

Include new symbol in 3.3

pio is the internal operating pressure.

NL 7.1 2nd sentence Ed Grammar “are governed” should be “is governed” Accepted

NL 7.2.3 1st sentence Ed Typo “considered; The” should be “considered. The” Accepted

NL 7.2.11 2nd para Ed Typo 22.05 should be 22,05 (decimal comma) Accepted


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NL 7.2.13.2 NOTE 2 Ed Typo, semicolon missing Insert semicolon after « etc. » Accepted

NL 7.2.14 Last sentce Ed Syntax “considerations shall be performed” should be “care shall be taken”

Accepted

NL 7.2.19 Te/Ed Does this not belong in 9 ? Check/amend Not accepted

This marking in this clause refers to marking for material traceability

NL 7.2.21 1st sentce Ed Typo, for consistency “resume” should be “résumé”, also in 11.10 2nd sentce

Accepted

NL 7.2.22 Te/Ed Does this not belong in 9 ? Check/amend Accepted in principal

This clause refers to fabrication phase.

1st para: delete 2nd sentence.

NL 7.3.3.3 1st sentce Ed “heat treatment” appears twice Delete one “heat treatment” Accepted

NL 7.3.3.3 5th para Ed 5th para duplicates 2nd sentence of 4th para Delete 5th para Accepted

NL 7.4.3 2nd para Ed Typo Insert comma after “relevant” Accepted

NL 7.4.12 1st para Ed Typo “heat-treatment” should be “heat treatment” Accepted

NL 7.5.1 5th para Te/Ed Logic “materials” should be “thicknesses” Accepted

NL 8.3.2 3rd para Ed Typo “provide” should be “provided” Accepted

NL 8.7 3rd sentce Ed Word missing Insert “a” before “minimum” Accepted

NL 10.3 a) Ed Word missing Insert “planned” before “design” Accepted

NL 11.2 3rd para Ed Syntax Place comma after “to” Accepted

NL 11.5.1 Below eq 29 Ed Consistency / typos Insert “is the” after Te, M and pec. The existing cases of “is the” should be in normal font

Accepted


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NL Fig.11 Te/Ed Legend T on horizontal axis should be Te Amend Accepted

NL 11.9 First c) Ed Typo, period missing Place period after “operation” Accepted

NL 11.10 Last para Ed Consistency in terminology “Owners” should be “user’s” Accepted

NL Annex A Ed Annex A is nowhere mentioned in the main text. Refer to Annex A somewhere in the main text Accepted

5.4.9 3rd para. new 2nd sentc.: " For separate tree running tool designs, a standard interface to the WCT-BOP is proposed in Annex A, for vertical trees. "

NL Annex A NOTE 5 Ed Text logic: this should not be a NOTE Delete “NOTE 5”; place text after it in normal font Accepted

NL Table A.1 Ed Inch sizes such as 41/16 etc. incorrectly typed Amend to 4 1/16 (or 4-1/16) etc. Accepted

4 1/16, 5 1/8, 13 5/8

NL Figs. A.1, A.2

Ed Key legends in figures hardly legible Print larger Noted


NL B.2.1.1 1st sentce Ed Syntax Insert “assemblies of” before “riser”. After “frames” place comma and delete “assemblies”


Assemblies have been deleted after frames.

NL B.2.1.4 Last para Ed Typo “manufacturerr” should be “manufacturer” Accepted

NL B.2.1.6 5th sentce Ed Syntax “strength, stroke” should be “strength and stroke”

Accepted


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Annex (e.g. 3.1)


Note (e.g. Table 1)

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NL Figs. B.1-B.3

Ed Key legends in figures hardly legible, also Figs. B.6/7/8 Print larger Noted


NL B.2.2.1 Te The difference between a)1) vs a)3), a)2) vs a)4) and b)1) vs b)2) is the presence of “tubing, tubing hanger” but it is not indicated why

Clarify Accepted

The significance is the weight of the tubing compared to no tubing weight. But this is considered to be over specified. Therefore the following shall be deleted:

a)3), a)4) b)2)

NL Fig.B.2 Te/Ge For clarity and consistency Add to Key: “A,B,C,D,E see Table B.1” Not accepted

A, B, C, D, E are dimensions and are included in Table 1. Including these in the key would infer the same for Figures F.1 and F.2

NL Table B.1 Title Te/Ge For clarity and consistency Add to title: “(see Figure B.2)” Accepted

NL B.2.2.2 Last para Ed Typos “its” should be “it”. “don’t” should be “do not” Accepted

NL B.2.2.4 3rd para Ed Grammar in last sentence “do not exceed” should be “does not exceed” Accepted

NL B.2.2.4 4th para Ed Word missing Insert “to” after “according” Accepted

NL B.3.2.2 2nd sentence Ed Syntax “sufficient” should be “sufficiently” Accepted

NL B.3.3.1 2nd para Ed Syntax in last sentence “length of” should be “lengths of the” Accepted

NL B.3.3.1 Last para Ed Word missing Insert “a” before “specially” Accepted


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Annex (e.g. 3.1)


Note (e.g. Table 1)

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NL B.3.4 1st para Ed Typo (?) “transient’s load” should be “transient loads” (?)

Accepted

NL Table B.3 Title Ed Syntax « analyses » should be « analysis » Accepted

NL C.1.3, C.5.1 2nd para Ed Syntax « environmental » should be environment- » Accepted

NL C.1.5 5th para Ed Typo in 1st sentence / word missing in 3rd sentence “be summed” should be “by summed”. Insert “the” after “establish”

Accepted

NL Table C.2 Ge Sgs not defined here, but in 3.3. Km not defined here, but in 3.3 and C.2.3. Kt not defined here but in 3.3 and C.2.4. Sb not defined here but in 3.3 and C.2.3

Add definitions here, certainly if 3.3 is to be deleted (see above)


Symbols will be defined in below Table C.2

Otherwise equation symbols are defined in the text based on the principal of first time use to aid readability but to limit repeated symbols list below equations.

NL C.2.3 Ge Is cross-ref to D.2.3 correct? Sb not mentioned there Check/amend Accepted

Delete reference to D.2.3

NL Figs.C.3/C.7

Ed Key legends barely legible Print larger Noted


NL C.2.5 Ge Ab,s and db not defined here but in 3.3 Add definitions here if 3.3 is to be deleted Not accepted

Ab,s is defined in text above equation C.6.

Db is defined below equation C.7


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NL C.3.1 1st para Ed One word too much “welds can is” should be “welds is” Accepted

NL C.3.1 6th para Ed Syntax “potential” should be “potentially” Accepted

NL C.3.3.3 3rd para Ed Grammar in 1st and 2nd sentence “falls” should be “fall”. “have” should be “has” Accepted

NL C.4 Ed Typo below equation (C.21) Second “is the” should be in normal font Accepted

NL C.4 Ed Word missing in sentence below equation (C.26) Insert “should” before “be specified” Accepted

NL C.5.3 3rd para Ed Typo/syntax in last sentence “method” should be “methods” Accepted

NL C.6.2.3 Title Ed Typo, also in 1st sentence “gaussian” should be “Gaussian” Accepted

NL C.6.3 3rd para Ed Syntax in 2nd sentence “recommend” should be “recommended” Accepted

NL C.6.3 4th para Ed Typo Delete closing bracket after “C.10b” Accepted

NL C.7 Ed Word missing in sentence below equation (C.49) (?) Insert “which” before “fatigue” Accepted

NL C.7 9th para Ed Word missing Insert “made” before “regarding” Accepted

NL C.7 10th para Ge Reference to “BS and API” insufficient Add Bibliography item numbers Accepted

Change to see BS 7910 [18] and API RP 579 [9]

NL C.7 11th para Ed Typo Delete comma after “normally” Accepted

NL C.8.1 2nd hyp item Ed Typo “peeing” (!) should be “peening” Accepted

NL D.1.3 NOTE Ed Typo 1.5 should be 1,5 (decimal comma) Accepted


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Annex (e.g. 3.1)


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NL D.2.1 5th para Te/Ed 2nd sentence rambles, presumably part missing Check, amend

Accepted

Change 5th para 2nd sentc to:

The reason for the non-conservatism is related to the non-linear stress distributions associated with heavy wall sections are not accurately represented by the implicit linear stress distribution utilised in the stress categorisation and classification procedure.

NL D.2.1 4th para Ed Word too much “part to of” should be “part of” Accepted

NL D.2.3 Eq. (D.14) Ed For consistency, in sentence below it Insert “is the” before “applied” Accepted

NL D.2.3 NOTE 3 Ed Syntax “stress” should be “stresses” Accepted

NL D.2.4 2nd para Ed Syntax “to affecting a seal” should be “affecting a seal’s performance”

Accepted

NL D.2.5 4th para Ed Syntax « as the most” should be “at the most” Accepted

NL D.2.5 Last sentce Te/Ed Rambles, presumably part missing Check, amend

Accepted

Last paragraph shall be deleted. Tolerance effect for typical C/WO riser connectors are small

NL E.1 d) Ed Typo Semicolon at end should be a period Accepted

NL E.3.2 a) Ed Typos Should be 129,29 mm (5,09 in) (decimal commas)

Accepted

NL E.3.2 Eq. (E.1) Ed Typo 135,0 should be in normal font Accepted

NL Annex F Ed Typo: under “C/WO riser….parameters” “insider drilling” should be “inside drilling” Accepted


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NL Annex F Ed A few unnecessarily large spaces between words Amend Accepted

Change from center to left justified

NL Figs F.1, F.2

Ed Key legends barely legible Print larger Noted


NL Fig. F.2 Te/Ed Key missing Add Accepted

Note that this table was included in proposal by the task group but has be omitted by ICS.

NL G.2.4 Eq. (G.12) Te/Ed Typo “db;0,75” should presumably be “db / 0,75” Not accepted

Lse shall be the minimum of either Db or the product of 0,75*(Rto,5/T,stud)/(Rt0,5Tt,tapped)

Include last expression in parenthesis to aid readability.

NL G.3 2nd / 3rd para Ed Typos “valves” should be “values” / “values” should be “value”

Accepted

NL G.3 Last para Ed Typo: “Some factors which affect tension…are” Should be in normal font size Accepted

NL H.1 1st para Ed 2nd sentence: word missing Insert “be” before “impervious” Accepted

NL H.1 4th para Ed Syntax Comma after “time” should be semicolon Accepted

NL H.3 1st para Ed Typo Delete closing bracket at end of last sentence Accepted


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NL I.1.2 3rd para Te/Ed Syntax last sentence “to affecting a seal” should be “affecting a seal’s performance”

Accepted

NL Annex I Te Should this annex not be (partly) replaced with ISO 21329 “Testing procedures for mechanical connectors” ?. Possibly too late at this stage.

Check / amend. Possibly consider at next revision.

Noted

ISO 21329 in it present form is not considered directly applicable to dynamic riser connectors.

NL I.1.4 8th para Ed Typo “manufacture’s” should be “manufacturer’s” Accepted

NL I.1.5 2nd para Ed Typos “suitabley” should be “suitably” (2x) Accepted

NL I.1.6 NOTE Ed Typos Should be in smaller font. “Zinc” should be “zinc”

Accepted

NL I.1.12 Title Ed For consistency Place hyphen in “Third-party” Accepted

NL I.3 Last sentce Ed Word missing Insert “be” before “performed” Accepted

NL I.3, I.5 Te/Ed Conversion wrong (from psi to MPa) 0,138 MPa should be 1,38 MPa and 0,207 MPa should be 2,07 MPa

Accepted

NL I.5 5th para Ed Typo “leak-lightness” should be “leak-tightness” Accepted

NL I.6 1st hyp item Ed Typo “manufacture’s” should be “manufacturer’s” Accepted

NL I.8 1st sentce Ed Syntax “test” should be “tests” Accepted

NL I.10 Last sentce Ed Syntax “test” should be “tests” Accepted

NL I.10 Last sentce Ed For consistency Place hyphen in “three-dimensional” Accepted

NL Bibliography

Ed Typos: Titles of [16], [18], [37], [38] and [39] Should be in italics; and in [27]: “ENV” should be “EN”

Accepted

NO 3.1.85 ed The term "lower riser package" is incorrect it should be "lower workover riser package

Change to "lower workover riser package" and include an addition definition for "lower riser package"

Accepted


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Annex (e.g. 3.1)


Note (e.g. Table 1)

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NO 5.4.6.3 te It shall be possible to override the interlock at any time (e.g. automatically during an EQD).

Accepted

Include at end of 4th para:

(e.g. automatically during an emergency quick disconnect).

NO 5.5.2 te "The system shall be designed to ensure that no single failure will cause a total system shutdown or prevent the ability to secure the well."

An overall objective is to design the system to ensure that no single failure will cause a total system shutdown or prevent the ability to secure the well.


2nd para shall be changed as follows:

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. Consideration shall be given in the design to early detection of failure or redundancy for critical components, which cannot be designed according to this principal.

NO 6.2.3 Item a) te "Riser joints and components shall possess ductile resistance unless the specified purpose requires otherwise;" This requirement may open for use of brittle materials which is not the intention. The following rewording is recommended:

"Riser joints and components shall possess ductile and tough resistance;"

Accepted


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Annex (e.g. 3.1)


Note (e.g. Table 1)

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NO 6.2.4 3rd ident, page 80

ed "valves" should be "values" "For temporary operational conditions the most

probable extreme combined load effect for the following return values shall apply:"

Accepted

NO 6.3.4.4 te There is no guidance on which wall thickness should be used in the load effect analysis

"Variation in pipe wall or component wall thickness over the service life of the riser system shall be considered in the fatigue life calculations, i.e. running, operational and hang-off conditions. The global fatigue analysis may be based on nominal wall thickness while the fatigue stresses may be based on average representative wall thickness, i.e. the nominal wall thickness minus half the corrosion allowance."

Accepted

Insert after 3rd para.

NO 6.3.4.4 ge Only a general reference is made to Annex C for further details

"Stresses to be considered in the fatigue analysis are given in Table C.2. , for further details, see Annex C"

Accepted

NO 7.2.7 3rd para. te The restriction to Cr 1.25% max prevents the use of commonly used low alloy steels. There is no technical justification for this limit.

"Low alloy steels, including AISI 4130 and AISI 4140 should be modified as follows: P: 0,025 % max and S: 0,025 % max."

Accepted


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Annex (e.g. 3.1)


Note (e.g. Table 1)

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NO 7.2.9 Table 15 te The maximum hardness requirement for non-sour service and cathode protection of HV10 320 is not consistent with 13628-4.

Hardness requirements should be consistent through the different parts of ISO 13628.

Subclause 5.1.3.4 in ISO 1628-4:1999 states HRC 32

Draft version of ISO/DIS 13628-1: 2004 states:

Clause 6.6.1

Submerged parts subjected to CP.

SMYS < 700 MPa for low alloy steel material

SMYS < 720 MPa for low alloy steel bolts

Actual yield < 900 MPa or 300 HB

Carbon steel welds < 325 HV10

ISO/DIS 13628-7.2 states

Clause 7.2.8

Parent, weld and HAZ < 350 HV10

Clause 7.3.5

Carbon/low alloy bolting < 350 HV10

ISO 13628-4:1999

Clause 5.1.3.4 states HRC 32 for submerged low alloy closure bolting

Noted

NO 7.2.11 2nd para. te The requirement for conducting hardness testing with the Vickers HV10 method, is applicable only for testing of welding procedures. For testing of forgings and other base materials, it should be possible to use also other methods, such as HB and HRC. It is therefore, proposed to reword this paragraph to read:

Hardness testing of welding procedure qualifications shall be performed using the Vickers method in accordance with ISO 6507-1 with a test force of 98,07 N (22.05 lbf), i.e. HV10."

Accepted


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Annex (e.g. 3.1)


Note (e.g. Table 1)

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NO 7.3.5 5th para. te The maximum hardness requirement for bolting of 350 HV10 is not consistent with ISO 13628-1 and 13628-4.

Hardness requirements should be consistent through the different parts of ISO 13628.

Subclause 6.4.2 in ISO 13628-1:1999 states HB 320

Subclause 5.1.3.4 in ISO 1628-4:1999 states HRC 32

Noted

US Te please reinstate the abbreviation LWRP in the definitions section. (LRP + EDP)

Accepted

US 3.2 Ed ASTM was FORMERLY known as the American Society of Testing and Materials. The organization is now known as ASTM International.

"Revise American Society of Testing and Materials" to "ASTM International".

Accepted

US 4.11 Ed It is unlikely that "legislation" will speak to barrier requirements. "Regulations" would be a more appropriate term.

Change "legislation" to "regulations." Accepted

US 4.13.2 Te Table 3 speaks to an "IMO consequence class" without a reference having been provided to this information.

Include a reference to where the "IMO consequence class" can be found.

Accepted


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Note (e.g. Table 1)

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US 4.6.2 Te A systematic review is required to determine compliance with "regulatory requirements"; however, there does not appear to be a requirement for the user/operator to specify the regulatory jurisdictions in which the equipment is intended to operate. Appendix "F" speaks only to "additional" regulations, not base requirements as are implied in 4.6.2

Add a new clause,revise a paragraph within an appropriate existing clause to require the user/operator to specify the regulatory jurisdictions in which the equipment is intended to operate, or revise Appendix F to eliminate "Additional" and the blocks for yes and no, so that specific regulatory requirements will be specified.

Accepted

Change 4.12 from "References, codes and standards" to " Regulations, codes and standards.

Include new 1st para:

"The C/WO riser system shall comply with the applicable regulatory requirements. User/operator shall specify the regulatory jurisdictions in which the system is intended to operate."


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US B.2.1.6 Te Both B.2.1.3 and B.2.1.5 refer to (allowable) wave height in determining the operating envelope, yet B.2.1.6 implies that the designer will prepare graphs for determining the operating envelope on the basis of "significant wave height." Is it intended that the user interpret the limiting wave height as being the value of "significant wave height" shown on the charts -- thus being conservative, or is it intended that the user actually have equipment on board for statistically determining the significant wave height? Is the intended limit of the operating envelope reached when the observed wave height reaches the value of the "significant wave height" on the charts?

Clarification needs to be provided regarding the intended use of "significant wave height" in the charts. If it is intended that the user actually use "significant wave height" then there should be a reference to guidance on how this is to be determined.

Accepted

Please note that Annex B is informative and the figures are typical. The point raised is relevant.

B.2.1.6 insert following as new 2nd para:

"The parameters used for the setting of operating shown in Figure B.1 are functional and environmental. To ensure for safe operation these parameters should be monitored. These parameters may be monitored directly or indirectly. The method of monitoring and accuracy of measurement of these parameters should be accounted for in the setting of operating limits. Operating limits based on direct monitoring of environmental parameters (e.g. wave height, current and offset) will be less restrictive than indirect monitoring (e.g. vessel heave, pitch, roll etc.)."

US Section 2 – Normative References

Ed ISO 13628-1 is not referred here. Add ISO 13628-1 reference. Accepted.


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US Section 3.1 – Terms and definitions

Ed Secure condition, secure status. There are no references or definitions of these two terms that are used frequently in the text. It should refer to the definition of barriers in other ISO specifications.

Add definitions of Secure condition and secure status. Also refer to the definition of barriers in other ISO specifications.

Accepted

Only one term shall be used i.e. "secure status"

Definition of secure status: Establishment of two independent barriers between the reservoir and the environment"

US Section 4.11 – Barrier requirements

Te 2nd paragraph - “At least two independent and tested barriers between the reservoir and the environment shall, as a rule, be available in order to prevent unintentional flow from the well.”

Replace shall with should. Simpler C/WO riser systems may have only one barrier to the environment (e.g. in a non-cased open riser system).

Refer to barrier philosophy from ISO 13628-1 document.

Accepted

At least two independent and tested barriers between the reservoir and the environment should be available in order to prevent unintentional flow from the well

Accepted

"General guidance on barrier philosophy can be found in ISO 13628-1[xx]."


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US Section 4.11 – Barrier requirements

Te 3rd paragraph – “No single failure of a barrier or a barrier element, whether caused by operator error or equipment failure, shall lead to an unacceptable safety environment incident.”

Substitute shall by should.

Properly define “unacceptable safety and environment incident”.


No single failure of a barrier or a barrier element, whether caused by operator error or equipment failure, shall lead to a loss of well control.”

US Section 4.13.1 – General

Te 2nd paragraph – “C/WO riser system operational parameters shall be monitored at all times …”

Replace shall with should.

Better definition of operational parameters and the minimum to be monitored.

Possibly create a specific section to deal with riser monitoring systems and recommendations.


To eliminate the possible misunderstanding of a requirement for continuous monitoring it is proposed that "at all times" is deleted such that the requirements would read:

"C/WO riser system operational parameters shall be monitored to ensure that the riser is being operated within prescribed limits, see 10.4 and Annex B. The operational parameters may include parameters such as wave height and period, vessel heave, vessel offset and top tension."

Note the term "may" in the 2nd sentence means the listed parameters are optional. Also note that 10.4 states that a monitoring system is not mandatory. Annex B is informative.


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US Section 4.7.1 – Riser System

Te Currently the table 1 does not reflect the state-of-the-art for workover and intervention operations using Horizontal and Conventional trees. Conventional tree designs have had inside drilling riser well interventions. The table refers only to Horizontal trees for this mode. Furthermore, there are other hybrid tree designs being or already developed by vendors that should be included in this table or at least a NOTE should be included.

Consider additional text to cover the hybrid designs in use today. Or, at least, refer to there being other options.


Note that Table 1 is classified as Typical (i.e. informative).

Table has been updated to included VXT well intervention inside a drilling riser.

A note has been included. "These modes of operation are typical for horizontal and vertical trees . Other modes of operations may apply for existing and future tree designs.

US Section 4.7.2 Figure 3 – Typical C/WO riser GA – T

Te In the drawing there is no reference to a HT system variation.

Add a reference to a HT system variation. Noted

These figures are given as examples i.e. typical. It is not the intention to give figures for all possible configurations

US Section 4.9 – Operational Principles,

Te 2nd paragraph - “The C/WO riser system shall be designed and operated in a way that ensures its ability to resist the most extreme loads that it may be subjected to during operation.”

This statement should be re-written and the word shall be substituted by should. Also, a better definition of most extreme loads should be added.

Accepted in principal.

Replace 1st sentc with the following:

"For all operations the system design shall account for the most unfavourable combination of functional, environmental and accidental loads, which can be predicted to occur simultaneously, see 6.3."


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US Section 5.4.10 – Emergency Disconnect package

Te 6th paragraph – “The minimum disconnect angle should be 10 deg”

Comment: This seems quite a large minimum angle for a high-angle release mechanism. In fact, we know of several in use that don't meet this criteria. Where is this figure originally derived/required ?

Noted

10 deg and greater has been a north sea requirement for more than 15 years. 10 degrees relates to 90% availability limit in API RP 16Q combined with loss of single anchor for moored vessel and drift-off for DP vessel.

US Section 5.4.11 – WCT-BOP

Te General comment: There are designs available that incorporate the WCT-BOP function into the TRT, removing the need for a WCT-BOP.

Suggest a reference to this alternate design practice.

Noted

5.4.9, 3rd para states that the TRT may be integral with the WCT-BOP


Te 9th paragraph – “The WCT-BOP shall include methanol injection line/port…”

Replace shall with may. Accepted

Accepted replace shall with should


Te 10th paragraph – “A pressure sensor shall be located in the production bore…”

Remove shall, and replace with may Accepted


Ed General comment: There are many “shalls” in the text, where “shoulds” would be more applicable.

Suggest reviewing shall and should designations. This is an RP, not a Spec.

Noted

ISO 13628 is a standard not a recommended practice and therefore includes shall as well should. Shall is used with regard to safety and should is used with regard to operational convenience.


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Ed 13th paragraph – “The ram assemblies with actuators shall be designed…”

Replace shall by should. Accepted

US Section 5.4.12.2 – Emergency disconnect package co

Te Section 5.4.12.2 – Emergency disconnect package connectors

Remove this reference to 25%.

Not accpted

The 25% guidance comes from ISO 13628-4 clause 7.7.3.1 which states:

" Tree and TH spool connectors shall be capable of containing hydraulic release pressure of at least 25% above normal operating release pressure in the event that normal operating pressure is inadequate to effect release of the connector"

For an EQD connector, increase in pressure following failure to disconnect is not a feasible solution, therefore a typical 25% increase in force is recommended which may be achieved by increased unlock normal operating pressure or increased actuator of piston area.

US Section 5.4.12.2 – Emergency disconnect package co

Ed 8th paragraph – “The connector shall allow for low pressure back seal resting…”

Replace shall with should. Accepted


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US Section 5.4.12.3 –C/WO riser joint connector

Ed 6th paragraph – “Connector torque resistance shall be sufficient …”



Connector torque capacity shall be sufficinet to allow for the following where applicable:

• connector make-up and break-out;

• vessel weather vaning;

• tubing hanger orientation;

• subsea test tree connector orientation during re-entry;

• shearing of any mechanical secondary release mechanisms.

US Section 5.4.18 – Surface tree

Ed 8th paragraph – “Wing and kill outlets shall be arranged 90 degrees down”


US Section 5.4.3 – Landing string

Te 7th bullet – “shall provide the control line termination at its top and route all hydraulic/electrical lines from thereto the equipment within the landing string …”


Simpler landing strings may not comply with this statement

Accepted


Te 8th bullet – “… secure status …” Reference the definition of secure status; ie. number of barrier and barrier elements.

Accepted

See observation above


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Te 2nd paragraph – “The landing string assembly and its individual components shall include anti-rotation feature to permit torque transfer during orientation of the tubing hanger…”

Substitute shall with may, if required.

A true concentric tubing hanger may not require this feature. Does the drill pipe riser have an anti-rotational feature ?


"The landing string assembly and its individual components used for the insatllation of orientated tuging hangers shall include anti-rotation feature to permit torque transfer during orientation of the tubing hanger…….. For non-orienated tubing hangers, anti-rotation features may not be rquired.”

US Section 5.4.4 – Subsea test tree

Te 3rd, 4th and 5th paragraphs – “… shall …” Replace shall with should.

Simpler SSTT designs may still provide similar features, but not comply with these requirements.

Shearing using the lower valve may still maintain the coiled tubing in front of the upper valve.

Different philosophies may be used by different operators.


1st para: Change "secure condition" to "secure status"

3rd para: change shall in first sentc. to should.

4th para: change shall in 1st and 2nd sentc. to should.

5th para: Not accepted. To be fail-safe the valve shall hold pressure from below with the need for pressure assist.

US Section 5.4.4 – Subsea test tree

Ed 16th and 18th paragraphs – “… shall …” Replace shall with should.

Independent primary and secondary disconnection systems may not be a feature of simpler systems and well as chemical injection may not be required


16th para: change shall in first sentc. to should

18th Not accepted. This is standard industry practice. Considered necessary for safe operation


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US Section 5.4.8 – TH Orientation system

Te General comment: A true concentric TH system may not need an orientation feature.

Comment or note to this affect. Accepted

Note For concentric tree designs orientation of the tubing hanger may not be required.

Section 5.4.9 – Lower WO riser package

Te General comment: Simpler designs exist which does not contain as many features as described as mandatory (i.e. “shall”).

Change shall to should, or note that simpler systems may exist.


5th para: change shall to should. To be consistent 3rd para in 5.4.10 change shall to should

7th para .: change shall to should.

8th para 1st sentc.: change shall to should.

10th para 1st sentc: change shall to should

11th para: Change text to "The lower workover riser package should include a guidance system for installation and retrieval of the riser with or without guidelines as applicable"


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US Section 5.4.9 – Lower WO riser package

Te 2nd paragraph – “A Lower WO riser package shall include an emergency disconnect package, WCT-BOP and TRT, compatible with the subsea tree.”

Substitute the shall with may.

There are systems available that combine the WCT-BOP into the TRT, using shear valves.

Accepted

Change shall to may:

"A Lower workover riser package riser package may include an emergency disconnect package, WCT-BOP and TRT, compatible with the subsea tree, see Figure 9 b) and c).”

To be consistant with the above change the following also needs to revised:

Change 4th para. of 5.4.9.4

The WCT-BOP may be equipped with an upper re-entry spool to interface with an emergency disconnect package or with a connection to mate with the lower end of the riser.

Change 1st para. 2 senc. of 5.4.11

The upper end shall be compatible either with the emergency disconnect package or the connection on the lower end of the riser.

Insert 2 new para. in 5.4.10

The emergency disconnect package shall provide for quick disconnect of the riser in the event of loss of vessel station-keeping or unexpected environmental conditions (e.g. dunning)..

The emergency disconnect package may be located just above the WCT-BOP (see Figure 9 c)), or alternatively the emergency disconnect point may be at the tree re-entry spool interface (see Figure 9 a)). Choice of configuration will depend on the type of subsea tree and system requirements (see, 4.0). For example, for vertical tree systems, in the case shown in Figure 9 a), the tree running tool may serve as the emergency disconnect package and the tree valves may be used for well shut-in.

Figure 9 shall be revised to reflect the same as b) and c) in Fig 2 of API RP 17G.


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US Section 5.4.9 – Lower WO riser package

Ed 1st paragraph – “… secure status …” Definition of “secure status” should be addressed or referenced here.

Accepted

See above

US Section 5.5.14 – Control module design

Tel 2nd bullet – “the system shall be fail as-is on loss electrical power and/or communications”

Replace shall for may.

Please explain the rationale for requiring this fail as-is for this failure mode.


This requirement addresses single failures. To make this requirement open for other solutions the following text is proposed.

"the system shall be designed to ensure that loss of electrical power and/or communication does not result in a total system shut down or prevent the ability to secure the well. This may be achieved by the system being fail as-is on loss of electrical power and/or communication";


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Te 5th bullet – “the electronic and hydraulic systems shall be mounted inside a pressure compensated, dielectric fluid filled external housing”

Please re-write this bullet to read differently. Electronics are usually kept in an inert, one atmosphere receptacle, and then mounted in a compensated dielectric fluid housing environment.


5th and 6th list items shall be changed as follows:

All active electronic circuits should be enclosed in nominal one atmosphere gas filled enclosures designed for full external pressure conditions.

Electrical elements of electro-hydraulic components shall be mounted in a dielectric fluid filled and pressure compensated housing.


Te 8th paragraph – “all supply and function line control shall be performed by hydraulic latched, electrically pulsed, solenoid valves”

Replace shall with may.

There are alternative systems that may replace the hydraulic latched solenoid valves with all-electric DCV.

Accepted

US Section 5.5.15 – Umbilicals and jumpers

Ed 8th paragraph – “A minimum of one spare line shall be included in the umbilical.”


Replace with should.

Text shall be as follows:

"A minimum of one spare line should be included in the umbilical unless specified otherwise by purchaser."

US Section 5.5.16 – Multi-quick connector plates

Ed 1st paragraph – “Umbilicals and umbilical jumpers shall be terminated in multi-quick connector plates”



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US Section 5.5.16 – Multi-quick connector plates

Ed 3rd paragraph – “Multi-quick connector plates shall be designed for make-up and break-out by hand”


US Section 5.5.17 – Umbilical winch

Ed 4th paragraph – “The winch shall be equipped with a transverse reciprocating guidance system to evenly spool the umbilical on the drum during the wind-in retrieval.”


Replace with should


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US Section 5.5.17 – Umbilical winch

Ed Section 5.5.17 – Umbilical winch Replace shall for should. Accepted in principal

5th para: Components required for operation of the winch should be mounted on the winch.

6 th para: Change shall to should.

7th para: Change shall to should.

9h para 2nd sentc.: Change shall to should.

9th para 3rd sentc.: The brake shall have sufficient braking capacity to stop and hold the umbilical when subjected to maximum operating tension.

10th para: Change shall to should.

11th para: Changes winches to winch.

12th para 1st and 2nd sentc.: Change shall to should.

13th para 1st and 2nd sentc.: Change shall to should.

US Section 5.5.7 – HPU

Ed 17th paragraph – “The accumulators shall have individual visual indicators of low nitrogen pressure”

Replace shall with should. Accepted:

Change shall to should


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US Section 6.3.4.4 Fatigue load effect analysis

Te bullet c) – “vortex-induced vibrations” Add note for: VIV suppressing devices, if included as part of the design of the system, their effect shall be analysed as well.


Include in last paragraph of 6.3.4.2.2:

The effect of VIV suppressing devices, if included as part of the riser system, shall be analysed.

US Section 6.4.11.4 – Drilling riser flex/ball joint

Tel Table 12

These angles are quite higher than the norm. Is further information on these figures and their derivation available ?

Noted

These angles are based on North sea industry practice for last 15 years. They are comparable with API 16Q recommendation for drilling (i.e. mean 2 deg , maximum 4 deg)

US Section 6.4.9 Fatigue and Fatigue inspections

Ed 4th paragraph – “C/WO risers should be designed so that vortex-induced resonant vibrations are prevented, whenever practical.”

Add note referring to VIV suppression devices. Accepted

“C/WO risers should be designed so that vortex-induced resonant vibrations are prevented, whenever practical. Vortex suppression devices may be used as a method to minimise the strength of vortex-induced resonant vibrations, for further details see, API RP 2RD [2]


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US Section C.5.3 VIV

Tel This section should be expanded with additional information and further details of the analysis to be performed and the envelopes for consideration in the maximum fatigue exposure (i.e. 100 year current profile, etc).

This section should be expanded with additional information and further details of the analysis to be performed and the envelopes for consideration of the maximum fatigue exposure (i.e. 100 year current profile, etc).

Noted

Will be considered as future work item.

** General ed Document very well prepared; a few points to save time at ISO/CS are given below.

Noted


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** 3 Terms and defs

ed Terms (and defs therefore) shall be given in singular;

pls list synonyms under the preferred term rather than in a Note.

Cross-refs not permitted as a definition, list word as synonym under preferred term

e.g." accidental load" not "...loads"

Delete 3.1.144 and renumber remaining terms.

Accepted

The following terms have been changed to singular:

Accidental load Buoyancy model Kill and choke line Drill pipe riser Functional load Gimbal Integral riser Make-up tool Non-integral riser Operating mode Primary load Primary stress Secondary load Secondary stress Shearing valve Stab sub Vortex induced vibration

Accepted

List of synonyms have listed instead of in notes:

Apparent weight

BOP adapter joint

Accepted

** General ed Couple typos not caught by spellcheck 3.1.110 "partly of wholly" to be "partly or wholly"

6.6.1.2 "confirm" to be "conform"

Accepted

Accepted


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** Lists ed Reminder-- cannot have two sets of a) b) c) in same subclause (impossible to refer to one clearly)

In 4.13.2, 7.2.10.3, 11.5.1, 11.9 pls change one list to unordered (dashes)

Accepted

** General ed It is preferable to have only one Scope in the doc., becaouse of its special meaning

Pls rethink/find another word in C.1.1, 7.1, D.1 Accepted

C.1.1 change from scope to purpose.

7.1 change from scope to introduction

D.1 change scope to purpose

D.1.2 change general to methods


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** Notes ed MANY Notes need to be converted to full text as they give provisions. Look for "should" , "of special importance", "may" when clearly permission

See e.g. notes in 6.4.8, 6.4.11.2, 6.5.2, 6.6.6, 6.6.7, 7.2.13.3, 7.3.5, Annexes A and D-and elsewhere

Accepted

The following notes have been converted to full text: Note 1 in 4.6.3 Note 2 in 4.6.3 Note in Table 4 Note 1 4.17 Note 2 in 4.17 Note 5 in 6.2.4 Note in 6.3.2.2 Note 2 in 6.3.2.3.2 Note in 6.3.2.3.5 Note 2 in 6.3.2.3.7 Note in 6.3.2.4 Note 1 6.3.4.2.2 Note in 6.4.8 Note 2 in 6.4.11.2 Note 3 in 6.4.11.2 Note 2 in 6.5.2.2 Note 1 in 6.5.2.3 Note 3 in 6.5.2.3 Note in 6.6.6 Note 1, 2, and 3 in 6.6.7 Note in 6.7.1 Note 1 and 2 in 7.2.13.3 Note 2 in 7.3.5 Note 3 and 4 in Annex A Note 2 in C.4 Note 1 and 2 in C.7 Note 1 and 3 in D.2.3 Note 2 in 4 D 2.4


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** Notes ed Lists in Notes follow same rule as main text, i.e. begin a) b) c)... not 1) 2) 3)

Correct as necessary Accepted

Notes 1 and 2 in 4.6.3 have been converted to full text and list unordered

** Annex C Figs. C.9 and C.10

ed Pl use lower case t for as symbol time Correct as necessary Accepted

** Eqns (C.37), (C.38)

ed Pls use capital M as symbol for moment Correct as necessary Not accepted

m, mo, m1, m2 are spectral moments not bending moments and standardised symbols used by the industry for these variables

** Eqns. (C.48), (C.49)

ed Pl use upright d for derivative (function) and gamma function rather than d (symbol) and Γ

Correct here and elsewhere as necessary Accepted

Also functions fs and f(Sa) has

been changed to fsand f(Sa)

Includes f(Sa) in symbols list

** Bibliography

ed Pls create using template style Biblio Thanks Accepted

** Biblio refs. ed Throughout text, biblio refs should be superscripted [4]

unless part of sentence This is the icing on the cake! Thank you! Accepted

Task Group

General Ed Change all occurrences of "conventional tree" to "vertical tree"

Accepted

Task Group

B.2.2.1 Table B.1 Ed Landing stroke is defined incorrectly Change to: Landing stroke (distance from tubing hanger well head landing shoulder to underneath of the suspended tubing hanger)

Accepted


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Task Group

G.2.3 Eq G.8 Te Change ε to εt , where εt is the scatter in the applied torque during make-up.

Accepted

Symbols list is also updated

Task Group

Annex A Fig A.1 Ed Legend to Figure A.1

2 "Lower workover riser package (LWRP)" should be "Lower riser package (LRP)"

10 "Wireline-coiled cooling BOP" should be "Wireline/coiled tubing BOP"

Accepted

Task Group

6.5.3.3 EQ 25 Te Kim Mørk, DNV in his position as a task group member of ISO 16389 had previously commented on the validity of the combined load design equations in ISO 13628-7.2 at an ISO 61389 task group meeting in May 2004. In order to harmonise the equations in DNV-OS-F201, ISO 16389 and ISO 13628-7 it is proposed that the net external overpressure combined load equation in ISO 13628-7.2 be modfied as shown. This modification will not have any effect on top tensioned C/WO risers designed using the original equation.

oicd

io

pdpd

e pppFpp

MFM

TFT

<≤⎟⎟⎠

⎞⎜⎜⎝

⎛×−

+⎟⎟

⎠

⎞

⎜⎜

⎝

⎛

⎟⎟⎠

⎞⎜⎜⎝

⎛

××+⎟

⎟⎠

⎞⎜⎜⎝

⎛

× 1

95,0

222

Accepted

Task Group

Annex F Table F.1 Te Include the following in Table F.1

Variable= Well head datum to drill floor, Comment = Elevation between well head datum and drill floor at operating draft

Variable = Mean water level to drill floor, Comment = Elevation between mean water level and drill floor at operating draft.

Revise figure to shown telescope joint dimension at operating draft. Include elevation to shackle interface on tension ring.

Accepted


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Task Group

6.4.9 7th para Ed Change "design fatigue life" to "calculated fatigue life", 4 places

Accepted

Task Group

6.4.9 7th para Ed Replace "If the purchaser specifies no service life" with "If the service life has not been specified by the purchaser"

Accepted

Task Group

6.5.3.2 3rd para Te Para graph being In cases where the bending moments" should be deleted.

The equations in 6.5 are based on load controlled conditions. This para. Refers to displacement controlled conditions and may result in low cycle fatigue failure. In order to allow for this degree of loading additional qualification and testing would be required, which at present is not included in the standard

Accepted

Task Group

6.5 New 3rd para Te Include following statement, "Full utilisation of the riser pipe capacities calculated according to the equations given in 6.5, requires that the riser connectors have a level of structural safety comparable to the pipe, see 6.6"

Accepted

Task Group

Annex D Gen Te Precision of the methodology and criteria for the performance and interpretation of elastic-plastic FEA in D.2.4 is required to eliminate misunderstanding.

Accepted

Documents

Template for comments and secretariat observations...NACE, SAE Add these Accepted American Petroleum Institute, 1220 L Street, North West Washington, DC 20005-4070, USA. ASME International,