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EXPLANATORY REPORTRAPPORT EXPLICATIF

ISO/DIS 13628-15N436

ISO/TC 67 / SC 4 Secretariat ANSI

This form should be sent to the ISO Central Secretariat, together with the English and French versions of the committee draft, by the secretariat of the technical committee or subcommittee concerned.

Ce formulaire doit être envoyé au Secrétariat central de l'ISO en même temps que les versions anglaise et française du projet de comité, par le secrétariat du comité technique ou du sous-comité concerné.

The accompanying document is submitted for circulation to member body vote as a DIS, following consensus obtained from the P-members of the committee.

Le document ci-joint est soumis, pour diffusion comme DIS, au vote comité membre, suite au consensus des membres (P) du comité obtenu.

on

at the meeting ofà la réunion du

TC / SC see resolutionvoir résolution

No.no

indans le

document

by postal ballot initiated onpar un vote par correspondance démarré le

2009-01-14

Number Countries

P-members in favour:Membres (P) approuvant le projet:

10 Argentina, Brazil, France, Italy, Kazakhstan, Korea, Netherlands, Norway, United Kingdom, United States

P-members voting against:Membres (P) désapprouvant:

0

P-members abstaining:Membres (P) s'abstenant:

3 Canada, Germany, Indonesia

P-members who did not vote:Membres (P) n'ayant pas voté:

Remarks/Remarques

See Comments below.

I hereby confirm that this draft meets the requirements of part 2 of the ISO/IEC DirectivesJe confirme que ce projet satisfait aux prescriptions de la partie 2 des Directives ISO/CEI

Date

2009-06-12

Name and signature of the secretaryNom et signature du secrétaire

Ed Baniak

FORM 8 A (ISO) FORMULAIRE 8 A (ISO) of/de 23

Template for comments and secretariat observations Date: 2009-04-14 Document: ISO CD 13628-15

1 2 (3) 4 5 (6) (7)

MB1 Clause No./Subclause No./

Annex(e.g. 3.1)

Paragraph/Figure/Table/N

ote(e.g. Table 1)

Type of com-

ment2

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

BR 1 te A figure showing the extent of typical subsea production system identifying manifold, PLET, PLEM and others equipments covered by the scope of this standard will help to understanding the applicability of this standard.

This figure may be similar to one in the standard ISO 13628-1 page 7 – clause 4 – figure 1.

Include a figure at the end of the clause nº 1 showing the extent of typical subsea production system with Manifold, PLET, PLEM and others equipments covered by the scope of this standard.

BR 1 subclause (d)

New component

te The inclusion of Pig Diverter Valves allow continuity of pigging of flowline system. Example: Gas Lift manifold: the pig may be sent by annular flowline and returned by the production flowline.

Include Pig Diverter Valves in the scope covered by this standard.

BR 2 ed Several standards are referred inside this document without being listed in the Normative references, such as:API equivalents for ISO 13626 series (17A, 17F, 17E, etc), API 1111, ISO 13819, API Q1, ISO 9001, Several of UNS standards supporting material grades, API 17P, API 17H, etc

Perform a complete double check around the document and list all reference is missing at this section.

BR 2 ed ASTM A 388 is presented out of alphabetical order. The Normative references list should be presented in alphabetical order in order to facilitate document utilization.

BR 3.1 ed Abbreviation for Carbon Equivalent = CE, CE(Pcm) and CE(IIW) is made at 7.11.1.4.2 (Page 36), but the terms are not list in the abbreviations list.

The list of abbreviation shall contain all the abbreviations used in the document.

BR 3.1 ed The SSIV is not in the abbreviation list. Include SSIV – subsea isolation valve in the abbreviation list.

BR 3.2.14 te We understand that a design has been validated once the following steps (that are objective evidences that the design has been validated for the design requirements ) has been performed:

Verification of design calculation (dimensioning)

Factory process verification (FAT)

Change the text to: Confirmation that specified design requirements have been fulfilled through the provision of objective evidence. Typically this is achieved by calculations, design reviews, performance verification testing and Factory Acceptance Testing.

FORM 8 A (ISO) FORMULAIRE 8 A (ISO) of/de 23 Version 2001-07

Performance verification (PVT)

Site integration testing (SIT)

Also, operational service conditions shall be included in the design requirements.

BR 4.1 Second paragraph

te The topic “The end user should define or approve the following performance and configuration requirements, including” is not considering the following requirements to be defined or approved by end user:

o Design life

o Water depth

o Soil conditions and axial stiffness

o Metocean data

Include the following requirements to be defined or approved by end user in the topic:

o Design life

o Water depth

o Soil conditions and axial stiffness

o Metocean data


te The following considerations related to structures and modules are not being addressed:

o Planned and emergency shutdowns of wells and manifold (including Valves open/close cycles/month)

o Flow rates range (max., min. etc)

o Pressure drops

o Fluid composition

Address the following considerations related to structures and modules:

o Planned and emergency shutdowns of wells and manifold (including Valves open/close cycles/month)

o Flow rates range (max., min. etc)

o Pressure drops

o Fluid composition

BR 4.3 te In order to maintain integrity and functionality in the service conditions the system interface shall take into account the zero seawater ingress.

Include the zero seawater ingress as requirement, changing the text “Zero external leakage” to “Zero external leakage and seawater ingress”.

BR 4.3 te In order to maintain integrity and functionality in the service conditions the system interface shall take into account the internal temperature variation.

Include the internal temperature as requirement, changing the text “External temperature variations” to “Internal and external temperature variations”.

BR 4.3 te To be more extensive about the requirement of potential hydrate prevention.

Change the text “Potential external hydrates” to “Potential hydrates formation”.

BR 4.4.2 te To avoid any doubt of which axis shall be considered, complement the title with (related to vertical and horizontal axis).

Change the title to Alignment (related to vertical and horizontal axis).

BR 5.1.3 te To be more clear regarding what analysis method shall be used for fault analysis.

Include (RAM – Reliability, Availability and Maintainability) at the end of text “Fault analysis capability to identify failed components ….”


resulting the following text: “Fault analysis capability to identify failed components (RAM – Reliability, Availability and Maintainability)”.

BR 5.1.7 New sub-section

te A section related to “Corrosion Protection Strategy”, comprising cathodic protection and painting, should be included as part of the System Design Considerations.

As a suggestion:

“Cathodic protection should be design in accordance with DnV-RP-B401 or equivalent international recognized standard. Special considerations shall the made to material selection when the Manifold of the Subsea structure is part of a impressed current cathodic protection system.”

Paint system should be design in accordance API 17D – Appendix D or equivalent international recognized standard.”

BR 5.3.1 First topic te It is very important to consider actuation valve performance degradation due to wear-out with open/close cycles or natural aging. A wear-out or aged valve may not work properly and jeopardize the gathering produced fluids and/or distribution of injected fluids.

Adapt the text to “The manifold shall provide sufficient piping, valves and flow controls devices to safely gather produced fluids and/or distribute injected fluids such as gas, water or chemicals, and take into account actuation valve performance degradation due to wear-out with open/close cycles or natural aging”

BR 5.3.1 Sixth topic te To be more specific regarding what manifold may provide for testing of individual wells.

Adapt the text to “The manifold may provide for testing of individual wells (pressure and flow rate).”

BR 5.31 New topic te Depending on which depth the manifold will work and considering the density of control fluid, the actuator will have to close the valve against a backpressure higher than 100 psi (the minimum pressure above ambient pressure establish by ISO 13628-4).

Include the topic with the following text: The design shall account for control fluid column (air gap plus water depth) and take account its density as a function of temperature and hydrostatic pressure.

BR 5.3.2 First paragraph

te None of the referenced standards in this paragraph is specifically written for subsea manifold piping systems.

Manifold Piping should be revised because it is completely open allowing the use of parts of different standards to design the manifold piping. However, design methodologies are based on material and quality requirements of a same standard only or in some cases the design methodologies are clearly addressed to other one.

Piping systems for subsea use shall be designed in accordance with BSI PD 8010-2 - Code of practice for pipelines Part 2: Subsea pipelines.


The BSI PD 8010-2 is applicable to subsea pipeline intended for conveyance of hydrocarbon liquids, hydrocarbon gases and others gases, liquid and gases in two-phase flow, fluid base-slurries and water.

BR 5.3.3 te Include: When not specified by the purchaser Internal diameter variations of all pigging components shall be in accordance with the allowable ID variations adopted by the pig manufacturers for solid cast pigs.

BR 5.3.3 te Include: Between any two components (valves, fittings) shall be provided a minimum straight length of pipe equivalent to three nominal pipe diameters.

BR 5.3.3 te Include: Piping branch diameters greater than 50% of the header shall be provided with guide bars.

BR 5.3.5 te For those flow assurance issues identified as having the potential to significantly impact the performance of the system at some time in the life-cycle of the development, further evaluation should be undertaken to predict the extent and severity of the problem as well as to identify possible prevention and remediation measures that may need to be considered.

Include the following paragraph: General flow assurance considerations are given in the standard ISO 13628-1 – Annex I.

BR 5.4.1 Second paragraph

ed To be compatible with other comments. Change the text to: As an alternative, a design verification or design qualification load test of 1.5 times its rated capacity may be substituted for design analysis. The component shall sustain the test loading without deformation to the extent that any performance requirement is not met, and the test documents shall be retained at an agreed location for an agreed time.

BR 5.6 te Design, building and testing of production/injection valves and choke are also covered by ISO 10423 and 13628-4. The standard ISO 13628-4 is especially applicable for subsea equipments (WCT and Wellehad).

Production/Injection valves and choke shall also be designed, built and testing according to the following applicable specifications: ISO 10423 and ISO 13628-4. Therefore the table shall be revised to:

Component Industry SpecProduction/Injection Valves

API 6A / ISO 10423API 17D / ISO 13628-4


Chokes API 6A / ISO 10423API 17D / ISO 13628-4

Control Components API 17F

End Connectors API 17D

Flanges API 6A / ISO 10423API 17D / ISO 13628-4

BR 6.1 Fourth topic te As manifold is an equipment compounded by several components such as valves, control system and connectors, it is very important that theses components are subjected to the qualification testing according to API 6A / ISO 10423 and API 17D / ISO 13628-4.

Change the text to: Performing qualification testing according to this Recommended Practice (for components such as valves, control system and connectors qualification testing shall be performed according to API 6A / ISO 10423 and API 17D / ISO 13628-4).

BR 6.1 Fifth topic te To be clear regarding the prototype shall be subjected to the factory acceptance testing prior to qualification testing.

Adapt the text to: Performing factory acceptance testing of the prototype to be used to perform qualification testing.

BR 6.1 New topic te Product shall be representative of its design and a manner of ensuring it is to define the FAT acceptance criteria during the design validation based on the results of the qualification tests.

Include the following topic: Defining FAT acceptance criteria.

BR 6.2 First paragraph

te The design calculation and design review are part of the design verification.

Include the following topics in the first paragraph: Design calculation verification and Design review.


te We understand that the design verification shall be performed to ensure that the design equipments have been met instead of specific operational requirements.

Change the text to: Design verification is performed to ensure that the design requirements have been met. In certain cases, it is necessary to perform wet-simulation testing to prove correct functioning of components and systems underwater.

BR 7.3 Table 7.3 ge Table 7.3 should also has a column for API standards as it already have for ASTM, EN and ISO standards.

Include API 17D and API 6A as material standard for forged retaining components built in carbon or low-allow steel.

BR 7.6.3 Table 7.5 ed Table 7.5 is split in two parts at pages 29 and 30 of the document.

Re-position the table 7.5, across the text of item 7.6.3 in order that it will not be split in two pages, in order to facilitate document utilization.


BR 7.6.3 Table 7.5 te The present document makes reference to DnV-OS-F101, to API 6A and to API 17D, but the minimum average and single energy value (J) recommend are not aligned with any one of these. Also it is not mentioned the test temperature (see that table 7.4 is missing).

Same comment is made below regarding table 7.8 of the document.

The technical committee could note that values listed at DnV-OS-F-101 for minimum absorbed energy and test temperature are really more realistic to materials class equivalent to PSL-2 and/or PSL-3 than the API-6A or API-17D suggested values.

It is also fare to say that the API 6A/17D proposed values for temperature and energy are applicable in a great amount of equipment worldwide. However, the API 6A/17D values are cleared obsolete for shut down conditions of gas systems in artic applications.

As a suggestion, this document should cleared use the reference of one of these standards regarding absorbed energy value in Charpy V-notch impact test and test temperature instead of specify another set of divergent values.

BR 7.6.4 2nd

Paragraphed 2nd paragraph is a repetition of the 1st paragraph of this

section.Remove 2nd paragraph from the document text.

BR 7.6.5 Last Paragraph

ed Reference to “API 6A718” is made incorrectly. Fix reference to: “API 6A”.

BR 7.9.3.3 Table 7.7 ed Table 7.7 is split in two parts at pages 32 and 33 of the document.

Make table 7.7 in only one segment. Special attention shall be made to avoid heading of tables in one page and entire table in other page.

BR 7.11.1.3.5 Table 7.8 ge Reference for Table 7.4 is made at column “Test Temperature” of the table 7.8 first line. However, there is no table 7.4 is the document.

Include the missing Table 7.4 inside the text of item 7.6.3.

NL 4.3 Te add "Subsea Controls and Chemical Injection" to the list of system interfaces in this section

NL 7.0 Te this is redundant to Annex L in 13628-1 / 17A...... either we remove this section from 17P and use Annex L or the opposite.

NO ge GENERAL COMMENTThe ISO 13628-15 would benefit form providing more specific guidance on the various topics. The freedom of choice is high, and more specific requirements would improve the effect of the document. The comments below try to improve the document with this in mind.

NO 1 First para. ge The scope need rewording as this standard may well provide different to other specifications (and standards).


NO 1 Second para.

ed Second para: Replace “Recommended Practice” with “International Standard”

NO 1 Last para. te Last para: Replace references to API standards with same references to ISO standards.

NO 1.d ge It should be clarified whether branch connectors are part of the scope. The sub-section only refers to flowline connectors.

Branch connectors should be mentioned specifically

NO 2 ed No reference is made to 13628-7 and DNV rules for Marine Operations. These are relevant and should be included.

Include references (see column 5)

NO 2 te Several references are overlapping wrt scope. Review list and evaluate to sort on normative references and informative references.

NO 2 - te Please consider including the following recommended practice:DNV-RP-F112 - Design of duplex stainless steel subsea equipment exposed to cathodic protection

See column 5

NO 2 ed Not all these standards are normative for all type of equipment cover by this document.

Erase “normative”

NO 2 ge Add the following standards:Asme B 31.3, ASME B31.8, Dnv-RP F112 (HISC)Delete the following:TR 1236 (StatoilHydro) internal spec.

Include and delete these standards

NO 2 te Replace references to API standards now issued jointly with ISO to the ISO references. This applies to API 5L, API 6A, API 14E and API 17D. References to ASME B31 Standards of Pressure Piping is too general as B31 includes many parts. Reference relevant part. Reference to NACE MR 0175 can be taken out as it is cobranded with ISO 15156. TR1236 is not an open document and need to be removed. Make sure all references in the text of the standard is correctly represented in Clause 2.

NO 3.1 ed No mention of HIP under ‘Abbreviations’ Include HIP under ‘Abbreviations’

NO 3.2 te Delete references 3.2.1-4 as they are covered by the ISO Directive.

NO 3.2.15 te Is System Integration Testing (SIT) acceptable as verification? If SIT is acceptable, what about FAT or EFAT? Further 3rd part verification should be mentioned

Include FAT and EFAT and describe 3rd party verification in section.

NO 3.2.16 te Is the piping manifold included in the term ‘Template’? Normally the manifold module will be a separate retrievable unit containing the production or injection piping system including valves etc. supported by a steel frame.

Clarify how the manifold module relates to the template.

NO 3.2.16 te No mention of templates for subsea processing plants Processing plants template should be described and defined.


NO 3.2 te When listing the various foundation types as suction piles, driven piles, mudmats – gravity based foundations is not included.

Include gravity based foundation in the listing

NO 4 ed Clause 4 should include structure in title

NO 4.1 ,4.2, 4.3 te No mention of protection against dropped objects (impact protection) or trawl protection in 4.1 or 4.2. This is mentioned in 4.3, but a template or cluster manifold could be integrated with the protection structure, thus this should be included.

Dropped objects and trawl protection should be included in functions that the manifold should fulfil if applicable

NO 4.1 Second bullet point

te The end user should specify the material requirements , not necessarily do the material selection

Rephrase with material requirements

NO 4.1 Fifth bullet point

te Ball valves and possibly also choke, check valves etc. should be included in addition to gate valves on branches.

Include ball valves etc. in addition to gate valves on branches

NO 4.2 te Slugging is not mentioned under the listing of considerations for manifold systems. Slugging can be a significant design issue

Consider to include slugging in listing.

NO 4.2 Bullet point no 3

te Workover system not mentioned under listing (bullet points) Should be included

NO 4.3 Last two bullet points

te Interfaces vs flowlines and/ or jumpers are important and should be included in listing

Include interfaces towards flowline and/or jumpers

NO 4.3 te Add “slugging”

NO 4.4.2 te Several important items missing in what should be included on the manifold if applicable.

Include that manifold should include support and space for Subsea Control Module (SCM), Subsea Distribution Unit (SDU) and Electrical Distribution Unit (EDU).

NO 4.5.1 te Definition of template is different from the one in 3.2.16 that includes piping in the template

Adjust definition of template between 3.2.16 and 4.5.1.

NO 5.1.2 te Other guidelines provide specific well spacing. ISO should also state specific no

Consider specific number(s) for well spacing

NO 5.1.3 te Definition of access / safety distance requirements for ROV are missing

Include definite dimensions for space / safety distance for ROV access

NO 5.1.4 te The barrier philosophy does not discuss diver operable template / manifolds. In the case of divers making up connections between well jumpers and manifold, there should always be double barriers also after removal of pressure cap or flange. This will normally require two valves per branch. To achieve sufficient safety, a bleed function must be included between the two branch valves.

Include double block philosophy for diver operable manifolds.

NO 5.1.4 te Wording ‘flowlines’ is not representative Replace with ‘piping’

NO 5.1.4 te The text must distinguish between active and passive barriers Add the following text: Permanent barriers in a manifold system shall be


provided by at least one Passive barrier against the environment.

If use of Active barriers against external leakage for pressurized manifold systems such system shall be provided by double, pressure retaining seal systems. This is normally satisfied by having two separate valves in series.

NO 5.1.5 ge Consider reference to DNV relevant OS and RP Refer to DNV-OS-A101 and DNV-RP-H101

NO 5.2.1.1 te To include the fabrication phase as a load relevant phase can be discussed. How to handle pre fab. Items should be discussed under the fabrication section ( Section 8)

Rephrase statement for fabrication as a load relevant phase

NO 5.2.3 te Conductor hang-off loads on structures are not given in ISO 13628-1 appendix F. This is an important design parameter for the Norwgian Continental shelf.

Include drilling loads as stated in NORSOK U-001 appendix A.

NO 5.2.1.2 te Consider rephrasing the part : ‘..normally accepted as guidelineless, fishing is not applicable an the equipment needs only be protected against dropped objects’

Rephrase with ’….bottom trawling is less common. For locations where it can be documented that no bottom trawling occurs, and is not likely to occur within the design life of the installations, the equipment needs only be protected against dropped objects.

NO 5.3.1 Bullet no 5 ge Meaning of sentence is unclear ‘If wells are to be completed on the template, the corresponding manifold should provide for connection to the tree’

Rephrase to clarify

NO 5.3.1 Bullet no 10 and 11

te Erosion allowance should be considered in addition to corrosion allowance. Further, it should be specified more details for consideration wrt high fluid velocities down stream of chokes.

Include erosion allowance in discussion and more details around high velocity considerations

NO 5.3.1 Para 2 te Please consider to include a requirement to “design for NDT”. This means that already during the design phase the position and access of joints shall be evaluated, so that welded joints are accessible for inspection by ultrasound and/or radiography from both sides. This will often be a concern during fabrication, when there is no access to control proper weld quality.

See column 5

NO 5.3.2 Para. 1 te Please consider including DNV-RP-F112 as a reference for evaluation of hydrogen embrittlement (HE), hydrogen induced stress cracking (HISC) and brittle fracture.

See column 5

NO 5.3.2 te The ISO standard opens for ‘all’ codes for ‘all manifold’ applications currently used in the industry. I would be beneficial to limit the freedom use of codes – ASME B31.4 for fluid and ASME B31.8 for gas systems. ASME B31.3 for smallbore systems like hydraulic, chemical injection, Methanol MEG etc. DNV-OS-F101 may be used as alternative to ASME

Rewrite the section to reflect comment. Further, include statement ‘ This will be the ISO requirement until manifold piping purpose specific design code is established in the industry’


B31.4 or B31.8.The industry lacks a purpose made design code for subsea manifold piping and should work to establish such a code

NO 5.4 te The section does not describe sufficiently environmental extremes, how to calculate accidental loads nor detail requirements for the temporary phases.

Include the following normative rules: DNV ‘Rules for Marine Operations’, DNV-RP-C203, DNV–RP-C204, DNV-RP-C205 and DNV-OS-C101.

NO 5.4 ge Check if ISO 13819-1, - 2 is still valid.These standards may have been replaced with iso 19000

NO 5.4 ISO 13819-1, ISO 13819-2, have been superseded. Make correct references.

NO 5.4.1 te The load test of 1.5 the rated capacity cannot with 100% certainty cover all relevant loads. This is dependent how the test will be performed and the nature and direction of the load. Further, no knowledge of the utilization of the structure will be known which again will mean that there is no control of the risk involved

Remove alternative with load test

NO 5.5.1 te Gravity based foundation is not listed Include gravity based foundation

NO 5.5.3 te Max level for template is set to 0.3 deg. This seems very strict. Consider adjusting this to 0,5 deg

NO 5.6 te The listing of component spec does not include API 6D for header ball valves

Include API 6D

NO 5.6 te Replace API references with ISO references.

NO 6 te 3rd party verification is not discussed. Include description of 3rd party verification and extent of 3rd party verification.

NO 6.1.1 te Geotechnical analysis is not included. This is relevant for the foundation structures

Include Geotechnical analysis in the listing

NO 6.1.3 te No reference for two hour holding time during hydrostatic testing

Remove requirement for 2 hours and refer only to design code.

NO 6.1.3 ge Manifold piping system test pressure requirements are not included. Lack of requirements in international standards on strength testing of a manifold system, independent of piping spec. The FAT requirement may be the dimensional load for the piping.

NO 6.2 te SIT and FAT seem to overlap. It should be clarified what fall under the scope of FAT and what falls under SIT

Clarify / Describe scope of SIT vs FAT

NO 7 te This clause is a copy of a committee draft (CD) version of ISO 13628-1, Annex L ”Materials and welding of manifold piping and jumpers”.

This annex L is currently in a DIS version. The changes from the CD version used in the current API 17P and the DIS version are

Replace current clause 7 with the DIS version of ISO 13628-1 Annex L (enclosed document), and correct the references accordingly.


minor. The only obvious change is the 1st paragraph under 7.1 General. (A FDIS of Annex L is scheduled to be finalised October 2009).

NO 7.1 Para. 4 te The current ISO 10474 is from 1991, while the current EN 10204 is from 2004/2005. The previous revision of EN 10204 was identical to ISO 10474, but some changes have been made in the update. Notably 3.1 certificates are in ISO 10474 subdivided into 3.1.A, 3.1.B and 3.1.C, while in the new EN 10204 there are only one type of 3.1 certificate (i.e. 3.1.B is not only 3.1, and “A” and “C” are void). Hence if the reference to ISO 10474 is kept, it is not sufficient to only state “3.1 certificate” – a letter is also needed.

See column 5

NO 7.2 Para. 3 ed A full stop missing at the end of the last sentence. See column 5

NO 7.2 Para. 2 te It is stated that delivery condition of pipes may be N, TMCP or QT. It is suggested to use “shall” to avoid annealed condition (if annealed condition is requested avoided).

See column 5

NO 7.2 Para. 2 te It is stated that delivery condition of fittings shall be N, N+T, A or QT. It is suggested to delete “annealed” condition.

See column 5

NO 7.2 Table 7.1 te It is suggested to add “PSL 2” in the line with ISO 3183. ISO 3183 has been harmonised with API 5L in 2007, and the same requirements should apply.

See column 5

NO 7.2 Para. 2 te It is suggested to specify that all materials for pipes and fittings shall be killed (fully de-oxidised). ISO 3183, ref. Table 1, does not require de-oxidation. Alternatively, it should be specified “ISO 3183 PSL2” in Table 1

See column 5

NO 7.2 Para. 3 ge Please note that DNV-OS-F101 has extensive requirements to welding qualifications, as opposed to the other standards listed in Table 7.1.No change in text proposed.

NO 7.2 Para. 4Table 7.2

te Please note that DNV-OS-F101 is also completely self-contained with regard to stainless steel pipe, i.e. duplex 22Cr and 25Cr as well as 13Cr martensitic steel. Since this standard is included for C-Mn steel pipe, it should also be included in Table 7.2.

See column 5

NO 7.2 Para. 5 + 6 geed

It is specified “type 316, 22 and 25 Cr”. It is recommended to specify 316L (for better weldability). In addition, it is recommended to specify “22Cr and 25Cr” (instead of 22 and 25 Cr). Alternatively the UNS numbers can be used.

NO 7.2 Para. 6 ed Isn’t this paragraph redundant? See column 5


NO 7.3. Para. 2 te Please consider to include a minimum forging ratio, for instance 4:1.

See column 5

NO 7.4 Para. 2 te Please consider to include some requirements to the hydrogen content in welding consumables (e.g. 5 ml per 100 g weld metal, reference to ISO 3690 for testing).

See column 5

NO 7.5.1 - ed It is stated “..shall taken..”. Shouldn’t it be “…shall be taken…” See column 5

NO 7.5.1 - te It should be stated that “… reflect the properties in the finished product (i.e. after all manufacturing steps, such as forming, expansion and heat treatment), …”.

See column 5

NO 7.5.2 para 1 te What is meant by “type”? Is this same size, dimensions, or merely the same general form (i.e. bends, tees etc).

See column 5

NO 7.5.2 - te Some design codes (such as ASME VIII) allows testing in areas determined critical by the design. Please consider implementation.

See column 5

NO 7.6.3 para 1 te Subsize specimens are allowed, down to 5 mm. Please include how the test requirements are modified for smaller specimens. It is recommended to use 5/6 of the value for full-size specimens for 7.5 mm, and 2/3 for 5 mm.

See column 5

NO 7.6.4 ed The same paragraph is repeated. It is probably sufficient to state this requirement only once.

See column 5

NO 7.6.5 para 2 te What is a “near surface”? Please elaborate. See column 5

NO 7.6.5 para 2 te The ferrite content requirement can be somewhat strict for duplex welds. Here the ferrite content is typically allowed up to 60 or 65%.

See column 5

NO 7.7 - te UT of austenitic material is notoriously difficult, due to the different dispersion of the sound waves compared to ferritic material. Thus the grain structure of duplex stainless steel and austenitic stainless steel warrants some additional precautions when applying UT.

NO 7.7 - te Weld bevels on all types of components should be inspected by magnetic particle or penetrant, in order to ensure a good weld quality. Please consider implementation.

See column 5

NO 7.8 - te More requirements should be considered, e.g.:- Same toughness requirements apply for the bolts as for the materials to be bolted, or alternatively testing at minimum 10 oC lower than minimum design temperature- Rolled threads for bolts subjected to fatigue loads- Forged to shape- Sufficient marking and full traceability to inspection document.- Heat treatment procedure shall ensure uniform properties of all bolts in the same heat treatment batch.

See column 5


NO 7.9.3.1 para 1 ed The proper reference is ISO 15590-1. Please include “-1”. See column 5

NO 7.9.3 - te Please note that ISO 15590-1 is based on ISO 3183, and is applicable for C-Mn steel pipe. Stainless steel and Ni-based alloys are not within the intended scope of the standard.

See column 5

NO 7.9.3.3 Table 7.7 ed In note 1, please include that the abbreviations are in “Table 3” of ISO 15590-1.

See column 5

NO 7.9.2 te For CMn-steels, only the EN standards and DNV-OS-F101 require Nitrogen-binding elements. It should be considered if Nitrogen-binding elements e.g. Al/N>2 should be required for all CMn steels subjected to cold forming resulting in >5% deformation.

See column 5

NO 7.11.1 Para. 1 te It is not clear if impact testing is mandatory for weld thickness > 6 mm, or if the code/standard applies. E.g. ISO 15614 does not require impact testing for t < 10 mm.

See column 5

NO 7.11.1.4.2 4th bullet te Why only for 25Cr. It is suggested to have this for 22Cr as well.

NO 9.1 te Section describes the requirements in too little detail. Reference should be made to standards describing safety level, e.g. DNV ‘Rules for Marine Operations’

NO 9.4 te Not all subsea equipment should be designed for reinstallation. One example is the template structure

Rephrase sentence.

NO 10 ed Last bullet point - first sentence Text seems to have been mixed up.

Rephrase sentence

NO 10 te Valves should be gathered in easy accessible panels Special attention shall be given to valve placement and -orientation in order to avoid hydrates formation and sand accumulation in valve cavity. All valve override buckets shall be gathered in easy accessible valve panels in order to give efficient operation and protection of valve stem interface.

NO 11.1 / 11.2 te Design of padeyes should also refer to DNV ‘Rules for Marine operations’

Refer to DNV ‘Rules for Marine operations’

NO 12.3 te Bullet point no 11: Alternative to “S” for shut can be “X” Include letter “X” as alternative to “S”

NO 13 ed Section seems incomplete Evaluate to detail the section. Section will require a defined safety level.

NO 14 te Statement corresponds to section 9.4 only if comment to that section is included

No change required if comment to 9.4 is incorporated.

NO 14.2 te No reference to safety level Evaluate to detail the section. Section will require a defined safety level.

NO Appendix A te In the data sheet, no material description for connection system or thermal insulation are included

Include materials for connection systems and insulation

NO Appendix A te No listing of control system HP pressure rating is included. Further, HP and LP systems should be described ( applications)

Include pressure rating for HP control system and list relevant systems


US 5.1.4 Technical

It is generally not possible to leak test isolation valves in large systems full of hydrocarbons before pulling pressure caps. It is much more effective to manage pressures to prevent the release of hydrocarbons to the environment in the event a valve has the potential to leak.

Strike last sentence "This requires the valve to be leak....activity." Instead you could say "The manifold should be depressurized to below hydrostatic pressure to prevent possible leakage of hydrocarbons to the environment"

US 5.4.4 Technical

Second bullet in particular. Not all structures are designed for high loads. Deep water structures are not subject to the same risks but often have roof mounted flowline connection hardware, ROV buckets for valves and actuated valve stems for overrides. The "roof" may be intended only to protect against minor impacts without deflection.

I don't know exactly what to do with this as the whole section seems to be written with heavy North Sea type protection structures in mind. This is not really relevant to deep water GOM.

US 5.5.3 Technical

In my experience, the need for leveling equipment is the exception not the rule and level indication can be nice but is not the rule either.

1st paragraph add after first sentence of first paragraph, "Subsea hardware can generally tollerate being 1-3 degrees from vertical and up to 5 degrees may be acceptable. This can normally be achieved without leveling systems."

Replace last sentence of first paragraph "A means...included" with "A means of level indication may be included on the structure if there is a concern about how level it is."

US Entire document

Other While I believe the document to be of value to the subsea community, I am abstaining due to a lack of resources to properly review and comment on it.

US 7.5.1 General Editorial

The is a word missing between "shall" and "taken". The test sample for production testing shall realistically reflect the properties in the product and shall be taken according to the selected pipe, fitting or forged component standards listed in Table 7.1 to 7.3.

US Technical


US Other Have no technical knowledge on this part of ISO 13628.

US 3.2 Definitions Editorial

The words in the Definitions section are not in alphabetical order.

Put words in alphabetical order

US Technical

1. Section 4.3 System Interfaces

- add "Subsea Controls and Chemical Injection" to the list of system interfaces in this section

2. Section 7.0 Materials

- this is redundant to Annex L in 13628-1 / 17A......either we remove this section from 17P and use Annex L or the opposite

US Clause 2 Editorial

Several standards are referred inside this document without being listed in the Normative references, such as:

API equivalents for ISO 13626 series (17A, 17F, 17E, etc), API 1111, ISO 13819, API Q1, ISO 9001, Several of UNS standards supporting material grades, API 17P, API 17H, etc

Perform a complete double check around the document and list all reference is missing at this section.

US Clause 2 Editorial

ASTM A 388 is presented out of alphabetical order. The Normative references list should be presented in alphabetical order in order to facilitate document utilization.

US Clause 3 - Section 3.1

Editorial

Abbreviation for Carbon Equivalent = CE, CE(Pcm) and CE(IIW) is made at 7.11.1.4.2 (Page 36), but the terms are not list in the abbreviations list.

The list of abbreviation shall contain all the abbreviations used in the document.


US Clause 3 - Section 3.2

Editorial

The list of definitions is out of alphabetical order. The list of definitions (sub-items 3.21 to 3.2.28) should be presented in alphabetical order in order to facilitate document utilization.

US Clause 5 - Sub-section 5.1.7 (New

sub-section)

Technical

A section related to “Corrosion Protection Strategy”, comprising cathodic protection and painting, should be included as part of the System Design Considerations.

As a suggestion:

“Cathodic protection should be design in accordance with DnV-RP-B401 or equivalent international recognized standard. Special considerations shall the made to material selection when the Manifold of the Subsea structure is part of a impressed current cathodic protection system.”

Paint system should be design in accordance API 17D – Appendix D or equivalent international recognized standard.”

US Clause 7 - Section 7.3,

Table 7.3

Technical

Table 7.3 should also has a column for API standards as it already have for ASTM, EN and ISO standards.

Include API 17D and API 6A as material standard for forged retaining components built in carbon or low-allow steel.

US Clause 7 - Sub-section 7.6.3, Table

7.5

Technical

Table 7.5 is split in two parts at pages 29 and 30 of the document.

Re-position the table 7.5, across the text of item 7.6.3 in order that it will not be split in two pages, in order to facilitate document utilization.


US Clause 7 - Sub-section 7.6.3, Table

7.5

Technical

The present document makes reference to DnV-OS-F101, to API 6A and to API 17D, but the minimum average and single energy value (J) recommend are not aligned with any one of these. Also it is not mentioned the test temperature (see that table 7.4 is missing).





US Clause 7 - Sub-section 7.6.4, 2nd paragraph

Editorial

2nd paragraph is a repetition of the 1st paragraph of this section.

Remove 2nd paragraph from the document text.

US Clause 7 - Sub-section 7.6.4, Last paragraph

Editorial

Reference to “API 6A718” is made incorrectly. Fix reference to: “API 6A”.

US Clause 7 - Sub-section

Editorial

Table 7.7 is split in two parts at pages 32 and 33 of the Make table 7.7 in only one segment. Special attention shall be made to avoid heading of tables in one page


7.9.3.3, Table 7.7

document. and entire table in other page.

US Clause 7 - Sub-section 7.11.1.3.5, Table 7.8

Other Reference for Table 7.4 is made at column “Test Temperature” of the table 7.8 first line. However, there is no table 7.4 is the document.

Include the missing Table 7.4 inside the text of item 7.6.3.


Editorial

Table 7.8 is relevant to item 7.11.1.3.2 and not to item 7.11.1.3.5.

Re-position the Table 7.8 inside the text of the item 7.11.1.3.2.


Technical

The present document makes reference to DnV-OS-F101, to API 6A and to API 17D, but the minimum average and single energy value (J) recommend are not aligned with any one of these. Also it is not mentioned the test temperature (see that table 7.4 is missing).







1st paragraph

Technical

Only 2 examples of installation vessels are suggested in the 2nd line of the 1st paragraph.

Add “Subsea Construction Vessels” as a third example.

As a suggestion the text could be: “… Different types of installation vessel, such drilling rigs, subsea construction vessels or crane barges, should be evaluated.”


8th bullet

Technical

Only positioning capacity is referred in the installation requirements bullet list. Re-positioning should also be part of this list once this procedure is often required and involve different loads conditions than the 1st positioning of a manifold or subsea structure.

As a suggestion, 8th bullet should be adjusted to:

• Positioning and re-positioning capability

US Clause 7 - Section 12.2, 3rd paragraph

Technical

The document refers only to “orange” as a color which the “active” parts during intervention should be marked. Yellow is also an often accepted and even preferred color depending of the region in the globe where the manifold or subsea structure installation occurs.

Add yellow and a possible color.

As a suggestion the text should be adjusted to: “…should be marked with orange or yellow color.”

US 3.2.18 Technical

Definition of Drilling template ends in an incomplete sentance. End or complete sentance.

US 5.5.2.3 Technical

In reference to the following in paragraph two: "The installed weight of the structure shall be accommodated solely by skirt

Reword the two sentances referenced above as follows: "The installed weight of the structure may be


friction (i.e., without any load resting on the skirt roofs/mudmats). A filter mattress shall be installed underneath the mudmat in each suction anchor to facilitate distribution of pressure to the entire mudmat area." The requirement to have a structures weight supported solely by skin friction is not realistic and is not in accordance with common industry accepted design practices. The use of the mudmat plate to support the weight of a structure in conjuction with the friction of the skirt should be allowed. The use of a filter mattress under a mudmat should not be a requirement but rather should be mentioned as a method to distribute load if required.

accommodated by the skirt friction and bearing on the mudmat. A filter mattress may be installed underneath the mudmat in each suction anchor to facilitate distribution of pressure to the entire mudmat area as required."

US 7.2 Technical

This section only refers to pipe and pipe fitting standards but does not address forgings.

Propose to add to first paragraph “Pipe fittings can be made from forgings per section 7.3.” Alternatively in section 7.3 “Forgings for pressure-containing components including pipe fittings shall conform…”

US 7.3 Technical

Martensitic stainless steel has not been included in Table 7.3. Add martensitic stainless steels to Table 7.3 under Material type column.

US 7.5.2 Technical

This section should be consistent with API 6A and other applicable standards.

Section should explicitly allow the use of testing sampling per API 6A or other applicable standards.

US 7.5.2 Technical

In reference to "Separate test blocks in accordance with ISO 10423 requirements for QTC’s are acceptable if agreed with end user.” Seperate test blocks should be considered acceptable.

"Separate test blocks in accordance with ISO 10423 requirements for QTC’s are acceptable.”

US 7.6.3 Technical

In reference to "Test temperature for components in carbon and low-alloyed steel, and martensitic stainless steels with an integral weld end shall be minimum design temperature minus 10 °C (18 °F) or at lower temperatures. The test temperature for components not intended for welding shall be the minimum design temperature." The test temperature for impact testing should only have to be the minimum design temperature regardless of the component.

Reword paragraph three as follows "Test temperature for components in carbon and low-alloyed steel, and martensitic stainless steels shall be the minimum design temperature or at lower temperatures." delete "The test temperature for components not intended for welding shall be the minimum design temperature."

US 7.6.3 Technical

Minimum impact energy requirements in Table 7.5 should be Table 7.5 should be consistent with the values given in


consistent with API 6A. API 6A section 5.4.1 Table 6 for PSL 3 equipment.


Test temperature for G48 corrosion testing should be 40 deg C which is consistent with current industry practice.

“Test temperature shall be 40 °C and the exposure time 24 hours.”

US 7.7.3 Technical

In first paragraph include API 6A for acceptance criteria. Last sentance of first paragraph “The acceptance criteria shall be ASME VIII, Div. 1, Appendix 6 or 8 as relevant, API 6A or equivalent.”


Requires NDE of weld procedure qualification test welds. This is not required by ASME IX, thus would invalidate existing welding procedures.

Remove section 7.11.1.2

US 7.11.1.4.2 Technical

Comment on last bullet point. Chemistry control on carbon steel piping will create logistical and schedule problems in delivering equipment. You either have to qualify welding procedures and then control the chemistry of the pipe when you order it so it does not exceed the chemistry of the PQR material, or you order pipe and qualify procedures on the richest heat, or you qualify procedures and then check each heat as it come in to see if we can use our existing weld procedure or have to qualify a new one.

Reword the last bullet point as follows: "The chemical composition of the procedure qualification test material shall be representative of the production material."

US 7.11.1.5.1 Technical

Delete reference to ISO 3834-2. ISO 3834-2 is not consistent with industry fabrication practices or other API codes for subsea equipment.

Delete first paragraph.

US 7.11.1.5.1 Editorial

Fifth paragraph should be rewritten to allow the use of socket welds but agreed on by the end user.

"The use of socket welds on pressure containing piping shall be agreed upon with the end user."

US 5.1.4 Technical

This section does not state the barrier requirements for injection systems

US 5.5.1 Technical

Applicable industry spec for suction piles and mudmats should be referenced and not just driven piles.

US 7.2 Technical

Operating temperature needs to be considered when minimum yield strength is selected.


(for example at higher temperatures 22 Chrome has to be derated)

US 7.2 Technical

Not sure if this is the correct section for it but a minimum corrosion allowance should be recommended for carbon and low allow steel.

US Technical

US 6.1.1 Technical

Should include reference to computational erosion analysis such as Tulsa or DNV programs.

US 6.1.1 Technical

Should include reference to computational erosion analysis such as Tulsa or DNV programs.

US 7.2 - 7.13 Technical

The material requirements was a carbon copy from 13628-1, Annex L.

Confirm if Annex L Materials section still exists within 13628-1 and if so section 7 should reference 13628-1 to avoid revision control.

The material requirements are of a detail nature as found in a specificationor a code such as API 6A and not really the realm of a recommended practice.

ES We agree.


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