EXPLANATORY REPORT
RAPPORT EXPLICATIF
ISO/TC 67 / SC 4
ISO/DIS 13628-15
N436
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.
on
Le document ci-joint est soumis, pour diffusion comme DIS, au vote
comité membre, suite au consensus des membres (P) du comité
obtenu.
at the meeting of
à la réunion du
TC
see resolution No.
voir résolution no
/ SC
by postal ballot initiated on
par un vote par correspondance démarré le
document
2009-01-14
Number
P-members in favour:
Membres (P) approuvant le projet:
in
dans le
10
P-members voting against:
Membres (P) désapprouvant:
0
P-members abstaining:
Membres (P) s'abstenant:
3
Countries
Argentina, Brazil, France, Italy, Kazakhstan,
Korea, Netherlands, Norway, United Kingdom,
United States
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 Directives
Je confirme que ce projet satisfait aux prescriptions de la partie 2 des Directives ISO/CEI
Date
Name and signature of the secretary
Nom et signature du secrétaire
2009-06-12
Ed Baniak
FORM 8 A (ISO)
FORMULAIRE 8 A (ISO)
Page 1 of/de 23
Template for comments and secretariat observations
Document: ISO CD 13628-15
Date: 2009-04-14
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
comment2
Comment (justification for change) by the MB
Proposed change by the MB
Secretariat observations
on each comment submitted
BR
1
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.
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.
te
This figure may be similar to one in the standard ISO
13628-1 page 7 – clause 4 – figure 1.
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:
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)
Version 2001-07

Verification of design calculation (dimensioning)

Factory process verification (FAT)

Performance verification (PVT)
FORMULAIRE 8 A (ISO)
Page 2 of/de 23

Site integration testing (SIT)
Also, operational service conditions shall be included in
the design requirements.
BR
BR
4.1
4.2
Second
paragraph
Second
paragraph
te
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:
Include the following requirements to be defined or
approved by end user in the topic:
o
Design life
o
Design life
o
Water depth
o
Water depth
o
Soil conditions and axial stiffness
o
Soil conditions and axial stiffness
o
Metocean data
o
Metocean data
The following considerations related to structures and
modules are not being addressed:
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 Planned and emergency shutdowns of wells
and
manifold
(including
Valves
open/close cycles/month)
o Flow rates range (max., min. etc)
o Flow rates range (max., min. etc)
o Pressure drops
o Pressure drops
o Fluid composition
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 –
FORM 8 A (ISO)
FORMULAIRE 8 A (ISO)
Page 3 of/de 23
Reliability, Availability and Maintainability)”.
BR
5.1.7
New subsection
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.
Piping systems for subsea use shall be designed
in accordance with BSI PD 8010-2 - Code of
practice for pipelines Part 2: Subsea pipelines.
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.
The BSI PD 8010-2 is applicable to subsea pipeline
intended for conveyance of hydrocarbon liquids,
FORM 8 A (ISO)
FORMULAIRE 8 A (ISO)
Page 4 of/de 23
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
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:
Second
paragraph
Component
Production/Injection
Valves
Chokes
FORM 8 A (ISO)
FORMULAIRE 8 A (ISO)
Page 5 of/de 23
Industry Spec
API 6A / ISO 10423
API 17D / ISO 13628-4
API 6A / ISO 10423
API 17D / ISO 13628-4
Control Components
API 17F
End Connectors
API 17D
Flanges
API 6A / ISO 10423
API 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
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.
BR
6.2
Second
paragraph
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 lowallow 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
The technical committee could note that values listed
FORM 8 A (ISO)
FORMULAIRE 8 A (ISO)
Page 6 of/de 23
topic:
Defining
FAT
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).
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.
Same comment is made below regarding table 7.8 of the
document.
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
Paragraph
ed
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
NL
7.0
Te
add "Subsea Controls and Chemical Injection" to the list of
system interfaces in this section
this is redundant to Annex L in 13628-1 / 17A......
NO
ge
NO
1
First para.
ge
NO
1
Second
para.
ed
FORM 8 A (ISO)
either we remove this section from 17P and use Annex
L or the opposite.
GENERAL COMMENT
The 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.
The scope need rewording as this standard may well provide
different to other specifications (and standards).
Second para: Replace “Recommended Practice” with
“International Standard”
FORMULAIRE 8 A (ISO)
Page 7 of/de 23
NO
1
NO
1.d
ge
NO
2
ed
NO
2
te
NO
2
NO
2
ed
NO
2
ge
NO
2
te
NO
3.1
ed
NO
3.2
te
NO
3.2.15
te
NO
3.2.16
te
NO
3.2.16
te
NO
3.2
te
FORM 8 A (ISO)
Last para.
-
te
te
Last para: Replace references to API standards with same
references to ISO standards.
It should be clarified whether branch connectors are part of
the scope. The sub-section only refers to flowline connectors.
No reference is made to 13628-7 and DNV rules for Marine
Operations. These are relevant and should be included.
Several references are overlapping wrt scope.
Please consider including the following recommended
practice:
DNV-RP-F112 - Design of duplex stainless steel subsea
equipment exposed to cathodic protection
Not all these standards are normative for all type of
equipment cover by this document.
Add the following standards:
Asme B 31.3, ASME B31.8, Dnv-RP F112 (HISC)
Delete the following:
TR 1236 (StatoilHydro) internal spec.
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 mention of HIP under ‘Abbreviations’
Delete references 3.2.1-4 as they are covered by the ISO
Directive.
Is System Integration Testing (SIT) acceptable as verification?
If SIT is acceptable, what about FAT or EFAT?
Further 3rd part verification should be mentioned
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.
No mention of templates for subsea processing plants
When listing the various foundation types as suction piles,
driven piles, mudmats – gravity based foundations is not
included.
FORMULAIRE 8 A (ISO)
Branch connectors should be mentioned specifically
Include references (see column 5)
Review list and evaluate to sort on normative
references and informative references.
See column 5
Erase “normative”
Include and delete these standards
Include HIP under ‘Abbreviations’
Include FAT and EFAT and describe 3rd party
verification in section.
Clarify how the manifold module relates to the
template.
Processing plants template should be described and
defined.
Include gravity based foundation in the listing
Page 8 of/de 23
NO
4
ed
Clause 4 should include structure in title
NO
4.1 ,4.2, 4.3
te
Dropped objects and trawl protection should be
included in functions that the manifold should fulfil if
applicable
NO
4.1
Second
bullet point
te
NO
4.1
Fifth bullet
point
te
NO
4.2
NO
4.2
Bullet point
no 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.
The end user should specify the material requirements , not
necessarily do the material selection
Ball valves and possibly also choke, check valves etc. should be
included in addition to gate valves on branches.
Slugging is not mentioned under the listing of considerations
for manifold systems. Slugging can be a significant design
issue
Workover system not mentioned under listing (bullet points)
NO
4.3
Last two
bullet points
te
Include interfaces towards flowline and/or jumpers
NO
4.3
te
Interfaces vs flowlines and/ or jumpers are important and
should be included in listing
Add “slugging”
NO
4.4.2
te
Several important items missing in what should be included on
the manifold if applicable.
NO
4.5.1
te
NO
5.1.2
te
NO
5.1.3
te
NO
5.1.4
te
NO
5.1.4
te
Definition of template is different from the one in 3.2.16 that
includes piping in the template
Other guidelines provide specific well spacing. ISO should also
state specific no
Definition of access / safety distance requirements for ROV
are missing
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.
Wording ‘flowlines’ is not representative
Include that manifold should include support and
space for Subsea Control Module (SCM), Subsea
Distribution Unit (SDU) and Electrical Distribution Unit
(EDU).
Adjust definition of template between 3.2.16 and
4.5.1.
Consider specific number(s) for well spacing
NO
5.1.4
te
The text must distinguish between active and passive barriers
FORM 8 A (ISO)
te
FORMULAIRE 8 A (ISO)
Rephrase with material requirements
Include ball valves etc. in addition to gate valves on
branches
Consider to include slugging in listing.
Should be included
Include definite dimensions for space / safety distance
for ROV access
Include double block philosophy for diver operable
manifolds.
Replace with ‘piping’
Add the following text:
Permanent barriers in a manifold system shall be
provided by at least one Passive barrier against the
environment.
Page 9 of/de 23
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.
Refer to DNV-OS-A101 and DNV-RP-H101
NO
5.1.5
ge
Consider reference to DNV relevant OS and RP
NO
5.2.1.1
te
NO
5.2.3
te
NO
5.2.1.2
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)
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.
Consider rephrasing the part : ‘..normally accepted as
guidelineless, fishing is not applicable an the equipment needs
only be protected against dropped objects’
NO
5.3.1
Bullet no 5
ge
NO
5.3.1
Bullet no 10
and 11
te
NO
5.3.1
Para 2
te
NO
5.3.2
Para. 1
te
NO
5.3.2
FORM 8 A (ISO)
te
Meaning of sentence is unclear ‘If wells are to be completed
on the template, the corresponding manifold should provide
for connection to the tree’
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.
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.
Please consider including DNV-RP-F112 as a reference for
evaluation of hydrogen embrittlement (HE), hydrogen induced
stress cracking (HISC) and brittle fracture.
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
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
FORMULAIRE 8 A (ISO)
Rephrase statement for fabrication as a load relevant
phase
Include drilling loads as stated in NORSOK U-001
appendix A.
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.
Rephrase to clarify
Include erosion allowance in discussion and more
details around high velocity considerations
See column 5
See column 5
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’
Page 10 of/de 23
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
NO
5.4
NO
5.4.1
te
NO
5.5.1
te
Check if ISO 13819-1, - 2 is still valid.
These standards may have been replaced with iso 19000
ISO 13819-1, ISO 13819-2, have been superseded. Make
correct references.
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
Gravity based foundation is not listed
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
Include API 6D
NO
5.6
te
The listing of component spec does not include API 6D for
header ball valves
Replace API references with ISO references.
NO
6
te
3rd party verification is not discussed.
NO
6.1.1
te
NO
6.1.3
te
NO
6.1.3
ge
NO
6.2
te
NO
7
te
Geotechnical analysis is not included. This is relevant for the
foundation structures
No reference for two hour holding time during hydrostatic
testing
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.
SIT and FAT seem to overlap. It should be clarified what fall
under the scope of FAT and what falls under SIT
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”.
Include description of 3rd party verification and extent
of 3rd party verification.
Include Geotechnical analysis in the listing
Remove alternative with load test
Include gravity based foundation
Remove requirement for 2 hours and refer only to
design code.
Clarify / Describe scope of SIT vs FAT
Replace current clause 7 with the DIS version of ISO
13628-1 Annex L (enclosed document), and correct the
references accordingly.
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
minor.
The only obvious change is the 1st paragraph under 7.1
General. (A FDIS of Annex L is scheduled to be finalised
FORM 8 A (ISO)
FORMULAIRE 8 A (ISO)
Page 11 of/de 23
October 2009).
NO
7.1
Para. 4
te
NO
7.2
Para. 3
ed
NO
7.2
Para. 2
te
NO
7.2
Para. 2
te
NO
7.2
Table 7.1
te
NO
7.2
Para. 2
te
NO
7.2
Para. 3
ge
NO
7.2
Para. 4
Table 7.2
te
NO
7.2
Para. 5 + 6
ge
ed
NO
7.2
Para. 6
ed
NO
7.3.
Para. 2
te
NO
7.4
Para. 2
te
FORM 8 A (ISO)
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.
A full stop missing at the end of the last sentence.
See column 5
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).
It is stated that delivery condition of fittings shall be N, N+T, A
or QT. It is suggested to delete “annealed” condition.
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.
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
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.
Please note that DNV-OS-F101 is also completely selfcontained 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.
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.
Isn’t this paragraph redundant?
See column 5
Please consider to include a minimum forging ratio, for
instance 4:1.
Please consider to include some requirements to the hydrogen
content in welding consumables (e.g. 5 ml per 100 g weld
See column 5
FORMULAIRE 8 A (ISO)
See column 5
See column 5
See column 5
See column 5
See column 5
See column 5
See column 5
Page 12 of/de 23
NO
7.5.1
-
ed
NO
7.5.1
-
te
NO
7.5.2
para 1
te
NO
7.5.2
-
te
NO
7.6.3
para 1
te
NO
7.6.4
NO
7.6.5
para 2
te
NO
7.6.5
para 2
te
NO
7.7
-
te
NO
7.7
-
te
NO
7.8
-
te
NO
7.9.3.1
para 1
ed
NO
7.9.3
-
te
FORM 8 A (ISO)
ed
metal, reference to ISO 3690 for testing).
It is stated “..shall taken..”. Shouldn’t it be “…shall be taken…”
See column 5
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), …”.
What is meant by “type”? Is this same size, dimensions, or
merely the same general form (i.e. bends, tees etc).
Some design codes (such as ASME VIII) allows testing in areas
determined critical by the design. Please consider
implementation.
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.
The same paragraph is repeated. It is probably sufficient to
state this requirement only once.
What is a “near surface”? Please elaborate.
See column 5
The ferrite content requirement can be somewhat strict for
duplex welds. Here the ferrite content is typically allowed up
to 60 or 65%.
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.
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.
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.
The proper reference is ISO 15590-1. Please include “-1”.
See column 5
Please note that ISO 15590-1 is based on ISO 3183, and is
applicable for C-Mn steel pipe. Stainless steel and Ni-based
See column 5
FORMULAIRE 8 A (ISO)
See column 5
See column 5
See column 5
See column 5
See column 5
See column 5
See column 5
See column 5
Page 13 of/de 23
NO
7.9.3.3
NO
7.9.2
NO
7.11.1
Para. 1
te
NO
7.11.1.4.2
4th bullet
te
alloys are not within the intended scope of the standard.
In note 1, please include that the abbreviations are in “Table
3” of ISO 15590-1.
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.
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.
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.
NO
9.4
te
NO
10
ed
NO
10
te
Not all subsea equipment should be designed for
reinstallation. One example is the template structure
Last bullet point - first sentence Text seems to have been
mixed up.
Valves should be gathered in easy accessible panels
NO
11.1 / 11.2
te
NO
12.3
NO
Table 7.7
ed
te
See column 5
See column 5
See column 5
Reference should be made to standards describing
safety level, e.g. DNV ‘Rules for Marine Operations’
Rephrase sentence.
Rephrase sentence
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.
Refer to DNV ‘Rules for Marine operations’
te
Design of padeyes should also refer to DNV ‘Rules for Marine
operations’
Bullet point no 11: Alternative to “S” for shut can be “X”
13
ed
Section seems incomplete
NO
14
te
NO
14.2
te
Statement corresponds to section 9.4 only if comment to that
section is included
No reference to safety level
Evaluate to detail the section. Section will require a
defined safety level.
No change required if comment to 9.4 is incorporated.
NO
Appendix A
te
NO
Appendix A
te
US
5.1.4
Techn
FORM 8 A (ISO)
Include letter “X” as alternative to “S”
In the data sheet, no material description for connection
system or thermal insulation are included
No listing of control system HP pressure rating is included.
Further, HP and LP systems should be described ( applications)
Evaluate to detail the section. Section will require a
defined safety level.
Include materials for connection systems and
insulation
Include pressure rating for HP control system and list
relevant systems
It is generally not possible to leak test isolation valves in large
Strike last sentence "This requires the valve to be
FORMULAIRE 8 A (ISO)
Page 14 of/de 23
ical
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.
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
Techn
ical
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
Techn
ical
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
Editori
al
The is a word missing between "shall" and "taken".
US
Techn
ical
US
Other
Have no technical knowledge on this part of ISO 13628.
Editori
al
The words in the Definitions section are not in alphabetical
US
3.2 Definitions
FORM 8 A (ISO)
FORMULAIRE 8 A (ISO)
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.
Put words in alphabetical order
Page 15 of/de 23
order.
US
Techn
ical
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
Editori
al
Several standards are referred inside this document without
being listed in the Normative references, such as:
Perform a complete double check around the
document and list all reference is missing at this
section.
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
US
Clause 2
Editori
al
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
Editori
al
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
Editori
al
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
FORM 8 A (ISO)
FORMULAIRE 8 A (ISO)
Page 16 of/de 23
document utilization.
US
Clause 5 Sub-section
5.1.7 (New
sub-section)
Techn
ical
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
Techn
ical
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 lowallow steel.
US
Clause 7 Sub-section
7.6.3, Table
7.5
Techn
ical
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.
FORM 8 A (ISO)
FORMULAIRE 8 A (ISO)
Page 17 of/de 23
US
Clause 7 Sub-section
7.6.3, Table
7.5
Techn
ical
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).
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.
Same comment is made below regarding table 7.8 of the
document.
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.
US
Clause 7 Sub-section
7.6.4, 2nd
paragraph
Editori
al
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
Editori
al
Reference to “API 6A718” is made incorrectly.
Fix reference to: “API 6A”.
US
Clause 7 Sub-section
7.9.3.3, Table
7.7
Editori
al
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.
FORM 8 A (ISO)
FORMULAIRE 8 A (ISO)
Page 18 of/de 23
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.
US
Clause 7 Sub-section
7.11.1.3.5,
Table 7.8
Editori
al
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.
US
Clause 7 Sub-section
7.11.1.3.5,
Table 7.8
Techn
ical
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).
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.
Same comment is made below regarding table 7.5 of the
document.
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.
FORM 8 A (ISO)
FORMULAIRE 8 A (ISO)
Page 19 of/de 23
US
Clause 7 Section 9.1,
1st paragraph
Techn
ical
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.”
US
US
Clause 7 Section 9.1,
8th bullet
Techn
ical
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:
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.
•
Positioning and re-positioning capability
Clause 7 Section 12.2,
3rd paragraph
Techn
ical
US
3.2.18
Techn
ical
Definition of Drilling template ends in an incomplete sentance.
End or complete sentance.
US
5.5.2.3
Techn
ical
In reference to the following in paragraph two: "The installed
weight of the structure shall be accommodated solely by skirt
friction (i.e., without any load resting on the skirt
roofs/mudmats). A filter mattress shall be installed
Reword the two sentances referenced above as
follows: "The installed weight of the structure may be
accommodated by the skirt friction and bearing on the
mudmat. A filter mattress may be installed
FORM 8 A (ISO)
FORMULAIRE 8 A (ISO)
As a suggestion the text should be adjusted to:
“…should be marked with orange or yellow color.”
Page 20 of/de 23
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.
underneath the mudmat in each suction anchor to
facilitate distribution of pressure to the entire mudmat
area as required."
US
7.2
Techn
ical
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
Techn
ical
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
Techn
ical
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
Techn
ical
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
Techn
ical
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
Techn
ical
Minimum impact energy requirements in Table 7.5 should be
consistent with API 6A.
Table 7.5 should be consistent with the values given in
API 6A section 5.4.1 Table 6 for PSL 3 equipment.
FORM 8 A (ISO)
FORMULAIRE 8 A (ISO)
Page 21 of/de 23
US
7.6.6.1
Techn
ical
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
Techn
ical
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.”
US
7.11.1.2
Techn
ical
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
Techn
ical
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
Techn
ical
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
Editori
al
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
Techn
ical
This section does not state the barrier requirements for
injection systems
US
5.5.1
Techn
ical
Applicable industry spec for suction piles and mudmats should
be referenced and not just driven piles.
US
7.2
Techn
ical
Operating temperature needs to be considered when
minimum yield strength is selected.
(for example at higher temperatures 22 Chrome has to be
FORM 8 A (ISO)
FORMULAIRE 8 A (ISO)
Page 22 of/de 23
derated)
US
7.2
US
Techn
ical
Not sure if this is the correct section for it but a minimum
corrosion allowance should be recommended for carbon and
low allow steel.
Techn
ical
US
6.1.1
Techn
ical
Should include reference to computational erosion analysis
such as Tulsa or DNV programs.
US
6.1.1
Techn
ical
Should include reference to computational erosion analysis
such as Tulsa or DNV programs.
US
7.2 - 7.13
Techn
ical
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
FORM 8 A (ISO)
We agree.
FORMULAIRE 8 A (ISO)
Page 23 of/de 23