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Template for comments and secretariat observations Date: 2007-02-07 Document: ISO/TC67/SC4/WG6/13628-1 A1&A2

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MB1 Clause No./Subclause No./

Annex(e.g. 3.1)

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

FR 3.1.14 te Is the intention to distinguish CRAs from Stainless Steels?

It can be inferred from other sections such as 6.4.3 and 6.4.5 that stainless steels are also CRAs.

Clarify if CRAs have less than 50% iron; example : Ni based alloys.

Otherwise mention as examples that austenitic stainless steels (eg 316L) and Duplex stainless steel are also considered as CRAs in this standard.

FR 6.3.4 3rd bullet point

te Why specifically mention glass reinforced plastics ? Use a more general term for these type of materials non subject to corrosion : non-metallic composites.

FR 6.3.4 te Cathodic protection standards mentioned are DNV RP-B401 and NACE RP0176

Mention also ISO 15589-2

US Entire document

Technical

The US requests that these comments be fully considered as DIS comments – reviewed and resolved prior to the issuance of the first DIS ballot, with resolutions noted in an included comment register;

As needed to resolve comments.

US Entire document

Technical

The material contained in this ballot should be compared and aligned to the content of proposed API 17P / ISO 13628-15. It should be noted that overlapping material will be withdrawn on the publication of 17P/-15;

Align documents and add Introduction note “Upon publication of API 17P / ISO 13628-15, the requirements/ recommendations in (pertinent clauses) for (pertinent products) in this International Standards 13628-1 will be superseded.”

US 6.4.2.2 Table 4

Technical

Verify the that temperature ranges for the materials are correct or not. In the past edition of this document (1999), the temp ranges for bolt material were "Above 100 (212)", "Above 46 (115)" and "-196 to +60 (-320 to +140). The new ranges all start with large negative temps (-46, -100, -196) that are very different than the previous edition. Note that a similar problem appears to exist with the current ediiton Table 1 for bolting material.

-46 should be 46; -100 should be 100; 65mm might be 50mm (but regardless, the correct USC unit dimensions should be given). A temporary corrigenda may need to be issued to correct Table 1 in the current published edition until this new Table 4 replaces it.

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

page 1 of 30ISO electronic balloting commenting template/version 2001-10


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Also, in the 1999 edition, size range for L7 material was 50 mm, and is 65 now and in the current published edition, 65 mm (1.969 in) is listed. Which is correct?

US Entire Document

Technical

TC67/SC4/WG6 documents are jointly developed with API SC17 and have both SI and USC units used in the text and tables, inlcuding the current edition of ISO 13628-1/API RP 17A. Some USC units are given in parentheses in the amendatory material, but in many places in new Clause 6 and Annex L, the USC units are missing (i.e. 6.2.2.2, 6.3.2, 6.3.4, Table 2, Table 4, 6.5.1, and all of Annex L).

Add the USC units in parantheses after the SI units in all text and tables to match the remainder of the document and the common practices of users in all parts of the world.

US L.6.1.13 Technical

Clause L.6.1.13, last sentence, "In no case shall the PWHT temperature exceed the tempering temperatures of the base materials." This is unacceptable for martensitic stainless steels such as AISO 410; for such material it is necessary to exceed the tempering temperature in order to obtain proper stress relief.

Revise to read:

"For carbon and low alloy steels, the PWHT temperature shall not exceed the tempering temperatures of the base materials."

US L.2.2 Editorial

In the last sentence of the 2nd paragraph, "All fittings shall be delivered in normalised, normalised and tempered..." the use of the word "delivered" could create disagreements as to when in the production process the material must be heat treated.

Revise to read, "All fitting shall be used in normalised, normalised and tempered..."

US L.6.1.5.1 Technical

Fifth paragraph, "Socket welds shall not be used at pressure containing piping," is unnecessarily restrictive. There are acceptable uses of welds which could be considered socket welds, and this sentence would increase design complexity without value. An example is for a small injection line penetration into a thick-wall pipe where a termination fitting would be sealed at the pipe OD with a socket weld.

Revise to read, "Socket welds shall not be used at pressure containing piping, except by agreement."

US Clause 3, Terms and definitions

Editorial

The definition proposed for "corrosion resistant alloys (CRAs)" is the same as in ISO 15156, but different than is used in ISO 10423. Also, throughout the proposed Annex

(a) Replace definition for CRAs with definition from ISO 10423, (b) add definition for "stainless steel" from ISO 10423, and insert "stainless steels"




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L, the term "steel" is used where it is intended to refer to carbon steel, alloy steel, and stainless steel. ISO 13628-1 will be used primarily by systems design engineers, not metallurgists, and it would be much clearer to use the 10423 definition for CRAs and to use the term "carbon, alloy, and stainless steels," where that is what is intended. Non-metallurgist users of the document would typically not think of "steels" as including stainless steels, and would typically prefer to differentiate stainless steels from other, more corrosion-resistant CRAs.

throught Annex L and clause 6 where needed for clarification.

US 6.4 Other Table 3 — Materials selection for subsea systems — Weld overlay materials

Table 3 — Materials selection for subsea systems

US Table 3 Editorial

Sub-sea Subsea

US 6.4.5 Editorial

Sub-sea Subsea

US L.2.2 Paragraph 3

Technical

For welded pipe and fittings, PQR/WPQR shall be qualified in accordance with DNV OS F101 Eliminate reference to ASME IX and ISO 15614-1. These documents are not designed to specifically address submarine pipeline design as the DNV code is. These documents are inadequate to address requirements for subsea applications.

For welded pipe and fittings, PQR/WPQR shall be qualified in accordance with DNV OS F101

US L.2.2 Paragraph 3

Technical

Add DNV code to last sentence for welder qualifications. All welding shall be carried out by welders qualified in accordance with ISO 9606, ASME IX, DNV OS F101 or EN 287

US Paragraph L.2.4 Second bullet

Technical

The PWHT temperature and the tempering temperature should be a minimum of 30 degrees centigrade difference

The tempering temperature shall be at least 30 degrees centigrade higher than the PWHT temperature.

US L.2.6.6.1, Paragraph 3

Technical

Prior to corrosion testing the specimen shall not be pickled. The testing should be carried out in the exact condition that it will be placed in service. More times than

Eliminate the last sentence of the third paragraph.




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not the material goes into service not pickled.

US L.4.3.1, Paragraph 3

Technical

All bends for duplex stainless steel shall be solution annealed after bending. Numerous material problems have been identified with induction bending duplex stainless steel without solution anneal after bending.

Add sentence: Duplex stainless steel shall be solution annealed after induction bending.


Technical

The number of test locations shall not be reduced for any reason. Mechanical properties at all locations need to be verified no matter how closely the process is controlled.

Eliminate paragraph 5


Technical

Replace codes referenced with DNV OS F101. Eliminate reference to ASME IX and ISO 15614-1 and ISO 15614-5. These documents are not designed to specifically address submarine pipeline design as the DNV code is. These documents are inadequate to address requirements for subsea applications.

…shall be qualified according to DNV OS F101 and to this standard.


Technical

Replace codes referenced with DNV OS F101. Eliminate reference to ASME IX and ISO 15614. These documents are not designed to specifically address submarine pipeline design as the DNV code is. These documents are inadequate to address requirements for subsea applications.

Mechanical testing shall be performed as specified in DNV OS F101 and the additional requirements in this standard.


Technical

Maximum of 1% of intermetallics shall be acceptable for accepting a WPQR based on corrosion and impact testing alone. The specimens used for corrosion and impact testing may be selectively sampled in an attempt to provide areas that have less intermetallics

In case of excessive amounts of intermetallics phases of limit stated above, up to a maximum of 1%,

US L.6.1.3.5, L.8 Technical

Acceptance criteria for Type 22Cr and 25 Cr shall be 48 J in lieu of 27 J.

Change 27 J to 48 J.


Technical

Remove all standards references and replace with DNV OS F101. . Eliminate reference to ASME IX and ISO 15614. These documents are not designed to specifically address submarine pipeline design as the DNV code is. These documents are inadequate to address

…essential variables listed in DNV OS F101 and the additional essential variables …




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requirements for subsea applications.


Technical

Reduce the allowable heat input range to + 10 %. 15% is excessive on heat input to control intermetallic phases consistently.

…heat input shal be + 10 %.


Technical

10 ml shall be changed to 8 ml to be consistent with the AWS designation of H8

…consumables (HDM 8 ml/100g weld metal or AWS H8) or solid…


Other There is no table 1 in this text. Need to indicate the correct reference.


Technical

PWHT temperature shall be at least 30 degrees centigrade lower than the tempering temperature of the material. This ensures adequate mechanical properties maintained in the base materials.

The PWHT temperature shall be at least 30 degrees centigrade lower than the tempering temperature of the base materials.

US 6.2.3 Other Recommends adhering to ISO 15156 to minimize likelihood of CP, however this criteria is not commonly used for this purpose.

Recommend following the criteria of DnV RP B401 section 5.5.

US 6.2.3 Other Requires that DNV RP F112 be satisfied to protect Duplex SS with CP. This is only a draft document that has not been accepted. Recommend following the guidelines in DnV RP B401 and NORSOK.

Recommend following the guidelines in DnV RP B401 and NORSOK.

US Editorial

For 13628-1. The highlighted in yellow text (editorial) changes to address one or more of the following concerns:

1. CRA’s and CRM’s need to be defined the same as what is defined in 13628-4.

2. Several “shalls” are reverted to “shoulds” since these address recommended practice rather than mandated specification

3. Imperial units added to augment SI units

4. Concerns over the statement that certain

See below comments.




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stainless steels cannot be used in sea water above 20 degrees C. We think this should be over 40 degrees C.

US 3.2 Editorial

Missing some abbreviations used in the document; add to the list in 3.2. Perform a spell check on entire document to find all abbreviations.

Add:

CGB completion guide base

GLL guidelineless

QTC quality test coupon

SCM subsea control module

US 7.10.2.1.2 Editorial

Add to Table 16 Section B (Actuator) new #12 Type of control fluid (oil or water based)

Table 16, Section B, add

12 Type of Control Fluid (oil or water base)

US 12.5.3 Editorial

Additional information about the SCSSV would be helpful in the design of the control system and planning operating philosophy / procedures for producing the well.

In section h) Downhole interface for the SCSSV add three items in the Description column: "Swept Volume:" and "Total Vertical Set Depth:" and "Open / Close Gauge Pressures of SCSSV"

US 12.5.3 Editorial

Section h) and section n) are both labeled "Downhole interface." Combine these sections. Also, it would be helpful to list the data about the DHPT card interface to SCM.

Add to n)Downhole interface:

DHPT card interface to SCM - Specify:

Combine sections h) and n)

US ISO 13628-1 Amedment 2 ANNEX L Table L.4

Technical

Nominal wall thickness should be properly defined in Tab L.4, even for parts in which the wall thikness varies.

Replace "Nominal wall/weld thickness" with "Maximum wall/weld thickness"

US Clause 6/ ed The current draft contains only metric units, while, like it or not, the oil and gas industry still utilizes imperial units worldwide.

All metric units shall be followed by the imperial equivalent. For example 20o C (68o F).

US Clause 6/

6.1

ge The material selection principles in ISO 13628 Amendment 1 clause 6 need to be consistent with ISO 13628-4.

Add the following text as a new Para. 1:Material selection is the ultimate responsibility of the user as he has the knowledge of the production environment as well as control over the




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injected treatment chemicals. The user may specify the service conditions and injection chemicals asking the supplier to recommend materials for his review and approval.

US Clause 6/

6.1

Table 1 ge This table should be deleted. It doesn’t provide any real fixed requirement, and will just lead to a lot of requests for revision of the document in the future as equipment manufacturers and metal manufacturers want to have the alloys they use / make listed in the table.

When requests to add a new alloy to this table are submitted, what are the guidelines the committee will follow in determining what should be added and what shouldn’t?

Delete Table 1.

US Clause 6/

6.1

Table 1 ed Column 2 contains a number of trademarked names. Use of trademarked names can lead to restraint of trade lawsuits against ISO.

Delete the trade names (Nitronic, Custom, Monel, Elgiloy, Tungum), or delete column 2 altogether.

US Clause 6/

6.1

Table 1 ed UNS N07716 is not Custom 625. It is Custom 625 Plus. However, “Custom” is a trademark name.

Revise to read Alloy 625 Plus.

US Clause 6/

6.1

Table 1 te CA6NM composition is not correct. If Table 1 was still kept, all alloy composition need to be checked to be correct and only UNS alloy designation to be listed in the table.

US Clause 6/

6.2.2.1

te The existing list does not contain a reference to elemental sulphur, and elemental sulphur can lead to environmental cracking.

Add to the defined list:“The presence of free sulphur.”

US Clause 6/

6.2.2.1

PARA. 2 ed The term “industry best practice corrosion modelling” is not acceptable. This term is wide open for debate and interpretation, and could lead to significant problems if that debate were to take place in a court of law.

Furthermore, not all end users consider themselves knowledgeable enough to specify a corrosion model. Thus, it is not always the end user that selects the

Revise to read:

“The potential for corrosion shall be evaluated using corrosion modelling or corrosion testing.”

Please note this revised paragraph deletes the sentence:




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corrosion model. “The model to be used shall be specified by the end user.”

US Clause 6/

6.2.2.1

PARA. 6 ed The term “industry best practice” is not acceptable. This term is wide open for debate, and could lead to significant problems if that debate were to take place in a court of law.

Revise to read:

“The evaluation shall be based on erosion modelling.”

US Clause 6/

6.2.3

PARA. 2 te DNV RP F-112 is, we believe, still in a draft stage, it may be inappropriate here.

Revise the last sentence to read,

“The requirement of DNV RP F-112 for duplex stainless steels, when released, shall be satisfied.”

US Clause 6/

6.3.2

PARA. 2 te The grammar is not good and does not represent commercial practice.

“The standard minimum overlay thickness shall be 3mm. Either higher or lower minimum overlay thicknesses may be specified, if acceptable to both the manufacturer and the end user. For Nickel base alloy UNS N06625 (AWS ERNicrMo3), the chemical composition shall meet either Class Fe5 or Class Fe10 as specified in ISO 10423. The manufacturer and/or end user shall select the appropriate class.

US Clause 6/

6.3.4

PARA. 6 te Duplex stainless steel if left uncoated may be subject to hydrogen embrittlement.

The last sentence replace with:

Coating of tubing with outer diameter less than 25mm (1”) is not required except when duplex stainless materials are used.

US Clause 6/

6.3.4

PARA. 1 te The use of the term “All” is in conflict with the exemption that follows.

Delete “All” in the first sentence.

US Clause 6/

6.4.1

Table 3 ed The term “13Cr4Ni” is not a standard alloy designation. What is this alloy? Does it have a UNS number? Does it have a common name? If this is F6NM, call it F6NM or use the UNS number.

Replace “3Cr4Ni” with “UNS S41500”.

US Clause 6/ Table 3 te The title is incorrect for what the table covers. Revise to read:




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6.4.1 “Table 3 – Materials selection for subsea systems”

US Clause 6/

6.4.1

Table 3 ed The paragraph reference is incorrect.Footnote b should read

“Oxygen equivalent in compliance with 6.2.2.2 or lower.”

US Clause 6/

6.4.2.1

PARA. 10 ed This paragraph is not clear as to what needs to do the spot hardness check. The bolt manufacturer? The distributor? The equipment manufacturer? or the end user?

Revise to clarify which party must do the testing.

Also, revise to use a more descriptive term other than “spot hardness testing”.

US Clause 6/

6.4.2.1

PARA. 1 te The use of the term “Type A4” is open to discussion and debate.

Revise to read:

“…Type of any strength grade…”

US Clause 6/

6.4.2.1

PARA. 6 te Suitable coatings of the electrolytic plating category may include other materials such as Zn-Ni or Zn-Co.

Revise to read:

“Post-baking of parts after electrolytic plating is not required provided the hardness of the fasteners is as specified in table 4”

US Clause 6/

6.4.2.1

PARA. 9 te Cadmium plating is an excellent sacrificial coating that can be legally used in many countries and geographic locations around the world. There is no reason to add a prohibition to cadmium plating to this international standard just because some nations have banned cadmium plating. This is an international standard, not a North Sea standard!

Delete paragraph 9.

Add cadmium to the list of possible coatings.

US Clause 6/

6.4.3

PARA. 1 ed The wording is not good, and sounds more like a helpful hint rather than a specification.

Revise the first sentence to read:

"Gasket materials for subsea hydrocarbon service may be manufactured from Type 316 stainless steel, Alloy 825 or Alloy 625. Selection of the gasket material should address the desired level of




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corrosion resistance, as well as any environmental limits imposed by other standards such as NACE MR0175 / ISO 15156, if applicable."

US Clause 6/

6.4.3

PARA. 2 ed This paragraph reads, “Material for gaskets in ASME ring type joints…..”. Was this intended to read, “Material for gaskets in API ring type joints……”? If so, it should be revised.

Revise to read as follows if the intent is to say API rather than ASME.

“Material for gaskets in API ring type joints……”

US Clause 6/

6.4.4

PARA. 2 ge The term “independently verified” should be deleted. “Independently verified” tests are not required for metallic materials. Furthermore, the term is not defined to show independent of whom?

Revise the second sentence to read,

“The documentation shall include results from relevant tests, and confirmed successful experience in design, operational and environmental situation.”

US Clause 6/

6.4.4

PARA. 3 te Documentation for the relevant materials from suppliers refers to the NORSOK M710. In the real world, suppliers are not willing to pay the extra cost for the extensive NORSOK tests. Additionally, the long lead time required for testing and supply of parts in accordance with the NORSOK requirements has prevented widespread acceptance of these onerous requirements.

Revise to read as follows:

“For these components, documentation for the relevant materials from all suppliers used shall be provided in accordance with the documentation requirements of a recognized standards organization (for example, ISO, API, NACE, or NORSOK).”

US Clause 6/

6.5.1

PARA. 11 te Copper based alloys are not referenced, but they are subject to cracking when exposed to mercury.

Add Copper based alloys shall not be exposed to mercury or mercury based compounds.

US Clause 6/

6.5.1

PARA. 1,

2nd bullet

te The SMYS limit does not reflect long term actual practices in the oil and gas industry, and needs to be raised. Subsea wellheads and other components have been specified and manufactured with materials with a SMYS of 85 KSI (586 MPa) for decades, with no adverse affects. 85 KSI (586 MPa) is a norm, not an exception.

Revise to read:

“The SMYS of carbon and low alloy steels intended for welding shall not exceed 586 MPa (85 KSI). A higher ……”

US Clause 6/

6.5.1

PARA. 1,

3rd bullet

te It is widely known that the way to minimize the risk of environmentally assisted cracking of cathodically protected carbon and low alloy steels exposed to sea

Revise bullet 3 to read as follows:

“The hardness of carbon and low alloy steels




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water is to limit the hardness of the material. The SMYS is not the problem. The maximum hardness is.

Published literature indicates that the recommended limit for cathodically protected carbon and low alloy steels exposed to sea water is 34 HRC maximum. 34 HRC converts to 336 Vickers and 319 Brinell per ASTM E140.

Additionally, published literature indicates that the recommended limit for carbon and low alloy steels exposed to sea water but not cathodically protected is 35 HRC maximum. 35 HRC converts to 345 Vickers and 327 Brinell.

This international standard should not impose limits on minimum strength since that is not the problem, but instead impose limits on the maximum hardness.

exposed to sea water, but not cathodically protected, is 35 HRC maximum or 345 Vickers maximum or 327 Brinell maximum.

The hardness of carbon and low alloy steels exposed to sea water and cathodically protected is 34 HRC maximum or 336 Vickers maximum or 319 Brinell maximum.”

Delete bullet 4.

US Clause 6/ Table 5 te Is “Ln” natural log? Please specify. Define the characters used in the formula.

US Clause 6/ Table 5 te Published literature indicates that the recommended limit for cathodically protected carbon and low alloy steels exposed to sea water is 34 HRC maximum. 34 HRC converts to 336 Vickers and 319 Brinell per ASTM E140

Revise the maximum hardness values for carbon and low alloy steels to read as follows:

“34 HRC (336 HV) (319 HB)”

Also, delete the reference to footnote a.

US Clause 6/ Table 4 te Published literature indicates that the recommended limit for cathodically protected carbon and low alloy steels exposed to sea water is 34 HRC maximum. 34 HRC converts to 336 Vickers and 319 Brinell per ASTM E140

Revise column 5 and Replace the Maximum hardness value of “35 HRC” with “34 HRC”.

US Clause 6/ Table 4 te The title of the table is not clearly worded. Revise to read:

“Table 4 – Bolting materials for pressure equipment”.




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US Annex L/ ed The current draft contains only metric units, while, like it or not, the oil and gas industry still utilizes imperial units worldwide.

All metric units shall be followed by the imperial equivalent. For example 414 MPa (60 KSI)

US Annex L/

3.2 (abbreviated terms)

te SMYS is described in this draft as “specified minimum yield stress”, when the correct description is actually “specified minimum yield strength”.

Revise to read:

SMYS specified minimum yield strength

US Annex L/

Clause 2

te The following statements refers to ASME documents that are not included in the Page 1, Clause 2, normative references:

The defect acceptance level shall be in accordance with ASME B31.3, Chapter VI, Normal Fluid Service, and Chapter IX, High Pressure Service, for pipe classes with rating above class 2500, unless more severe requirements is specified by the designer.

ASME B31.8 GAS TRANSMISSION AND DISTRIBUTION PIPING SYSTEMS

Add ASME B31.8 and ASME B31.3 to the list of reference standards.

US Annex L/

L. 1

PARA. 3 ed Is there not an error in the second sentence at the reference to B31.3 (first sentence refers to B31.8)

Revise ASME B31.3 to B31.8

US Annex L/

L.2.4

PARA. 1 ed The term “low alloy steel” was inadvertently left out of this paragraph.

Revise to read:

The material shall have a weldability suitable for all stages of component manufacture, fabrication, and installation. The following requirements shall apply to carbon steel, low alloy steel, and stainless steel grades:




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US Annex L/

L.2.4

PARA. 1, bullet 1

ed The appropriate term is “sulphur”, not “sulphurous”. Revise “sulphurous” to “sulphur”.

US Annex L/

L.2.4

PARA. 1, bullet 1, table

te One of the standard maximum sulphur limits used for steels manufactured and stocked worldwide is 0.025 %. The way the table currently reads (S < 0,025%), the sulphur maximum is 0.024%. This will unnecessary limit the use of many heats of steel at a time when steel is in very short supply.

Revise any sulphur maximum in the table listed as “S < 0.025%” to read “S </= 0.025%”.

US Annex L/

L. 2.4

PARA. 1, Bullet 2

te For carbon and low alloy steels, material from stock must frequently be purchased. Thus, the equipment manufacturer does not always get to specify the tempering temperature.

Add the following wording to the end of the bullet.

“Alternatively the base material may be tested in the simulated PWHT condition”

US Annex L/

L.2.4

PARA. 2 ed / te

There is a reference to the maximum hardness values in ISO 13628-1 Amendment 1, Clause 6, Table 2, but Table 2 is for paint systems.

A reference to the correct table will need to be provided before we can determine if this is technically acceptable. (Table L.5)

US Annex L/

L.2.5.1

PARA. 4 te There is a term used in this paragraph that is neither a widely used term nor a term defined in the spec. That term is “same quality heat treatment load”.

Revise to read:

“same heat treatment lot”.

US Annex L/

L.2.5.2

Section Heading

ed The current heading references forgings, but the paragraphs that follow include requirements for forgings and HIPed components.

Revise to read:

“Test sampling of forgings and hot isostatically pressed components”

US Annex L/

L. 2.5.2

Para, 3,

Bullet 2

te How can the heaviest section from a prolongation be guaranteed when the thickest section may be in the middle of a forging?

Add another bullet:

“At a cross section thickness representing the area of the part with maximum stresses.”

US Annex L/

L.2.5.2

PARA. 1 ed

te

The 1st paragraph is in conflict with the 3rd paragraph of L.2.5.1. By not saying “same size”, it weakens the requirements and by adding the 6000 kg requirement, it adds a useless requirement with no real technical

Rewrite to read:

“A test lot is defined as components of the same type manufactured according to the same




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justification. manufacturing and heat treatment lot.”

US Annex L/

L.2.5.2

PARA. 4 te If separate test bars at to be allowed, then they should be restricted in accordance with the type of requirements specified by ISO 10423 for QTC’s.

Revise to include the ISO 10423 requirements for QTC’s as applicable.

US Annex L/

L.2.5.2

PARA. 6 ed This paragraph references forgings, but the requirement needs to reference HIP components since the paragraph immediately above this one specifies integral test blocks for HIP components.

Revise to read:

“Integral test samples shall not be parted from the HIP component until after all heat treatment is completed.”

Also, make this part of the 5th paragraph, rather than a stand alone paragraph.

US Annex L/

L. 2.6.3

PARA. 1 and

Table L.5

te Age hardened Nickel base alloys also need to be tested.

Replace with

All products in ferritic, ferritic-austenitic, martensitic steel and precipitation hardened nickel alloy shall be impact tested per test lot for products with wall thickness 6,0 mm or greater.

Revise Table L.5 to add the alloy 718 values from API Spec 6A 718.

US Annex L/

L. 2.6.3

Table L.5 te The orientation of the test specimens is not defined.

Add a Footnote to Table L.5 that states:

“Testing in only one orientation is required for acceptance.

US Annex L/

L.2.6.3

PARA. 1 te The 5th sentence does not make sense. Components have many surfaces.

Delete the 5th sentence.

Alternately, utilize industry standard designations to specify the orientation of the impact specimens.




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Note(e.g. Table 1)

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US Annex L/

L.2.6.3

Table L.5 ed The table references “carbon steels”, but does not reference “low alloy steels”.

Revise rows 2 and 3 to read:

“Carbon and low alloy steels …..”.

US Annex L/

L.2.6.5

Title ed The title says “Micrographic examination”, but the requirement is for a “Microstructure Examination”

Revise to read:

“Microstructure examination”

US Annex L/

L.2.6.5

PARA. 2 ed The requirement is for a microstructure examination, and this term is used in paragraph 1.

Revise to read:

“Microstructure evaluation”

US Annex L/

L.2.6.6

Title ed The grammar is not very good. Revise to read:

“25Cr duplex stainless steel, Type 6Mo stainless steel and other highly alloyed austenitic stainless steels

US Annex L/

L.2.6.6

PARA. 1 ed The grammar is not very good. Revise to read:

Corrosion testing shall be performed on all types of components manufactured from 25Cr duplex stainless steel, Type 6Mo stainless steel and other highly alloyed austenitic stainless steels”.

US Annex L/

L.2.6.6.2

Title ed The grammar is not very good. Revise to read:

“22Cr duplex stainless steel (Optional)”

US Annex L/

L.2.6.6.2

PARA. 1 ed The grammar is not very good. Revise to read:

“Corrosion testing of 22Cr duplex stainless steel is optional and must only be performed when specified by either the manufacturer or the end user. Testing shall be …..”

US Annex L/

L2.7.3

PARA. 1

3rd sentence

te Non-machined surfaces may not always be “cleaned”. For example, they may be grit blasted.

Suggest rewording 3rd sentence, 1st paragraph, to

“Non-machined surfaces shall be appropriately prepared before testing”.




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


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Note(e.g. Table 1)

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US Annex L/

L.4.3.1

PARA. 2 te The undefined term “quality heat treatment” is used again.

Revise to read:

“….does not require re-heat treatment, provided the process….”

US Annex L/

L.4.3.2

PARA. 1 ed An undefined acronym, “MPS”, is used in this paragraph. Revise to read:

Manufacturing Procedure Specification (MPS).

US Annex L/

L.5.2

PARA. 1 ed The grammar is not very good, and does not represent commercial practice.

Revise to read:

“Welding procedures for corrosion resistant weld overlay shall be qualified in accordance with ASME Section lX or ISO 10423, PSL3.”

US Annex L/

L.5.2

PARA. 2 ed/te The grammar is not very good. Revise to read:

“The standard minimum overlay thickness shall be 3mm. Either higher or lower minimum overlay thicknesses may be specified, if acceptable to both the manufacturer and the end user. For Nickel base alloy UNS N06625 (AWS ERNicrMo3), the chemical composition shall meet either Class Fe5 or Class Fe10 as specified in ISO 10423. The manufacturer and/or end user shall select the appropriate class.

US Annex L/

L.5.3

te Weld buttering and butt welding to buttered weld preps may contribute to field problems if not done properly. The existing text does not provide sufficient guidelines to avoid some of the know problems.

Add the following requirement to this section:

“Weld buttering and butt welding to buttered weld preps shall be performed in accordance with the guidelines specified in EEMUA Publication No. 194. Additionally, transitions in wall thickness shall not be made in the butt weld.”

US Annex L/

L6.1.1

PARA. 1,

1st sentence

te Titanium does not belong. Delete “ and Titanium”




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


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Note(e.g. Table 1)

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US Annex L/

L.6.1.1

3 ed The wording in this paragraph is different from the widely accepted wording in ASME Section lX regarding the manufacturer or contractors use of WPS’s.

Revise to read as follows:

Qualification and use of WPS’s is subject to the requirements of ISO 15614 Section 8.2 or ASME Section lX, QW-100.1 and QW-201.

US Annex L/ L6.1.4.2

6th bullet Te This bullet needs to be revised to use standard industry terms for carbon equivalents.

Revise to read:

“For carbon steels with SMYS>/= 415 MPa (60,000 PSI) without PWHT: an increase in carbon equivalent, CE(Pcm) or CE(IIW), of more than 0.02 for CE(Pcm) and 0.03 for the CE(IIW).”

US Annex L/ L6.1.4.2

7th bullet This bullet and the two equations need to be revised to use standard industry terms for carbon equivalents and standard industry equations for carbon equivalents.

The proposed wording in the column to the right comes directly from API Specification 5L, Section 6.1.3.1.

The benefit of standards is that they do just that, they standardize requirements. The current wording in the ballot does not help the standardization effort by adding a new equation for Pcm, when there is a widely used existing equation for Pcm.

Additionally, it is not helpful to take the existing equation for CE(IIW) that is correctly written, and re-name it as “Pce”

Let’s contribute to the standardization of specifications for the oil and gas industry, not make things less standard and more confusing.

Revise to read:

“For carbon steels for sour service: an increase in carbon equivalent, CE(Pcm) or CE(IIW), of more than 0.02 for CE(Pcm) and 0.03 for the CE(IIW).

a. When the carbon content is less than or equal to 0.12%, the carbon equivalent shall be calculated using the following formula for CE(Pcm) [see Note 1]:

CE(Pcm)=C+Si/30+Mn/20+Cu/20+Ni/60+Cr/20+Mo/15+V/10+5B

If the heat analysis indicates a boron content less than 0.001%, then the product analysis need not include boron, and the boron content can be considered as zero for the CE(Pcm) calculation.

b. When the carbon content is greater than 0.12%, the carbon equivalent shall be calculated using the following formula for C(IIW) [see Note 2]:

CE(IIW)=C+Mn/6+(Cr+Mo+V)/5+(Ni+Cu)/15




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Note 1:The CE(Pcm) formula for low carbon steels is commonly called the Ito-Bessyo formula. CE(Pcm) is in fact the chemical portion of the full formula. Reference: Y. Ito & K. Bessyo, “Weldability Formula Of High Strength Steels Related to Heat Affected Zone Cracking, “Journal of Japanese Welding Society; 1968, 37, (9), 938.

Note 2: The CE(IIW) formula is commonly called the IIW [International Institute of Welding] formula. Reference: Technical Report, 1967, IIW doc.IX-535-67.

US Annex L/

L6.1.5.1

Para. 4

1st sentence

te Titanium does not belong. Delete “ and titanium”

Revise to read “…nickel base alloys…”

US Annex L/

L6.1.5.1

PARA. 4 ed Does not make sense. Revise to read:

“The system designer or end user shall specify such systems.”

US Annex L/

L6.1.8

PARA. 1 te Measurements are not typically made down in the weld joint.

Revise to read:

“The interpass temperature shall be measured adjacent to the weld bevel. The minimum…”

US Annex L/

L6.1.9

PARA. 1. 3rd sentence

te The oxygen limit proposed in the draft spec does not represent common commercial practices used to successfully stainless steels and nickel alloys, and would put an unnecessary burden on the industry.

Revise to read:

“The oxygen content of the backing gas shall be controlled to be less than 5000 ppm.”




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US Annex L/

L.6.1.13

PARA. 4 te The requirement for the PWHT temperature to be lower than the original temperature is not acceptable for high strength quench and temper steels that must meet ISO 15156.

There are two options.

(1) Delete this paragraph.

Or

(2) Revise to read as follows:

“For weldments that are not required to meet ISO 15156, the PWHT temperature should not exceed the tempering temperature of the base metal(s).

For weldments that are required to meet ISO 15156, the PWHT temperature may exceed tempering temperature of the base metal(s) if the PQR demonstrates that the specified mechanical properties can still be maintained after PWHT.

US Annex L/

L7.1.3

PARA. 4 te The ASME term “GMAW” needs to be included. Add “131 MIG/135 MAG/GMAW”

US Annex L/

L7.1.4

Table L.9 te The variable “t” in the last column should be uniquely identified as the thickness of the block to distinguish it from the thickness of material to be examined t.

Change “t” to “T” in column 1 and 2;

Add footnote “t is the thickness of the calibration test block used.”

US Annex L/

L7.1.5

PARA. 1 te Replace with:

“…High Pressure Service, for pipe classes with rating above class 2500, unless more severe requirements are specified by the manufacturer or customer.”

US L.1 para 3 ed ASME B31.8 is listed then ASME B31.3 Change 31.8 to 31.3 and list in normative references

US L.2.2 Para 2, Line 3

ed Spelling “normalized” Change to “normalised” consistent with rest of document




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US L.2.4 Para 2, Table

te For Sour service, I find it odd that S<0,025% is allowed when welding consumables for certain materials require S<0,015%

S<0,015% consistent with Subclause L.6.1.7.3 and L.6.1.7.7

US L.2.5.2 Para 1 ed first paragraph states a definition Move to definition section

US L.2.6.3 Table L.4 ed requirement stated in footnote Move requirement to paragraph text.

US L.2.6.3 Table L.5 ed requirement stated in footnote Move requirement to paragraph text.

US L.4.3.2 Para 1 ed ...essential variables of the MPS qualification...

MPS is not defined in abbreviation list

add MPS to abbreviated terms list

US L.4.3.3 Para 5 ed intrados and extrados are not common oilfield terms add definition of both terms to definitions section

US L.5.1 Para 3, Line 1

ed LP is defined in abbreviations, but I think SNT-TC-1A uses PT for penetrant exam

Use “PT” vs. “LP” for consistent terminology

US L.5.3 NOTE following Para 1

ed requirements are stated in the NOTE which is informative by definition

Move requirements in NOTE to paragraph text.

US L.6.1.12 Para 2, Line 2

ed Reference to “table 1” is not clear Table L.1?

US L.7.1.2 Line 4 ed Reference to ASNT TC 1A is not strictly correct designation

Change to ASNT Recommended Practice SNT-TC-1A (ASNT is the issuing organization). This is consistent with ISO 10423 citation

US Page iii Contents ed 6.2 Corrosivity eveluation - Spelling Should be “evaluation”

US Page 3 footnote 1) ed "In course pf preparation Should be "In course of preparation"

US 3.1.13 Line 2 ed No period at end of sentence Add period consistent with rest of document



US 6.1 Para 1 and 3 ed Paragraphs 1 and 3 duplicate requirements Harmonize paragraphs 1 and 3 to have one set of




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requirements.

US 6.1 bullet 2 ed "shall be considered" at end of bullet statement is redundant to lead in statement

remove "shall be considered"

US 6.1 bullet 3 ed "shall be taken into account" at end of bullet statement is redundant to lead in statement

remove "shall be taken into account"

US 6.1 bullet 13 ed "corrosion fatigue loaded components" needs clarification likely should be "components subject to corrosion and fatigue loading"

US 6.1 Para 5 and 6 ed "...agreed upon" should state the parties of the agreement replace with "agreed between the user/purchaser and the supplier manufacturer"

US 6.1 Table 1 ed Table 1 breaks up the flow of the document and is really an informative list of materials that may be used in corrosive service.

Move Table 1 to an informative annex.

US 6.1 Table 1 te Alloy 718 is listed with UNS number only Include API Spec 6A718

US 6.1 Table 1 ed Cobalt is split along two lines fix table row widths to accommodate entire word

US 6.1 Table 1, footnotes

ed Footnotes a and b show 0.014% Should be 0,014% for consistent metric terminology

US 6.2.1 Para 1 and 2 ed both lead sentences end with a preposition Correct grammar

US 6.2.2.1 Para 1 ed As stated, all items in bullet list must be evaluated Add "where applicable" to the lead sentence.

US 6.2.2.1 Para 4 ed Definition given for "dry gas" Move to definitions.

US 6.2.2.1 last para ed ...are corrosive... assumes complete knowledge about all such chemicals now and in the future

change to "may be corrosive"

US 6.2.2.2 Para 2 ed As stated, all items in bullet list must be evaluated Add "where applicable" to the lead sentence.

US 6.2.2.2 bullet 6 ed high or low water velocity is redundant change to "water velocity"

US 6.3.1 para 2 ed ..."consideration should be given to applying a corrosion allowance"... does not state a requirement or a real recommendation

change to "it is recommended to apply a corrosion allowance"




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US 6.3.1 para 3 ed statement provides informative recommendations Change to NOTE. Add reference to Bibliography.

US 6.3.2 para 2 and 3 ed requirements are stated with no instruction on methods to achieve

add methodologies for evaluating mass fraction and documentation of corrosion resistance

US 6.3.3 para 3 ed this paragraph is informative move to NOTE.

US 6.3.4 bullet list ed Note contained in first bullet move to NOTE following list.

US 6.3.5 Table 2 ed requirements are stated as footnotes to the table move notes 1 and 2 in the table footnotes up into the paragraph text above

US 6.3.5 Table 2, note 3 and 4

ed “Note Such…” - lacks punctuation and lacks heading Should be “Note: Such…” and should have heading of "a" and "b" and be called out in the table above.

US 6.3.4.1 Table 3 ed 2nd and 4th lines state "As for production a b" which is unclear

Improve reference to other section of document.

US 6.4.1 Table 3, footnote b

ed Source of “6.3.2.2” reference is unclear ? There is no Subclause by that number in this document

US 6.4.1 Table 3, footnote g

ed “60oC” is not correct Should be “60ºC”

US 6.4.3 Para 1, Line 6

ed “...given to ensuring adequate…” grammar error Should be “…given to ensure adequate…”

US 6.4.4 para 3 ed reference to NORSOK M-710 is vague as to whether or not it is normative or informative

change wording to reflect correct reference as:

shall be provided according to NORSOK M-710

US 6.5.1 para 1 ed Design limitations... as stated are really material property limitations and the list following is re-stated in the bullets below

change first sentence to read:

Material selection and property limitations for the application of different material types are defined in the following general requirements that apply for all steel types including bolts.

US 6.5.1 Table 5, footnote b

ed “HRC = 43.796*In (HB) – 220.86” meaning is unclear Does this mean “multiply the Brinell hardness number by 43.796”? Need a clearer expression




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Note(e.g. Table 1)

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for “In”.

US 6.5.1 Table 5 row 3 and 4

ed The table is supposed to be values but notes are included instead.

Move "values" for rows 3 and 4 to notes in the bottom of the table.

US 6.5.1 Table 5, footnote 1

ed Requirements stated as footnotes to the table. Move this requirement to the paragraph text above

Cover See highlighted changes. immergés

3.1.14 See highlighted changes. 3.1.14corrosion-resistant alloys (CRA)non-ferrous alloys where any one or the sum of the specified amount of the following alloy elements exceeds 50%: titanium, nickel, cobalt, chromium, and molybdenum

NOTE This term refers to corrosion resistant alloys and not cracking resistant alloys as mentioned in ISO 15156

3.1.15 New definition 3.1.15corrosion-resistant materials (CRM)ferrous or non-ferrous alloys which are more corrosion resistant than low alloy steels. This term includes: CRA’s, duplex, and stainless steels.

3 New edition caused renumbering of all subsequent terms after 3.1.15

3.1.17 See highlighted changes. CRMs and

6.1 See highlighted changes. cost profile (i.e. Investment,

Materials selection should be

inspection and maintenance requirements, failure risk evaluations and other requirements specific to




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the project. It should provideThe following should be considered during the material selection corrosion protection design process: corrosivity (see 6.2), taking into account

specified operating conditions including start up, shut-down conditions and well stimulation and flowback operations;

corrosion during transportation of materials, storage, construction, installation and testing prior to start-up should be taken into account;

possible seawater flooding during installation and testing should be taken into account;

Table 1 See highlighted changes. a It is recommended to specify duplex stainless steels of type UNS 31803 to have a minimum nitrogen content of 0.14%b It is recommended to specify Super duplex stainless steels to have a minimum nitrogen content of 0.14% and PRE>40.

6.2.1 See highlighted changes. The corrosivity evaluation should consider

The model to be used should be specified

environmental cracking should be

pressure is 10 °C (18 °F) or more below the

service conditions during the lifetime should be

according to ISO 15156 (all parts).

The evaluation should be based




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corrosive and should be

6.2.2.2 See highlighted changes. injection systems should as

the use of biocides and other injected chemicals.

temperature of 30 °C (86 °F) and

6.2.3 See highlighted changes. compliant with ISO 15156 (All parts).

stainless steels should also be

6.3.2 See highlighted changes. thickness of 3,0 mm (0,12 in.) may

6.3.4 See highlighted changes. (service temperature less than 40 °C, 105 oF);

less than 25mm (1,0 in.)6.3.5 See highlighted changes. phase should be provided

systems should be selectedper ISO 12944-2, Table 2. The paint system specified in Table 2 shall be used.

Table 2 See highlighted changes. The paint systems should be used in combination with cathodic protection.

The paint system is aimed at ambient operating temperatures and maximum 50 °C (122 °F). For higher operating temperatures, a specific evaluation and performance documentation is needed. For temperatures between 50oC and 100oC (122 °F to 212 °F), 2 coats immersion grade epoxy phenolic each 125µm, may be considered as adequate.




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Table 1 See highlighted changes. Subsea wellheads and trees

Subsea wellhead and tree equipment for production

Subsea wellhead and tree equipment for de-aerated seawater

Subsea wellhead and tree equipment for aerated seawater

Subsea wellhead and tree equipment for produced water and aquifer water

Nickel alloys and Stainless steels with PRE>40 (max 40 ºC, 105 ºF), Nickel alloys, Titanium.

Hydraulic fluids/glycol/methanol Chemical injection and annulus bleed systems

Subsea production control systems

Thermoplastic elastomer, high strengthg AISI 316L instrument lines are suitable for subsea applications provided that they are protected by cathodic protection and the temperature is less than 60oC (140 ºF).

6.4.2.1 See highlighted changes. Subsea bolting not used in structural fastening applications shall be

Bolting screwed into component bodies should be of a

Bolts classified as main pressure bearing or for main structural Closure bolting (as defined in ISO 10423 and 13628-4) shall be delivered

higher temperature (>20 oC, >68 oF) seawater




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Table 4 See highlighted changes. Added USC units to entire table, including footnotes a and c.

6.4.3 See highlighted changes. limit of about 180 HV to 200 HV (180 to 200 HB / 89 to 92 HRB).

6.4.4 See highlighted changes. components, subsea trees, valves

6.4.5 See highlighted changes. Subsea control umbilicals

temperature should be considered

umbilicals should be made of seawater resistant CRM, unless

6.5.1 See highlighted changes. pecified in 6.2.1 should be considered. For submerged parts that may be exposed to

cathodic protection, the following shall apply:o The SMYS of carbon and low

alloy steels should not exceed 700 MPa (101 000 psi) (725 MPa (105 000 psi) for bolts)

not exceed 350 HV10 (35 HRC) (330 HB).

should be given

cold deformed up toa percentage of 15% may be used provided the elongation in a tensile test can be documented to be greater than 14% after cold forming, and that all welds exposed to the cold deformation areis coated or isolatedsheltered from the CP system.

Footnote 3) relevant part of ISO 13628,

Table 5 See highlighted changes. b a sensitivity to hydrogen




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Table 1 Table 1 should add another 25Cr duplex bar product—UNS 39277.

Notes a and b in Table 1 contain mistakes—the minimum nitrogen content for super duplex is 0.14%, not 0.014%.

6.3.4

Table 3

Both places specified stainless steel and nickel alloy with PRE>40 are regarded as resistant to corrosion when submerged in seawater and therefore do not require cathodic protection. There was additional statement of “service temperature less than 20 °C”. FMC assumes the statement is based on NORSOK M-001 (Rev.4 in 2004) which states “Alloy 625 and stainless steels with PRE ≥ 40 are borderline cases and should not be used for mechanical connections without cathodic protection when their material temperature exceeds ambient North Sea sea water temperatures.” in clause 4.3.6.

FMC feels that 20 °C is too low a service temperature. Sea water temperature (both surface and subsea) in Australia, S.E. Asia, and Africa will be 18 to 31°C. It’s been documented that simple pitting and crevice corrosion starts at temperatures above 40 °C. An operator’s recent specification cites, ”…materials are considered seawater resistant if PRE>40 without temperature limitation.” It further states, ”…the corrosion test as per ASTM G48A may be reduced to 40°C for duplex stainless steel base material and 35°C for duplex stainless steel welds, if it can be shown that the service temperatures will not exceed these values.” It also states, “…the corrosion test for supper duplex is at 50°C and alloy 625 overlay weld at 80 °C.” ASTM G48A is designed to correlate to performance in natural sea water; the degree of corrosion damage that




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occurs during testing will generally be greater than that in natural environments. These temperatures specified for the test in ASTM G48A should be used as temperature limitation. Titanium should be immune to corrosion in sea water regardless of temperature.

Table 4 Minimum temperature for ASTM A320 L7M should be -73 °C instead of -100 °C as per recommended by ASTM A320. Maximum temperature for ASTM A453 Grade 660 should be 65 °C and it’s allowed maximum hardness is 35 HRC as per ISO 15156 (NACE MR0175) Table A.26, and ISO 13628-4.

6.4.3 Hardness limit for AISI 316 and alloy 825 gasket materials will be 83 HRB and 92 HRB respectively according to ISO 10423 requirement.

Table L.5 The impact energy values in Table L.5 differ with the values stated in ISO 10423 for carbon steel and NORSOK M-630 for duplex steel. The values in table L.5 need to be aligned with these documents.

L.5.3 Revise “Test shall be 100 % volumetrically testing by ultrasonic and radiography methods” to “Test shall be 100 % volumetrically testing by ultrasonic or radiography methods”.

Annex L This heavily references ASTM A182, but does not mention ASTM A479, for rolled bar.

L.2.3 L.2.3 Rolled bar should reference ASTM A479. Table L.5 Charpy V-notch of 60J for 25Cr duplex would be very




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difficult to achieve. For 22Cr duplex, this is fine. 45J would be more likely for 25Cr.

L.6.1.3.5 L.6.1.3.5 states “…intermetallic phases, nitrides and carbides shall not in total exceed 0.5%.” Very nebulous as to what method to count, measure or prove this. Why not refer to words similar to that in the 3rd paragraph of L.2.6.5 “…acceptance should be based on corrosion testing or impact testing.”—as an alternative.



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