Comments for Results of voting on NWIP Amendments to …



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|As needed to resolve comments. | |

| | | | |– reviewed and resolved prior to the issuance of the first DIS ballot, | | |

| | | | |with resolutions noted in an included comment register; | | |

|US |Entire document | |Technical |The material contained in this ballot should be compared and aligned to|Align documents and add Introduction note “Upon publication of| |

| | | | |the content of proposed API 17P / ISO 13628-15. It should be noted |API 17P / ISO 13628-15, the requirements/ recommendations in | |

| | | | |that overlapping material will be withdrawn on the publication of |(pertinent clauses) for (pertinent products) in this | |

| | | | |17P/-15; |International Standards 13628-1 will be superseded.”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 |-46 should be 46; -100 should be 100; 65mm might be 50mm (but | |

| | | | |not. In the past edition of this document (1999), the temp ranges for |regardless, the correct USC unit dimensions should be given). | |

| | | | |bolt material were "Above 100 (212)", "Above 46 (115)" and "-196 to +60|A temporary corrigenda may need to be issued to correct Table | |

| | | | |(-320 to +140). The new ranges all start with large negative temps |1 in the current published edition until this new Table 4 | |

| | | | |(-46, -100, -196) that are very different than the previous edition. |replaces it. | |

| | | | |Note that a similar problem appears to exist with the current ediiton | | |

| | | | |Table 1 for bolting material. | | |

| | | | | | | |

| | | | |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 |Add the USC units in parantheses after the SI units in all | |

| | | | |both SI and USC units used in the text and tables, inlcuding the |text and tables to match the remainder of the document and the| |

| | | | |current edition of ISO 13628-1/API RP 17A. Some USC units are given in|common practices of users in all parts of the world. | |

| | | | |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). | | |

|US |L.6.1.13 | |Technical |Clause L.6.1.13, last sentence, "In no case shall the PWHT temperature |Revise to read: | |

| | | | |exceed the tempering temperatures of the base materials." This is |"For carbon and low alloy steels, the PWHT temperature shall | |

| | | | |unacceptable for martensitic stainless steels such as AISO 410; for |not exceed the tempering temperatures of the base materials." | |

| | | | |such material it is necessary to exceed the tempering temperature in | | |

| | | | |order to obtain proper stress relief. | | |

|US |L.2.2 | |Editorial |In the last sentence of the 2nd paragraph, "All fittings shall be |Revise to read, "All fitting shall be used in normalised, | |

| | | | |delivered in normalised, normalised and tempered..." the use of the |normalised and tempered..." | |

| | | | |word "delivered" could create disagreements as to when in the | | |

| | | | |production process the material must be heat treated. | | |

|US |L.6.1.5.1 | |Technical |Fifth paragraph, "Socket welds shall not be used at pressure containing|Revise to read, "Socket welds shall not be used at pressure | |

| | | | |piping," is unnecessarily restrictive. There are acceptable uses of |containing piping, except by agreement." | |

| | | | |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. | | |

|US |Clause 3, Terms and| |Editorial |The definition proposed for "corrosion resistant alloys (CRAs)" is the |(a) Replace definition for CRAs with definition from ISO | |

| |definitions | | |same as in ISO 15156, but different than is used in ISO 10423. Also, |10423, (b) add definition for "stainless steel" from ISO | |

| | | | |throughout the proposed Annex L, the term "steel" is used where it is |10423, and insert "stainless steels" throught Annex L and | |

| | | | |intended to refer to carbon steel, alloy steel, and stainless steel. |clause 6 where needed for clarification. | |

| | | | |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. | | |

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

| | | | |materials | | |

|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|For welded pipe and fittings, PQR/WPQR shall be qualified in | |

| | | | |with DNV OS F101 Eliminate reference to ASME IX and ISO 15614-1. |accordance with DNV OS F101 | |

| | | | |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. | | |

|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 | |Technical |The PWHT temperature and the tempering temperature should be a minimum |The tempering temperature shall be at least 30 degrees | |

| |Second bullet | | |of 30 degrees centigrade difference |centigrade higher than the PWHT temperature. | |

|US |L.2.6.6.1, | |Technical |Prior to corrosion testing the specimen shall not be pickled. The |Eliminate the last sentence of the third paragraph. | |

| |Paragraph 3 | | |testing should be carried out in the exact condition that it will be | | |

| | | | |placed in service. More times than not the material goes into service | | |

| | | | |not pickled. | | |

|US |L.4.3.1, Paragraph | |Technical |All bends for duplex stainless steel shall be solution annealed after |Add sentence: Duplex stainless steel shall be solution | |

| |3 | | |bending. Numerous material problems have been identified with |annealed after induction bending. | |

| | | | |induction bending duplex stainless steel without solution anneal after | | |

| | | | |bending. | | |

|US |L.4.3.3, Paragraph | |Technical |The number of test locations shall not be reduced for any reason. |Eliminate paragraph 5 | |

| |5 | | |Mechanical properties at all locations need to be verified no matter | | |

| | | | |how closely the process is controlled. | | |

|US |L.6.1.1, Paragraph | |Technical |Replace codes referenced with DNV OS F101. Eliminate reference to ASME|…shall be qualified according to DNV OS F101 and to this | |

| |1 | | |IX and ISO 15614-1 and ISO 15614-5. These documents are not designed |standard. | |

| | | | |to specifically address submarine pipeline design as the DNV code is. | | |

| | | | |These documents are inadequate to address requirements for subsea | | |

| | | | |applications. | | |

|US |L.6.1.3.1, | |Technical |Replace codes referenced with DNV OS F101. Eliminate reference to ASME|Mechanical testing shall be performed as specified in DNV OS | |

| |Paragraph 1 | | |IX and ISO 15614. These documents are not designed to specifically |F101 and the additional requirements in this standard. | |

| | | | |address submarine pipeline design as the DNV code is. These documents | | |

| | | | |are inadequate to address requirements for subsea applications. | | |

|US |L.6.1.3.5, | |Technical |Maximum of 1% of intermetallics shall be acceptable for accepting a |In case of excessive amounts of intermetallics phases of limit| |

| |Paragraph 2 | | |WPQR based on corrosion and impact testing alone. The specimens used |stated above, up to a maximum of 1%, | |

| | | | |for corrosion and impact testing may be selectively sampled in an | | |

| | | | |attempt to provide areas that have less intermetallics | | |

|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|Change 27 J to 48 J. | |

| | | | |J. | | |

|US |L.6.1.4.1, | |Technical |Remove all standards references and replace with DNV OS F101. . |…essential variables listed in DNV OS F101 and the additional | |

| |Paragraph 1 | | |Eliminate reference to ASME IX and ISO 15614. These documents are not |essential variables … | |

| | | | |designed to specifically address submarine pipeline design as the DNV | | |

| | | | |code is. These documents are inadequate to address requirements for | | |

| | | | |subsea applications. | | |

|US |L.6.1.4.3, | |Technical |Reduce the allowable heat input range to + 10 %. 15% is excessive on |…heat input shal be + 10 %. | |

| |Paragraph 1 | | |heat input to control intermetallic phases consistently. | | |

|US |L.6.1.7.2, | |Technical |10 ml shall be changed to 8 ml to be consistent with the AWS |…consumables (HDM 8 ml/100g weld metal or AWS H8) or solid… | |

| |Paragraph 1 | | |designation of H8 | | |

|US |L.6.1.12, Paragraph| |Other |There is no table 1 in this text. Need to indicate the correct | | |

| |2 | | |reference. | | |

|US |L.6.1.13, Paragraph| |Technical |PWHT temperature shall be at least 30 degrees centigrade lower than the|The PWHT temperature shall be at least 30 degrees centigrade | |

| |4 | | |tempering temperature of the material. This ensures adequate |lower than the tempering temperature of the base materials. | |

| | | | |mechanical properties maintained in the base materials. | | |

|US |6.2.3 | |Other |Recommends adhering to ISO 15156 to minimize likelihood of CP, however |Recommend following the criteria of DnV RP B401 section 5.5. | |

| | | | |this criteria is not commonly used for this purpose. | | |

|US |6.2.3 | |Other |Requires that DNV RP F112 be satisfied to protect Duplex SS with CP. |Recommend following the guidelines in DnV RP B401 and NORSOK. | |

| | | | |This is only a draft document that has not been accepted. Recommend | | |

| | | | |following the guidelines in DnV RP B401 and NORSOK. | | |

|US | | |Editorial |For 13628-1. The highlighted in yellow text (editorial) changes to |See below comments. | |

| | | | |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 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 |Add: | |

| | | | |3.2. Perform a spell check on entire document to find all |CGB completion guide base | |

| | | | |abbreviations. |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|Table 16, Section B, add | |

| | | | |or water based) |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 |In section h) Downhole interface for the SCSSV add three items| |

| | | | |of the control system and planning operating philosophy / procedures |in the Description column: "Swept Volume:" and "Total Vertical| |

| | | | |for producing the well. |Set Depth:" and "Open / Close Gauge Pressures of SCSSV" | |

|US |12.5.3 | |Editorial |Section h) and section n) are both labeled "Downhole interface." |Add to n)Downhole interface: | |

| | | | |Combine these sections. Also, it would be helpful to list the data |DHPT card interface to SCM - Specify: | |

| | | | |about the DHPT card interface to SCM. |Combine sections h) and n) | |

|US |ISO 13628-1 | |Technical |Nominal wall thickness should be properly defined in Tab L.4, even for |Replace "Nominal wall/weld thickness" with "Maximum wall/weld | |

| |Amedment 2 ANNEX L| | |parts in which the wall thikness varies. |thickness" | |

| |Table L.4 | | | | | |

|US |Clause 6/ | |ed |The current draft contains only metric units, while, like it or not, |All metric units shall be followed by the imperial equivalent.| |

| | | | |the oil and gas industry still utilizes imperial units worldwide. |For example 20o C (68o F). | |

|US |Clause 6/ | |ge |The material selection principles in ISO 13628 Amendment 1 clause 6 |Add the following text as a new Para. 1: | |

| |6.1 | | |need to be consistent with ISO 13628-4. |Material selection is the ultimate responsibility of the user | |

| | | | | |as he has the knowledge of the production environment as well | |

| | | | | |as control over the 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/ |Table 1 |ge |This table should be deleted. It doesn’t provide any real fixed |Delete Table 1. | |

| |6.1 | | |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? | | |

|US |Clause 6/ |Table 1 |ed |Column 2 contains a number of trademarked names. Use of trademarked |Delete the trade names (Nitronic, Custom, Monel, Elgiloy, | |

| |6.1 | | |names can lead to restraint of trade lawsuits against ISO. |Tungum), or delete column 2 altogether. | |

|US |Clause 6/ |Table 1 |ed |UNS N07716 is not Custom 625. It is Custom 625 Plus. However, “Custom”|Revise to read Alloy 625 Plus. | |

| |6.1 | | |is a trademark name. | | |

|US |Clause 6/ |Table 1 |te |CA6NM composition is not correct. |If Table 1 was still kept, all alloy composition need to be | |

| |6.1 | | | |checked to be correct and only UNS alloy designation to be | |

| | | | | |listed in the table. | |

|US |Clause 6/ | |te |The existing list does not contain a reference to elemental sulphur, |Add to the defined list: | |

| |6.2.2.1 | | |and elemental sulphur can lead to environmental cracking. |“The presence of free sulphur.” | |

|US |Clause 6/ |PARA. 2 |ed |The term “industry best practice corrosion modelling” is not |Revise to read: | |

| |6.2.2.1 | | |acceptable. This term is wide open for debate and interpretation, and |“The potential for corrosion shall be evaluated using | |

| | | | |could lead to significant problems if that debate were to take place in|corrosion modelling or corrosion testing.” | |

| | | | |a court of law. |Please note this revised paragraph deletes the sentence: | |

| | | | |Furthermore, not all end users consider themselves knowledgeable enough|“The model to be used shall be specified by the end user.” | |

| | | | |to specify a corrosion model. Thus, it is not always the end user that | | |

| | | | |selects the corrosion model. | | |

|US |Clause 6/ |PARA. 6 |ed |The term “industry best practice” is not acceptable. This term is wide|Revise to read: | |

| |6.2.2.1 | | |open for debate, and could lead to significant problems if that debate |“The evaluation shall be based on erosion modelling.” | |

| | | | |were to take place in a court of law. | | |

|US |Clause 6/ |PARA. 2 |te |DNV RP F-112 is, we believe, still in a draft stage, it may be |Revise the last sentence to read, | |

| |6.2.3 | | |inappropriate here. |“The requirement of DNV RP F-112 for duplex stainless steels, | |

| | | | | |when released, shall be satisfied.” | |

|US |Clause 6/ |PARA. 2 |te |The grammar is not good and does not represent commercial practice. | “The standard minimum overlay thickness shall be 3mm. Either| |

| |6.3.2 | | | |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/ |PARA. 6 |te |Duplex stainless steel if left uncoated may be subject to hydrogen |The last sentence replace with: | |

| |6.3.4 | | |embrittlement. |Coating of tubing with outer diameter less than 25mm (1”) is | |

| | | | | |not required except when duplex stainless materials are used. | |

|US |Clause 6/ |PARA. 1 |te |The use of the term “All” is in conflict with the exemption that |Delete “All” in the first sentence. | |

| |6.3.4 | | |follows. | | |

|US |Clause 6/ |Table 3 |ed |The term “13Cr4Ni” is not a standard alloy designation. What is this |Replace “3Cr4Ni” with “UNS S41500”. | |

| |6.4.1 | | |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. | | |

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

| |6.4.1 | | | |“Table 3 – Materials selection for subsea systems” | |

|US |Clause 6/ |Table 3 |ed |The paragraph reference is incorrect. |Footnote b should read | |

| |6.4.1 | | | | | |

| | | | | |“Oxygen equivalent in compliance with 6.2.2.2 or lower.” | |

|US |Clause 6/ |PARA. 10 |ed |This paragraph is not clear as to what needs to do the spot hardness |Revise to clarify which party must do the testing. | |

| |6.4.2.1 | | |check. The bolt manufacturer? The distributor? The equipment |Also, revise to use a more descriptive term other than “spot | |

| | | | |manufacturer? or the end user? |hardness testing”. | |

|US |Clause 6/ |PARA. 1 |te |The use of the term “Type A4” is open to discussion and debate. |Revise to read: | |

| |6.4.2.1 | | | |“…Type of any strength grade…” | |

|US |Clause 6/ |PARA. 6 |te |Suitable coatings of the electrolytic plating category may include |Revise to read: | |

| |6.4.2.1 | | |other materials such as Zn-Ni or Zn-Co. |“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/ |PARA. 9 |te |Cadmium plating is an excellent sacrificial coating that can be legally|Delete paragraph 9. | |

| |6.4.2.1 | | |used in many countries and geographic locations around the world. |Add cadmium to the list of possible coatings. | |

| | | | |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! | | |

|US |Clause 6/ |PARA. 1 |ed |The wording is not good, and sounds more like a helpful hint rather |Revise the first sentence to read: | |

| |6.4.3 | | |than a specification. | | |

| | | | | |"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 corrosion resistance, as well as any | |

| | | | | |environmental limits imposed by other standards such as NACE | |

| | | | | |MR0175 / ISO 15156, if applicable." | |

|US |Clause 6/ |PARA. 2 |ed |This paragraph reads, “Material for gaskets in ASME ring type |Revise to read as follows if the intent is to say API rather | |

| |6.4.3 | | |joints…..”. Was this intended to read, “Material for gaskets in API |than ASME. | |

| | | | |ring type joints……”? If so, it should be revised. |“Material for gaskets in API ring type joints……” | |

|US |Clause 6/ |PARA. 2 |ge |The term “independently verified” should be deleted. “Independently |Revise the second sentence to read, | |

| |6.4.4 | | |verified” tests are not required for metallic materials. Furthermore, |“The documentation shall include results from relevant tests, | |

| | | | |the term is not defined to show independent of whom? |and confirmed successful experience in design, operational and| |

| | | | | |environmental situation.” | |

|US |Clause 6/ |PARA. 3 |te |Documentation for the relevant materials from suppliers refers to the |Revise to read as follows: | |

| |6.4.4 | | |NORSOK M710. In the real world, suppliers are not willing to pay the |“For these components, documentation for the relevant | |

| | | | |extra cost for the extensive NORSOK tests. Additionally, the long lead|materials from all suppliers used shall be provided in | |

| | | | |time required for testing and supply of parts in accordance with the |accordance with the documentation requirements of a recognized| |

| | | | |NORSOK requirements has prevented widespread acceptance of these |standards organization (for example, ISO, API, NACE, or | |

| | | | |onerous requirements. |NORSOK).” | |

|US |Clause 6/ |PARA. 11 |te |Copper based alloys are not referenced, but they are subject to |Add | |

| |6.5.1 | | |cracking when exposed to mercury. |Copper based alloys shall not be exposed to mercury or mercury| |

| | | | | |based compounds. | |

|US |Clause 6/ |PARA. 1, |te |The SMYS limit does not reflect long term actual practices in the oil |Revise to read: | |

| |6.5.1 |2nd bullet | |and gas industry, and needs to be raised. Subsea wellheads and other |“The SMYS of carbon and low alloy steels intended for welding | |

| | | | |components have been specified and manufactured with materials with a |shall not exceed 586 MPa (85 KSI). A higher ……” | |

| | | | |SMYS of 85 KSI (586 MPa) for decades, with no adverse affects. 85 KSI | | |

| | | | |(586 MPa) is a norm, not an exception. | | |

|US |Clause 6/ |PARA. 1, |te |It is widely known that the way to minimize the risk of environmentally|Revise bullet 3 to read as follows: | |

| |6.5.1 |3rd bullet | |assisted cracking of cathodically protected carbon and low alloy steels|“The hardness of carbon and low alloy steels exposed to sea | |

| | | | |exposed to sea water is to limit the hardness of the material. The |water, but not cathodically protected, is 35 HRC maximum or | |

| | | | |SMYS is not the problem. The maximum hardness is. |345 Vickers maximum or 327 Brinell maximum. | |

| | | | |Published literature indicates that the recommended limit for |The hardness of carbon and low alloy steels exposed to sea | |

| | | | |cathodically protected carbon and low alloy steels exposed to sea water|water and cathodically protected is 34 HRC maximum or 336 | |

| | | | |is 34 HRC maximum. 34 HRC converts to 336 Vickers and 319 Brinell per |Vickers maximum or 319 Brinell maximum.” | |

| | | | |ASTM E140. | | |

| | | | |Additionally, published literature indicates that the recommended limit|Delete bullet 4. | |

| | | | |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. | | |

|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 |Revise the maximum hardness values for carbon and low alloy | |

| | | | |cathodically protected carbon and low alloy steels exposed to sea water|steels to read as follows: | |

| | | | |is 34 HRC maximum. 34 HRC converts to 336 Vickers and 319 Brinell per |“34 HRC (336 HV) (319 HB)” | |

| | | | |ASTM E140 |Also, delete the reference to footnote a. | |

|US |Clause 6/ |Table 4 |te |Published literature indicates that the recommended limit for |Revise column 5 and Replace the Maximum hardness value of “35 | |

| | | | |cathodically protected carbon and low alloy steels exposed to sea water|HRC” with “34 HRC”. | |

| | | | |is 34 HRC maximum. 34 HRC converts to 336 Vickers and 319 Brinell per | | |

| | | | |ASTM E140 | | |

|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”. | |

|US |Annex L/ | |ed |The current draft contains only metric units, while, like it or not, |All metric units shall be followed by the imperial equivalent.| |

| | | | |the oil and gas industry still utilizes imperial units worldwide. |For example 414 MPa (60 KSI) | |

|US |Annex L/ | |te |SMYS is described in this draft as “specified minimum yield stress”, |Revise to read: | |

| |3.2 (abbreviated | | |when the correct description is actually “specified minimum yield |SMYS specified minimum yield strength | |

| |terms) | | |strength”. | | |

|US |Annex L/ | |te |The following statements refers to ASME documents that are not included| | |

| |Clause 2 | | |in the Page 1, Clause 2, normative references: |Add ASME B31.8 and ASME B31.3 to the list of reference | |

| | | | | |standards. | |

| | | | |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 | | |

|US |Annex L/ |PARA. 3 |ed |Is there not an error in the second sentence at the reference to B31.3 |Revise ASME B31.3 to B31.8 | |

| |L. 1 | | |(first sentence refers to B31.8) | | |

|US |Annex L/ |PARA. 1 |ed |The term “low alloy steel” was inadvertently left out of this |Revise to read: | |

| |L.2.4 | | |paragraph. |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: | |

|US |Annex L/ |PARA. 1, bullet 1 |ed |The appropriate term is “sulphur”, not “sulphurous”. |Revise “sulphurous” to “sulphur”. | |

| |L.2.4 | | | | | |

|US |Annex L/ |PARA. 1, bullet 1,|te |One of the standard maximum sulphur limits used for steels manufactured|Revise any sulphur maximum in the table listed as “S < 0.025%”| |

| |L.2.4 |table | |and stocked worldwide is 0.025 %. The way the table currently reads (S|to read “S /= 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 |Revise to read: | |

| | | | |industry terms for carbon equivalents and standard industry equations |“For carbon steels for sour service: an increase in carbon | |

| | | | |for carbon equivalents. |equivalent, CE(Pcm) or CE(IIW), of more than 0.02 for CE(Pcm) | |

| | | | |The proposed wording in the column to the right comes directly from API|and 0.03 for the CE(IIW). | |

| | | | |Specification 5L, Section 6.1.3.1. |a. When the carbon content is less than or equal to 0.12%, | |

| | | | |The benefit of standards is that they do just that, they standardize |the carbon equivalent shall be calculated using the following | |

| | | | |requirements. The current wording in the ballot does not help the |formula for CE(Pcm) [see Note 1]: | |

| | | | |standardization effort by adding a new equation for Pcm, when there is |CE(Pcm)=C+Si/30+Mn/20+Cu/20+Ni/60+Cr/20+Mo/15+V/10+5B | |

| | | | |a widely used existing equation for Pcm. |If the heat analysis indicates a boron content less than | |

| | | | |Additionally, it is not helpful to take the existing equation for |0.001%, then the product analysis need not include boron, and | |

| | | | |CE(IIW) that is correctly written, and re-name it as “Pce” |the boron content can be considered as zero for the CE(Pcm) | |

| | | | |Let’s contribute to the standardization of specifications for the oil |calculation. | |

| | | | |and gas industry, not make things less standard and more confusing. |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 | |

| | | | | |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/ |Para. 4 |te |Titanium does not belong. |Delete “ and titanium” | |

| |L6.1.5.1 |1st sentence | | |Revise to read “…nickel base alloys…” | |

|US |Annex L/ |PARA. 4 |ed |Does not make sense. |Revise to read: | |

| |L6.1.5.1 | | | |“The system designer or end user shall specify such systems.” | |

|US |Annex L/ |PARA. 1 |te |Measurements are not typically made down in the weld joint. |Revise to read: | |

| |L6.1.8 | | | |“The interpass temperature shall be measured adjacent to the | |

| | | | | |weld bevel. The minimum…” | |

|US |Annex L/ |PARA. 1. 3rd |te |The oxygen limit proposed in the draft spec does not represent common |Revise to read: | |

| |L6.1.9 |sentence | |commercial practices used to successfully stainless steels and nickel |“The oxygen content of the backing gas shall be controlled to | |

| | | | |alloys, and would put an unnecessary burden on the industry. |be less than 5000 ppm.” | |

|US |Annex L/ |PARA. 4 |te |The requirement for the PWHT temperature to be lower than the original |There are two options. | |

| |L.6.1.13 | | |temperature is not acceptable for high strength quench and temper |(1) Delete this paragraph. | |

| | | | |steels that must meet ISO 15156. |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/ |PARA. 4 |te |The ASME term “GMAW” needs to be included. |Add “131 MIG/135 MAG/GMAW” | |

| |L7.1.3 | | | | | |

|US |Annex L/ |Table L.9 |te |The variable “t” in the last column should be uniquely identified as |Change “t” to “T” in column 1 and 2; | |

| |L7.1.4 | | |the thickness of the block to distinguish it from the thickness of |Add footnote “t is the thickness of the calibration test block| |

| | | | |material to be examined t. |used.” | |

|US |Annex L/ |PARA. 1 |te | |Replace with: | |

| |L7.1.5 | | | |“…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 | |

|US |L.2.4 |Para 2, Table |te |For Sour service, I find it odd that S ................
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