Amedment Operating Agreement

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


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

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                 Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                              on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

FR    3.1.14                              te       Is the intention to distinguish CRAs from Stainless               Clarify if CRAs have less than 50% iron; example :
                                                   Steels?                                                           Ni based alloys.
                                                   It can be inferred from other sections such as 6.4.3 and          Otherwise mention as examples that austenitic
                                                   6.4.5 that stainless steels are also CRAs.                        stainless steels (eg 316L) and Duplex stainless
                                                                                                                     steel are also considered as CRAs in this
                                                                                                                     standard.
                          rd
FR    6.3.4              3 bullet         te       Why specifically mention glass reinforced plastics ?              Use a more general term for these type of
                         point                                                                                       materials non subject to corrosion : non-metallic
                                                                                                                     composites.
FR    6.3.4                               te       Cathodic protection standards mentioned are DNV RP-               Mention also ISO 15589-2
                                                   B401 and NACE RP0176


US    Entire                              Tech     The US requests that these comments be fully                      As needed to resolve comments.
      document                            nical    considered as DIS comments – reviewed and resolved
                                                   prior to the issuance of the first DIS ballot, with
                                                   resolutions noted in an included comment register;
US    Entire                              Tech     The material contained in this ballot should be compared          Align documents and add Introduction note ―Upon
      document                            nical    and aligned to the content of proposed API 17P / ISO              publication of API 17P / ISO 13628-15, the
                                                   13628-15. It should be noted that overlapping material            requirements/ recommendations in (pertinent
                                                   will be withdrawn on the publication of 17P/-15;                  clauses) for (pertinent products) in this
                                                                                                                     International Standards 13628-1 will be
                                                                                                                     superseded.‖
US    6.4.2.2 Table                       Tech     Verify the that temperature ranges for the materials are          -46 should be 46; -100 should be 100; 65mm
      4                                   nical    correct or not. In the past edition of this document              might be 50mm (but regardless, the correct USC
                                                   (1999), the temp ranges for bolt material were "Above             unit dimensions should be given). A temporary
                                                   100 (212)", "Above 46 (115)" and "-196 to +60 (-320 to            corrigenda may need to be issued to correct Table
                                                   +140). The new ranges all start with large negative               1 in the current published edition until this new
                                                   temps (-46, -100, -196) that are very different than the          Table 4 replaces it.
                                                   previous edition. Note that a similar problem appears to
                                                   exist with the current ediiton Table 1 for bolting material.



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 29
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Template for comments and secretariat observations                                                                   Date: 2007-02-07                  Document: ISO/TC67/SC4/WG6/13628-1 A1&A2


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

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                  Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                               on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                   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                              Tech     TC67/SC4/WG6 documents are jointly developed with                 Add the USC units in parantheses after the SI
      Document                            nical    API SC17 and have both SI and USC units used in the               units in all text and tables to match the remainder
                                                   text and tables, inlcuding the current edition of ISO             of the document and the common practices of
                                                   13628-1/API RP 17A. Some USC units are given in                   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                            Tech     Clause L.6.1.13, last sentence, "In no case shall the             Revise to read:
                                          nical    PWHT temperature exceed the tempering temperatures
                                                   of the base materials." This is unacceptable for                  "For carbon and low alloy steels, the PWHT
                                                   martensitic stainless steels such as AISO 410; for such           temperature shall not exceed the tempering
                                                   material it is necessary to exceed the tempering                  temperatures of the base materials."
                                                   temperature in order to obtain proper stress relief.
US    L.2.2                               Edito    In the last sentence of the 2nd paragraph, "All fittings          Revise to read, "All fitting shall be used in
                                          rial     shall be delivered in normalised, normalised and                  normalised, normalised and tempered..."
                                                   tempered..." the use of the word "delivered" could create
                                                   disagreements as to when in the production process the
                                                   material must be heat treated.
US    L.6.1.5.1                           Tech     Fifth paragraph, "Socket welds shall not be used at               Revise to read, "Socket welds shall not be used at
                                          nical    pressure containing piping," is unnecessarily restrictive.        pressure containing piping, except by agreement."
                                                   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.
US    Clause 3,                           Edito    The definition proposed for "corrosion resistant alloys           (a) Replace definition for CRAs with definition from
      Terms and                           rial     (CRAs)" is the same as in ISO 15156, but different than is        ISO 10423, (b) add definition for "stainless steel"
      definitions                                  used in ISO 10423. Also, throughout the proposed Annex            from ISO 10423, and insert "stainless steels"
                                                   L, the term "steel" is used where it is intended to refer to      throught Annex L and clause 6 where needed for
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 2 of 29
ISO electronic balloting commenting template/version 2001-10
Template for comments and secretariat observations                                                                   Date: 2007-02-07                  Document: ISO/TC67/SC4/WG6/13628-1 A1&A2


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

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                               Proposed change by the MB             Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                              on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                   carbon steel, alloy steel, and stainless steel. ISO 13628-        clarification.
                                                   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 —                Table 3 — Materials selection for subsea systems
                                                   Weld overlay materials
US    Table 3                             Edito    Sub-sea                                                           Subsea
                                          rial
US    6.4.5                               Edito    Sub-sea                                                           Subsea
                                          rial
US    L.2.2                               Tech     For welded pipe and fittings, PQR/WPQR shall be                   For welded pipe and fittings, PQR/WPQR shall be
      Paragraph 3                         nical    qualified in accordance with DNV OS F101 Eliminate                qualified in accordance with DNV OS F101
                                                   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.
US    L.2.2                               Tech     Add DNV code to last sentence for welder qualifications.          All welding shall be carried out by welders
      Paragraph 3                         nical                                                                      qualified in accordance with ISO 9606, ASME IX,
                                                                                                                     DNV OS F101 or EN 287
US    Paragraph                           Tech     The PWHT temperature and the tempering temperature                The tempering temperature shall be at least 30
      L.2.4 Second                        nical    should be a minimum of 30 degrees centigrade difference           degrees centigrade higher than the PWHT
      bullet                                                                                                         temperature.
US    L.2.6.6.1,                          Tech     Prior to corrosion testing the specimen shall not be              Eliminate the last sentence of the third paragraph.
      Paragraph 3                         nical    pickled. The 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.

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 3 of 29
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Template for comments and secretariat observations                                                                   Date: 2007-02-07                  Document: ISO/TC67/SC4/WG6/13628-1 A1&A2


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

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                 Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                              on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

US    L.4.3.1,                            Tech     All bends for duplex stainless steel shall be solution            Add sentence: Duplex stainless steel shall be
      Paragraph 3                         nical    annealed after bending. Numerous material problems                solution annealed after induction bending.
                                                   have been identified with induction bending duplex
                                                   stainless steel without solution anneal after bending.
US    L.4.3.3,                            Tech     The number of test locations shall not be reduced for any         Eliminate paragraph 5
      Paragraph 5                         nical    reason. Mechanical properties at all locations need to be
                                                   verified no matter how closely the process is controlled.
US    L.6.1.1,                            Tech     Replace codes referenced with DNV OS F101. Eliminate              …shall be qualified according to DNV OS F101
      Paragraph 1                         nical    reference to ASME IX and ISO 15614-1 and ISO 15614-               and to this standard.
                                                   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.
US    L.6.1.3.1,                          Tech     Replace codes referenced with DNV OS F101. Eliminate              Mechanical testing shall be performed as specified
      Paragraph 1                         nical    reference to ASME IX and ISO 15614. These documents               in DNV OS F101 and the additional requirements
                                                   are not designed to specifically address submarine                in this standard.
                                                   pipeline design as the DNV code is. These documents
                                                   are inadequate to address requirements for subsea
                                                   applications.
US    L.6.1.3.5,                          Tech     Maximum of 1% of intermetallics shall be acceptable for           In case of excessive amounts of intermetallics
      Paragraph 2                         nical    accepting a WPQR based on corrosion and impact                    phases of limit stated above, up to a maximum of
                                                   testing alone. The specimens used for corrosion and               1%,
                                                   impact testing may be selectively sampled in an attempt
                                                   to provide areas that have less intermetallics
US    L.6.1.3.5, L.8                      Tech     Acceptance criteria for Type 22Cr and 25 Cr shall be 48 J         Change 27 J to 48 J.
                                          nical    in lieu of 27 J.
US    L.6.1.4.1,                          Tech     Remove all standards references and replace with DNV              …essential variables listed in DNV OS F101 and
      Paragraph 1                         nical    OS F101. . Eliminate reference to ASME IX and ISO                 the additional essential variables …
                                                   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.


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 4 of 29
ISO electronic balloting commenting template/version 2001-10
Template for comments and secretariat observations                                                                   Date: 2007-02-07                  Document: ISO/TC67/SC4/WG6/13628-1 A1&A2


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

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                 Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                              on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

US    L.6.1.4.3,                          Tech     Reduce the allowable heat input range to + 10 %. 15% is           …heat input shal be + 10 %.
      Paragraph 1                         nical    excessive on heat input to control intermetallic phases
                                                   consistently.
US    L.6.1.7.2,                          Tech     10 ml shall be changed to 8 ml to be consistent with the          …consumables (HDM 8 ml/100g weld metal or
      Paragraph 1                         nical    AWS designation of H8                                             AWS H8) or solid…
US    L.6.1.12,                           Other    There is no table 1 in this text. Need to indicate the
      Paragraph 2                                  correct reference.
US    L.6.1.13,                           Tech     PWHT temperature shall be at least 30 degrees                     The PWHT temperature shall be at least 30
      Paragraph 4                         nical    centigrade lower than the tempering temperature of the            degrees centigrade lower than the tempering
                                                   material. This ensures adequate mechanical properties             temperature of the base materials.
                                                   maintained in the base materials.
US    6.2.3                               Other    Recommends adhering to ISO 15156 to minimize                      Recommend following the criteria of DnV RP B401
                                                   likelihood of CP, however this criteria is not commonly           section 5.5.
                                                   used for this purpose.
US    6.2.3                               Other    Requires that DNV RP F112 be satisfied to protect                 Recommend following the guidelines in DnV RP
                                                   Duplex SS with CP. This is only a draft document that             B401 and NORSOK.
                                                   has not been accepted. Recommend following the
                                                   guidelines in DnV RP B401 and NORSOK.
US                                        Edito    For 13628-1. The highlighted in yellow text (editorial)           See below comments.
                                          rial     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
                                                   stainless steels cannot be used in sea water above 20
                                                   degrees C. We think this should be over 40 degrees C.

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 5 of 29
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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./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                  Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                               on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

US    3.2                                 Edito    Missing some abbreviations used in the document; add to           Add:
                                          rial     the list in 3.2. Perform a spell check on entire document
                                                   to find all abbreviations.                                        CGB completion guide base
                                                                                                                     GLL guidelineless
                                                                                                                     QTC quality test coupon
                                                                                                                     SCM subsea control module
US    7.10.2.1.2                          Edito    Add to Table 16 Section B (Actuator) new #12 Type of              Table 16, Section B, add
                                          rial     control fluid (oil or water based)
                                                                                                                     12 Type of Control Fluid (oil or water base)
US    12.5.3                              Edito    Additional information about the SCSSV would be helpful           In section h) Downhole interface for the SCSSV
                                          rial     in the design of the control system and planning operating        add three items in the Description column: "Swept
                                                   philosophy / procedures for producing the well.                   Volume:" and "Total Vertical Set Depth:" and
                                                                                                                     "Open / Close Gauge Pressures of SCSSV"
US    12.5.3                              Edito    Section h) and section n) are both labeled "Downhole              Add to n)Downhole interface:
                                          rial     interface." Combine these sections. Also, it would be
                                                   helpful to list the data about the DHPT card interface to         DHPT card interface to SCM - Specify:
                                                   SCM.                                                              Combine sections h) and n)
US    ISO 13628-1                         Tech     Nominal wall thickness should be properly defined in Tab          Replace "Nominal wall/weld thickness" with
      Amedment 2                          nical    L.4, even for parts in which the wall thikness varies.            "Maximum wall/weld thickness"
      ANNEX L
      Table L.4
US    Clause 6/                           ed       The current draft contains only metric units, while, like it      All metric units shall be followed by the imperial
                                                                                                                                                    o     o
                                                   or not, the oil and gas industry still utilizes imperial units    equivalent. For example 20 C (68 F).
                                                   worldwide.
US    Clause 6/                           ge       The material selection principles in ISO 13628                    Add the following text as a new Para. 1:
      6.1                                          Amendment 1 clause 6 need to be consistent with ISO               Material selection is the ultimate responsibility of
                                                   13628-4.                                                          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

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 6 of 29
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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./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                   Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                                on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                                                                                     materials for his review and approval.
US    Clause 6/          Table 1          ge       This table should be deleted. It doesn’t provide any real         Delete Table 1.
                                                   fixed requirement, and will just lead to a lot of requests for
      6.1                                          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.                  Delete the trade names (Nitronic, Custom, Monel,
                                                   Use of trademarked names can lead to restraint of trade           Elgiloy, Tungum), or delete column 2 altogether.
      6.1                                          lawsuits against ISO.
US    Clause 6/          Table 1          ed       UNS N07716 is not Custom 625. It is Custom 625 Plus.              Revise to read Alloy 625 Plus.
                                                   However, ―Custom‖ is a trademark name.
      6.1
US    Clause 6/          Table 1          te       CA6NM composition is not correct.                                 If Table 1 was still kept, all alloy composition need
      6.1                                                                                                            to be 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       Add to the defined list:
                                                   sulphur, and elemental sulphur can lead to environmental
      6.2.2.1                                      cracking.                                                         ―The presence of free sulphur.‖

US    Clause 6/          PARA. 2          ed       The term ―industry best practice corrosion modelling‖ is          Revise to read:
                                                   not acceptable. This term is wide open for debate and
      6.2.2.1                                      interpretation, and could lead to significant problems if         ―The potential for corrosion shall be evaluated
                                                   that debate were to take place in a court of law.                 using corrosion modelling or corrosion testing.‖

                                                   Furthermore, not all end users consider themselves                Please note this revised paragraph deletes the
                                                   knowledgeable enough to specify a corrosion model.                sentence:
                                                   Thus, it is not always the end user that selects the              ―The model to be used shall be specified by the
                                                   corrosion model.                                                  end user.‖
US    Clause 6/          PARA. 6          ed       The term ―industry best practice‖ is not acceptable. This         Revise to read:
                                                   term is wide open for debate, and could lead to significant
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 7 of 29
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Template for comments and secretariat observations                                                                   Date: 2007-02-07                  Document: ISO/TC67/SC4/WG6/13628-1 A1&A2


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

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                   Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                                on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

      6.2.2.1                                      problems if that debate were to take place in a court of          ―The evaluation shall be based on erosion
                                                   law.                                                              modelling.‖
US    Clause 6/          PARA. 2          te       DNV RP F-112 is, we believe, still in a draft stage, it may        Revise the last sentence to read,
                                                   be inappropriate here.
      6.2.3                                                                                                          ―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                     ―The standard minimum overlay thickness shall be
                                                   commercial practice.                                              3mm. Either higher or lower minimum overlay
      6.3.2
                                                                                                                     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          The last sentence replace with:
                                                   hydrogen embrittlement.
      6.3.4
                                                                                                                     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      Delete ―All‖ in the first sentence.
      6.3.4                                         that follows.

US    Clause 6/          Table 3          ed       The term ―13Cr4Ni‖ is not a standard alloy designation.           Replace ―3Cr4Ni‖ with ―UNS S41500‖.
                                                   What is this alloy? Does it have a UNS number? Does it
      6.4.1                                        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                                                                         Footnote b should read
                                                    The paragraph reference is incorrect.
      6.4.1                                                                                                          ―Oxygen equivalent in compliance with 6.2.2.2 or

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 8 of 29
ISO electronic balloting commenting template/version 2001-10
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./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                     Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                                  on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                                                                                     lower.‖
US    Clause 6/          PARA. 10         ed       This paragraph is not clear as to what needs to do the            Revise to clarify which party must do the testing.
      6.4.2.1                                      spot hardness check. The bolt manufacturer? The                   Also, revise to use a more descriptive term other
                                                   distributor? The equipment manufacturer? or the end               than ―spot hardness testing‖.
                                                   user?


US    Clause 6/          PARA. 1          te       The use of the term ―Type A4‖ is open to discussion and           Revise to read:
                                                   debate.
      6.4.2.1                                                                                                        ―…Type of any strength grade…‖


US    Clause 6/          PARA. 6          te       Suitable coatings of the electrolytic plating category may        Revise to read:
                                                   include other materials such as Zn-Ni or Zn-Co.
      6.4.2.1                                                                                                        ―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          Delete paragraph 9.
                                                   can be legally used in many countries and geographic
      6.4.2.1                                      locations around the world. There is no reason to add a           Add cadmium to the list of possible coatings.
                                                   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           Revise the first sentence to read:
                                                   hint rather than a specification.
      6.4.3
                                                                                                                     "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          Revise to read as follows if the intent is to say API
                                                   type joints…..‖. Was this intended to read, ―Material for
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 9 of 29
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 1            2                    (3)          4                                 5                                                              (6)                                  (7)

MB1    Clause No./        Paragraph/       Type            Comment (justification for change) by the MB                           Proposed change by the MB                 Secretariat observations
      Subclause No./     Figure/Table/      of                                                                                                                             on each comment submitted
         Annex               Note          com-
        (e.g. 3.1)       (e.g. Table 1)    ment2

      6.4.3                                         gaskets in API ring type joints……‖? If so, it should be          rather than ASME.
                                                    revised.
                                                                                                                     ―Material for gaskets in API ring type joints……‖
US    Clause 6/          PARA. 2           ge       The term ―independently verified‖ should be deleted.             Revise the second sentence to read,
                                                    ―Independently verified‖ tests are not required for metallic
      6.4.4                                         materials. Furthermore, the term is not defined to show          ―The documentation shall include results from
                                                    independent of whom?                                             relevant tests, and confirmed successful
                                                                                                                     experience in design, operational and
                                                                                                                     environmental situation.‖
US    Clause 6/          PARA. 3           te       Documentation for the relevant materials from suppliers          Revise to read as follows:
                                                    refers to the NORSOK M710. In the real world, suppliers
      6.4.4                                         are not willing to pay the extra cost for the extensive          ―For these components, documentation for the
                                                    NORSOK tests. Additionally, the long lead time required          relevant materials from all suppliers used shall be
                                                    for testing and supply of parts in accordance with the           provided in accordance with the documentation
                                                    NORSOK requirements has prevented widespread                     requirements of a recognized standards
                                                    acceptance of these onerous requirements.                        organization (for example, ISO, API, NACE, or
                                                                                                                     NORSOK).‖
US    Clause 6/          PARA. 11          te       Copper based alloys are not referenced, but they are             Add
                                                    subject to cracking when exposed to mercury.
      6.5.1                                                                                                          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       Revise to read:
                             nd                     in the oil and gas industry, and needs to be raised.
      6.5.1              2        bullet            Subsea wellheads and other components have been                  ―The SMYS of carbon and low alloy steels
                                                    specified and manufactured with materials with a SMYS            intended for welding shall not exceed 586 MPa (85
                                                    of 85 KSI (586 MPa) for decades, with no adverse affects.        KSI). A higher ……‖
                                                    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          Revise bullet 3 to read as follows:
                             rd                     environmentally assisted cracking of cathodically
      6.5.1              3 bullet                   protected carbon and low alloy steels exposed to sea             ―The hardness of carbon and low alloy steels
                                                    water is to limit the hardness of the material. The SMYS         exposed to sea water, but not cathodically
                                                    is not the problem. The maximum hardness is.                     protected, is 35 HRC maximum or 345 Vickers
                                                                                                                     maximum or 327 Brinell maximum.
                                                    Published literature indicates that the recommended limit
                                                    for cathodically protected carbon and low alloy steels           The hardness of carbon and low alloy steels
                                                    exposed to sea water is 34 HRC maximum. 34 HRC                   exposed to sea water and cathodically protected is
                                                                                                                     34 HRC maximum or 336 Vickers maximum or
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 10 of 29
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 1           2                (3)              4                                  5                                                              (6)                                  (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                 Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                              on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                   converts to 336 Vickers and 319 Brinell per ASTM E140.            319 Brinell maximum.‖
                                                   Additionally, published literature indicates that the
                                                   recommended limit for carbon and low alloy steels
                                                   exposed to sea water but not cathodically protected is 35         Delete bullet 4.
                                                   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         Revise the maximum hardness values for carbon
                                                   for cathodically protected carbon and low alloy steels            and low alloy steels to read as follows:
                                                   exposed to sea water is 34 HRC maximum. 34 HRC
                                                   converts to 336 Vickers and 319 Brinell per ASTM E140             ―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         Revise column 5 and Replace the Maximum
                                                   for cathodically protected carbon and low alloy steels            hardness value of ―35 HRC‖ with ―34 HRC‖.
                                                   exposed to sea water 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      All metric units shall be followed by the imperial
                                                   or not, the oil and gas industry still utilizes imperial units    equivalent. For example 414 MPa (60 KSI)
                                                   worldwide.
US    Annex L/                            te       SMYS is described in this draft as ―specified minimum             Revise to read:
                                                   yield stress‖, when the correct description is actually
      3.2                                          ―specified minimum yield strength‖.                               SMYS specified minimum yield strength
      (abbreviated
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 11 of 29
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 1             2              (3)              4                                  5                                                              (6)                                     (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                    Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                                 on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

      terms)
US    Annex L/                            te       The following statements refers to ASME documents that
                                                   are not included in the Page 1, Clause 2, normative
      Clause 2                                                                                                       Add ASME B31.8 and ASME B31.3 to the list of
                                                   references:
                                                                                                                     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               Revise ASME B31.3 to B31.8
                                                   reference to B31.3 (first sentence refers to B31.8)
      L. 1


US    Annex L/           PARA. 1          ed       The term ―low alloy steel‖ was inadvertently left out of this     Revise to read:
                                                   paragraph.
      L.2.4                                                                                                          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,         ed       The appropriate term is ―sulphur‖, not ―sulphurous‖.              Revise ―sulphurous‖ to ―sulphur‖.
                         bullet 1
      L.2.4
US    Annex L/           PARA. 1,         te       One of the standard maximum sulphur limits used for               Revise any sulphur maximum in the table listed as
                         bullet 1,                 steels manufactured and stocked worldwide is 0.025 %.             ―S < 0.025%‖ to read ―S </= 0.025%‖.
      L.2.4              table                     The way the table currently reads (S < 0,025%), the
                                                   sulphur maximum is 0.024%. This will unnecessary limit

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 12 of 29
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 1             2              (3)              4                                  5                                                              (6)                                  (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                 Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                              on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                   the use of many heats of steel at a time when steel is in
                                                   very short supply.
US    Annex L/           PARA. 1,         te       For carbon and low alloy steels, material from stock must         Add the following wording to the end of the bullet.
                         Bullet 2                  frequently be purchased. Thus, the equipment
      L. 2.4                                       manufacturer does not always get to specify the                   ―Alternatively the base material may be tested in
                                                   tempering temperature.                                            the simulated PWHT condition‖


US    Annex L/           PARA. 2          ed /     There is a reference to the maximum hardness values in            A reference to the correct table will need to be
                                          te       ISO 13628-1 Amendment 1, Clause 6, Table 2, but Table             provided before we can determine if this is
      L.2.4                                        2 is for paint systems.                                           technically acceptable. (Table L.5)
US    Annex L/           PARA. 4          te       There is a term used in this paragraph that is neither a          Revise to read:
                                                   widely used term nor a term defined in the spec. That
      L.2.5.1                                      term is ―same quality heat treatment load‖.                       ―same heat treatment lot‖.

US    Annex L/           Section          ed       The current heading references forgings, but the                  Revise to read:
                         Heading                   paragraphs that follow include requirements for forgings
      L.2.5.2                                      and HIPed components.                                             ―Test sampling of forgings and hot isostatically
                                                                                                                     pressed components‖
US    Annex L/           Para, 3,         te       How can the heaviest section from a prolongation be               Add another bullet:
                                                   guaranteed when the thickest section may be in the
      L. 2.5.2           Bullet 2                                                                                    ―At a cross section thickness representing the area
                                                   middle of a forging?
                                                                                                                     of the part with maximum stresses.‖


US    Annex L/           PARA. 1          ed       The 1st paragraph is in conflict with the 3rd paragraph of        Rewrite to read:
                                                   L.2.5.1. By not saying ―same size‖, it weakens the
      L.2.5.2                             te
                                                   requirements and by adding the 6000 kg requirement, it            ―A test lot is defined as components of the same
                                                   adds a useless requirement with no real technical                 type manufactured according to the same
                                                   justification.                                                    manufacturing and heat treatment lot.‖

US    Annex L/           PARA. 4          te       If separate test bars at to be allowed, then they should be       Revise to include the ISO 10423 requirements for
                                                   restricted in accordance with the type of requirements            QTC’s as applicable.
      L.2.5.2                                      specified by ISO 10423 for QTC’s.
US    Annex L/           PARA. 6          ed       This paragraph references forgings, but the requirement           Revise to read:
                                                   needs to reference HIP components since the paragraph
      L.2.5.2                                      immediately above this one specifies integral test blocks         ―Integral test samples shall not be parted from the
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 13 of 29
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 1           2                   (3)           4                                  5                                                              (6)                                         (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                        Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                                     on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                   for HIP components.                                               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/           PARA. 1 and      te       Age hardened Nickel base alloys also need to be tested.
      L. 2.6.3           Table L.5                                                                                   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/           Table L.5        te       The orientation of the test specimens is not defined.
      L. 2.6.3                                                                                                       Add a Footnote to Table L.5 that states:
                                                                                                                     ―Testing in only one orientation is required for
                                                                                                                     acceptance.
US    Annex L/           PARA. 1          te       The 5th sentence does not make sense. Components                  Delete the 5th sentence.
                                                   have many surfaces.
      L.2.6.3                                                                                                        Alternately, utilize industry standard designations
                                                                                                                     to specify the orientation of the impact specimens.
US    Annex L/           Table L.5        ed       The table references ―carbon steels‖, but does not                Revise rows 2 and 3 to read:
                                                   reference ―low alloy steels‖.
      L.2.6.3                                                                                                        ―Carbon and low alloy steels …..‖.
US    Annex L/           Title            ed       The title says ―Micrographic examination‖, but the                Revise to read:
                                                   requirement is for a ―Microstructure Examination‖
      L.2.6.5                                                                                                        ―Microstructure examination‖
US    Annex L/           PARA. 2          ed       The requirement is for a microstructure examination, and          Revise to read:
                                                   this term is used in paragraph 1.
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 14 of 29
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 1             2                 (3)           4                                  5                                                              (6)                                   (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                  Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                               on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

      L.2.6.5                                                                                                        ―Microstructure evaluation‖
US    Annex L/           Title            ed       The grammar is not very good.                                     Revise to read:
      L.2.6.6                                                                                                        ―25Cr duplex stainless steel, Type 6Mo stainless
                                                                                                                     steel and other highly alloyed austenitic stainless
                                                                                                                     steels
US    Annex L/           PARA. 1          ed       The grammar is not very good.                                     Revise to read:
      L.2.6.6                                                                                                        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/           Title            ed       The grammar is not very good.                                     Revise to read:
      L.2.6.6.2                                                                                                      ―22Cr duplex stainless steel (Optional)‖
US    Annex L/           PARA. 1          ed       The grammar is not very good.                                     Revise to read:
      L.2.6.6.2                                                                                                      ―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/           PARA. 1          te       Non-machined surfaces may not always be ―cleaned‖. For            Suggest rewording 3rd sentence, 1st paragraph, to
                                                   example, they may be grit blasted.
      L2.7.3             3rd sentence                                                                                ―Non-machined surfaces shall be appropriately
                                                                                                                     prepared before testing‖.
US    Annex L/           PARA. 2          te       The undefined term ―quality heat treatment‖ is used               Revise to read:
                                                   again.
      L.4.3.1                                                                                                        ―….does not require re-heat treatment, provided
                                                                                                                     the process….‖
US    Annex L/           PARA. 1          ed       An undefined acronym, ―MPS‖, is used in this paragraph.           Revise to read:
      L.4.3.2                                                                                                        Manufacturing Procedure Specification (MPS).
US    Annex L/           PARA. 1          ed       The grammar is not very good, and does not represent              Revise to read:

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 15 of 29
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 1             2              (3)              4                                  5                                                              (6)                                  (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                 Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                              on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

      L.5.2                                        commercial practice.                                              ―Welding procedures for corrosion resistant weld
                                                                                                                     overlay shall be qualified in accordance with
                                                                                                                     ASME Section lX or ISO 10423, PSL3.‖
US    Annex L/           PARA. 2          ed/te    The grammar is not very good.                                     Revise to read:
      L.5.2                                                                                                          ―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/                            te       Weld buttering and butt welding to buttered weld preps            Add the following requirement to this section:
                                                   may contribute to field problems if not done properly. The
      L.5.3                                        existing text does not provide sufficient guidelines to           ―Weld buttering and butt welding to buttered weld
                                                   avoid some of the know problems.                                  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/           PARA. 1,         te       Titanium does not belong.                                         Delete ― and Titanium‖
      L6.1.1             1st sentence
US    Annex L/           3                ed       The wording in this paragraph is different from the widely        Revise to read as follows:
                                                   accepted wording in ASME Section lX regarding the
      L.6.1.1                                      manufacturer or contractors use of WPS’s.                         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/           6th bullet       Te       This bullet needs to be revised to use standard industry          Revise to read:
      L6.1.4.2                                     terms for carbon equivalents.


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 16 of 29
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 1           2                (3)            4                                    5                                                              (6)                                   (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                  Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                               on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                                                                                     ―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/           7th bullet                This bullet and the two equations need to be revised to           Revise to read:
      L6.1.4.2                                     use standard industry terms for carbon equivalents and
                                                   standard industry equations for carbon equivalents.               ―For carbon steels for sour service: an increase in
                                                                                                                     carbon equivalent, CE(Pcm) or CE(IIW), of more
                                                   The proposed wording in the column to the right comes             than 0.02 for CE(Pcm) and 0.03 for the CE(IIW).
                                                   directly from API Specification 5L, Section 6.1.3.1.
                                                                                                                     a. When the carbon content is less than or equal
                                                   The benefit of standards is that they do just that, they          to 0.12%, the carbon equivalent shall be
                                                   standardize requirements. The current wording in the              calculated using the following formula for CE(Pcm)
                                                   ballot does not help the standardization effort by adding a       [see Note 1]:
                                                   new equation for Pcm, when there is a widely used
                                                   existing equation for Pcm.                                        CE(Pcm)=C+Si/30+Mn/20+Cu/20+Ni/60+Cr/20+M
                                                                                                                     o/15+V/10+5B
                                                   Additionally, it is not helpful to take the existing equation
                                                   for CE(IIW) that is correctly written, and re-name it as          If the heat analysis indicates a boron content less
                                                   ―Pce‖                                                             than 0.001%, then the product analysis need not
                                                                                                                     include boron, and the boron content can be
                                                   Let’s contribute to the standardization of specifications for     considered as zero for the CE(Pcm) calculation.
                                                   the oil 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.




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 17 of 29
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 1             2              (3)              4                                  5                                                              (6)                                    (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                   Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                                on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                                                                                     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              Revise to read:
                                                   joint.
      L6.1.8                                                                                                         ―The interpass temperature shall be measured
                                                                                                                     adjacent to the weld bevel. The minimum…‖


US    Annex L/           PARA. 1.         te       The oxygen limit proposed in the draft spec does not              Revise to read:
                         3rd sentence              represent common commercial practices used to
      L6.1.9
                                                   successfully stainless steels and nickel alloys, and would        ―The oxygen content of the backing gas shall be
                                                                                                                     controlled to be less than 5000 ppm.‖
                                                   put an unnecessary burden on the industry.


US    Annex L/           PARA. 4          te       The requirement for the PWHT temperature to be lower              There are two options.
                                                   than the original temperature is not acceptable for high
      L.6.1.13                                     strength quench and temper steels that must meet ISO              (1) Delete this paragraph.
                                                   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
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 18 of 29
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 1             2              (3)              4                                  5                                                              (6)                                  (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                 Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                              on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                                                                                     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            Change ―t‖ to ―T‖ in column 1 and 2;
                                                   identified as the thickness of the block to distinguish it
      L7.1.4
                                                   from the thickness of material to be examined t.                  Add footnote ―t is the thickness of the calibration
                                                                                                                     test block 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     ed       Spelling ―normalized‖                                             Change to ―normalised‖ consistent with rest of
                         3                                                                                           document
US    L.2.4              Para 2,          te       For Sour service, I find it odd that S<0,025% is allowed          S<0,015% consistent with Subclause L.6.1.7.3
                         Table                     when welding consumables for certain materials require            and L.6.1.7.7
                                                   S<0,015%
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...                add MPS to abbreviated terms list
                                                   MPS is not defined in abbreviation 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

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 19 of 29
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 1             2              (3)              4                                  5                                                              (6)                                  (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                 Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                              on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

US    L.5.1              Para 3, Line     ed       LP is defined in abbreviations, but I think SNT-TC-1A             Use ―PT‖ vs. ―LP‖ for consistent terminology
                         1                         uses PT for penetrant exam
US    L.5.3              NOTE             ed       requirements are stated in the NOTE which is informative          Move requirements in NOTE to paragraph text.
                         following                 by definition
                         Para 1
US    L.6.1.12           Para 2, Line     ed       Reference to ―table 1‖ is not clear                               Table L.1?
                         2
US    L.7.1.2            Line 4           ed       Reference to ASNT TC 1A is not strictly correct                   Change to ASNT Recommended Practice SNT-
                                                   designation                                                       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    3.1.14             Line 2           ed       No period at end of sentence                                      Add period consistent with rest of document
US    3.1.17             Line 3           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
                                                                                                                     requirements.
US    6.1                bullet 2         ed       "shall be considered" at end of bullet statement is               remove "shall be considered"
                                                   redundant to lead in statement
US    6.1                bullet 3         ed       "shall be taken into account" at end of bullet statement is       remove "shall be taken into account"
                                                   redundant to lead in statement
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          Move Table 1 to an informative annex.
                                                   an informative list of materials that may be used in

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 20 of 29
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 1            2                (3)             4                                    5                                                            (6)                                  (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                 Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                              on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                   corrosive service.
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,         ed       Footnotes a and b show 0.014%                                     Should be 0,014% for consistent metric
                         footnotes                                                                                   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              change to "may be corrosive"
                                                   all such chemicals now and in the future
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         change to "it is recommended to apply a corrosion
                                                   allowance"... does not state a requirement or a real              allowance"
                                                   recommendation
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         add methodologies for evaluating mass fraction
                                                   achieve                                                           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,         ed       ―Note Such…‖ - lacks punctuation and lacks heading                Should be ―Note: Such…‖ and should have
                         note 3 and 4                                                                                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          Improve reference to other section of document.
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 **)
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NOTE     Columns 1, 2, 4, 5 are compulsory.
                                                                                                                                                                                            page 21 of 29
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 1             2              (3)              4                                  5                                                              (6)                                   (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                  Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                               on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                   unclear
US    6.4.1              Table 3,         ed       Source of ―6.3.2.2‖ reference is unclear                          ? There is no Subclause by that number in this
                         footnote b                                                                                  document
US    6.4.1              Table 3,         ed       ―60oC‖ is not correct                                             Should be ―60ºC‖
                         footnote g
US    6.4.3              Para 1, Line     ed       ―...given to ensuring adequate…‖ grammar error                    Should be ―…given to ensure adequate…‖
                         6
US    6.4.4              para 3           ed       reference to NORSOK M-710 is vague as to whether or               change wording to reflect correct reference as:
                                                   not it is normative or informative
                                                                                                                     shall be provided according to NORSOK M-710
US    6.5.1              para 1           ed       Design limitations... as stated are really material property      change first sentence to read:
                                                   limitations and the list following is re-stated in the bullets
                                                   below                                                             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,         ed       ―HRC = 43.796*In (HB) – 220.86‖ meaning is unclear                Does this mean ―multiply the Brinell hardness
                         footnote b                                                                                  number by 43.796‖? Need a clearer expression
                                                                                                                     for ―In‖.
US    6.5.1              Table 5 row      ed       The table is supposed to be values but notes are included         Move "values" for rows 3 and 4 to notes in the
                         3 and 4                   instead.                                                          bottom of the table.
US    6.5.1              Table 5,         ed       Requirements stated as footnotes to the table.                    Move this requirement to the paragraph text above
                         footnote 1
      Cover                                        See highlighted changes.                                          immergés
      3.1.14                                       See highlighted changes.                                          3.1.14
                                                                                                                     corrosion-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


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 **)
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NOTE     Columns 1, 2, 4, 5 are compulsory.
                                                                                                                                                                                             page 22 of 29
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 1             2              (3)            4                                    5                                                              (6)                                   (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                  Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                               on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                                                                                     NOTE       This term refers to corrosion resistant
                                                                                                                     alloys and not cracking resistant alloys as
                                                                                                                     mentioned in ISO 15156
      3.1.15                                       New definition                                                    3.1.15
                                                                                                                     corrosion-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
                                                                                                                     the project. It should provide
                                                                                                                     The 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;




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 23 of 29
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 1            2               (3)            4                                    5                                                              (6)                                  (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                 Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                              on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

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


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 24 of 29
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 1            2               (3)            4                                    5                                                              (6)                                  (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                 Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                              on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                                                                                     less than 25mm (1,0 in.)
      6.3.5                                        See highlighted changes.                                          phase should be provided
                                                                                                                     systems should be selected
                                                                                                                     per 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
                                                                                                                                                            o
                                                                                                                     needed. For temperatures between 50 C and
                                                                                                                         o       °        °
                                                                                                                     100 C (122 F to 212 F), 2 coats immersion grade
                                                                                                                     epoxy phenolic each 125µm, may be considered
                                                                                                                     as adequate.
      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

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 25 of 29
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 1            2               (3)            4                                    5                                                              (6)                                   (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                  Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                               on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                                                                                     Thermoplastic elastomer, high strength
                                                                                                                     g        AISI 316L instrument lines are suitable
                                                                                                                     for subsea applications provided that they are
                                                                                                                     protected by cathodic protection and the
                                                                                                                                                o
                                                                                                                     temperature is less than 60 C (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
                                                                                                                                                 o        o
                                                                                                                     higher temperature (>20 C, >68 F) seawater
      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)

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 26 of 29
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 1            2               (3)            4                                    5                                                              (6)                                  (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                 Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                              on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2



                                                                                                                     not exceed 350 HV10 (35 HRC) (330 HB).
                                                                                                                     should be given
                                                                                                                     cold deformed up to 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 are
                                                                                                                     coated or isolated from the CP system.
                                                                                                                     Footnote 3) relevant part of ISO 13628,
      Table 5                                      See highlighted changes.                                          b
                                                                                                                     sensitivity to hydrogen

      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                                        Both places specified stainless steel and nickel alloy with
                                                   PRE>40 are regarded as resistant to corrosion when
      Table 3                                      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

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                                                                                                                                                                                            page 27 of 29
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 1            2               (3)            4                                    5                                                              (6)                                  (7)

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                 Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                              on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

                                                   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
                                                   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.



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 28 of 29
ISO electronic balloting commenting template/version 2001-10
Template for comments and secretariat observations                                                                   Date: 2007-02-07                  Document: ISO/TC67/SC4/WG6/13628-1 A1&A2


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

MB1    Clause No./        Paragraph/      Type             Comment (justification for change) by the MB                           Proposed change by the MB                 Secretariat observations
      Subclause No./     Figure/Table/     of                                                                                                                              on each comment submitted
         Annex               Note         com-
        (e.g. 3.1)       (e.g. Table 1)   ment2

      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
                                                   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
                                                                                              rd
                                                   not refer to words similar to that in the 3 paragraph of
                                                   L.2.6.5 ―…acceptance should be based on corrosion
                                                   testing or impact testing.‖—as an alternative.




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