2 Type of Comment: Ge = General Te = Technical Ed = Editorial s2

Template for Comments and Secretariat Observations Ballot ID: 697 Date: May 29, 2018 Document:

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

MB1 Clause No./ Paragraph/ Type of Comment (justification for change) by the MB Proposed change by the MB Secretariat observations Subclause No./ Figure/Table/Note comment2 on each comment submitted Annex (e.g. Table 1) (e.g. 3.1)

US Technical This is a test, after getting knocked off twice US 1.2 Editorial Define "independent competent body". US 1.2, last par Other Active rigs which fall out of class would rarely pass before note 19902. Does this apply to jack-ups that have retired to become museums or casinos? US 10.2, 3rd Technical Vibration acceptability not a criterion for site delete "and vibration" bullet assessment. US 10.3, 2nd Editorial Clarification "Stochastic...extreme value of bulet response from multiple actions." US 10.4.4 NOTE Technical The most obvious case is not mentioned. Add at the end: "..., as well as the largest waves." US 10.5.1, 2nd Technical We think it but don't say it. "...stochastic DYNAMIC analysis..." para US 10.5.3 Technical Nonlinear time domain is not presented as the only Add at the end of the 1st para: "If option. Frequency domain is notorious for frequency domain is used, it should understating drag forces in wave crests. be verified that the level of applied wave forces is comparable to time domain or deterministic methods." US 10.5.4 Technical clarification (P-delta effects included in analysis) "The leg moment due to INITIAL leg inclination OR OFFSET shall be..." US 10.5.5 Technical Overturning and sliding are two different failure modes. Reword: "-- Overturning and sliding Hambly's failure mode involves the interaction of stability; and" sliding and overstressing of the downwave legs. US 10.5.5, next to Technical This is out of place, a duplication, or its bullet list is delete last para missing. US 10.6 Technical Define what is "an appropriate program of inspection". US 10.7 Technical Same earthquake loads, analysis, and reponse required for L1, L2, and L3 exposure levels? US 10.7, 1st para Technical Clarify 3rd sentence. Some damage to ancillary For this ALE, the simplest check is

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 10 ISO electronic balloting commenting template/version 2001-10 Template for Comments and Secretariat Observations Ballot ID: 697 Date: May 29, 2018 Document:

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

equipment should be expected in the 1000-yr quake. that the primary structure should Safety factors used for the 50-yr wave are no longer satisfy ULS checks with resistance appropriate. factors set to unity. US 10.8 Technical "Stakeholders" not defined. US 11.1 Technical Not clear whether to use this document or ISO 19902 for jack-up (or jack-up like) structure that is used as a permanent production facility. US 12.1.6, 3rd Technical Beam-column capacity checking equations typically cross reference should be (12.4) bullet include node-to-node euler amplification. US 12.5.1, 1st Technical Beam shear so rarely governs in tubular bracing "... subjected to beam shear and para members that it is rarely checked. Tubular chords torsional shear shall also be checked stiffened by rack plates should be treated as prismatic where appropriate." members. US 12.5.1, 2nd Technical Consider when hydrostatic pressure is possible. "... checked for SEALED tubular para sections." US 12.6 Technical Editor's yellow concern "...BEAM shear and torsional shear..." US 13.2 Technical Text states that "The structural and foundation resistance factors are found in Section 12 and 9 respectively." Do not see these. These factors need to be in normative text and not in informative appendix. US 13.2 Technical clarification "factored load SET" not just factored load, in 1st equation and following sentence ------F-sub-d should be a summation of A times gamma values in 2nd equation. US 13.6 Technical This section is not definitive enough. Phrases like "whenever reasonably practicable" and "is considered adequate in many areas of the world" give this section no teeth. Instead define minimum acceptable requirements. US 13.8 Technical What is basis for change in overturning factor 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 10 ISO electronic balloting commenting template/version 2001-10 Template for Comments and Secretariat Observations Ballot ID: 697 Date: May 29, 2018 Document:

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

resistance factor of 0.95 in SNAME to 1.0 in this document? US 13.8, 1st Technical Load factors greater than unity should not be used in Unless I am missing something, bullet calculating the stabilizing moments. The text does not change "factored" to "unfactored." indicate factors less than unity. US 13.9.1 Technical What about interaction between vertical and sliding capacity? US 13.9.3 Editorial Delete clause 13.9.3 as it is redundant with clause 9.4.1. US 3.14 structure Technical purpose defined too narrowly "...provide ssome measure of RESISTANCE AND SUPPORT" US 3.x Editorial consequence category - Change "and" to "or" between words "environmental" and "economic" US 3.x Technical definition needed analysis performed with fixed deterministic assessment values of the loading analysis variables incolved, rather than their probabilistic (e.g. spectral) representation US 3.x Technical expand definition "...when subjected to loading and foundation incremental deformation" stability US 3.x long term Technical also need definition for "limited duration deployment" limited duration deployment: operation as used in 6.4 operation for a period less than one year which avoids seasonal severe loading conditions US 3.x nominal Technical nominal stress and strength are being confused --nominal stress: stress calculated for strength ... (use rest of existing definition)

------nominal strength: strength of a member defined in terms of

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

nominal stress or other appropriate limit state US 3.x Technical Don't invite the overzealous to get all excited about "... maximum NOMINAL stress in..." representative stress concentrations. yield strength US 3.x reserve Technical what baseline? strength ratio US 3.x spudcan Technical <> structure at the base of a leg footing providing support via bearing pressure, skin friction, and displacement US 3.x stochastic Technical <> Where was Vugts? analysis in which the spectral analysis response is determined from the spectral input, by applying a transfer function and integrating over all relevant frequencies and wave directions. US 3.x structural Technical two "locals" are confusing "...STRESS analysis of a structural analysis component,local analysis of a section..." US 3.x undrained Technical a definition should add knowledge "...for soil IN WHICH THE PORE shear strength VOLUME IS HELD CONSTANT." US 3.x action Technical "assembly" is confusing use "set" US 3.x air gap Technical so what happens to historical usage? add to note: "... which is herein called hull elevation." US 3.xx intrinsic Technical clarify "...with respect to the water through wave which the wave propagates, i.e....." frequency US 3.xx member Technical incomplete example e.g. leg of a non-truss jack-up; brace (web) or chord of a trussed lef.

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

US 3.xx most Technical revise definition value of a variable with the highest probable probability of being the maximum maximum over a defined period of time (e.g. X hours) US 3.xx sliding Technical This focus only on friction is confusing. Is lateral add NOTE Lateral resistance due to resistance resistance due to skirt or spudcan embedment to be embedment of skirts or spudcan may ignored? Or is this to be accounted for separately? be considered in addition to friction at the interface of the base footing and soil. US 3.xx Technical tighten up "...with A DEFINED averaging sustained duration..." wind speed US 3.xx mean Technical Harmonic components do not substantially change the change "ideally 19 years" to "at least sea level mean. Seasonal variations may be more important. one year" US 3.xx scour Technical steady state minor bed load transport is not the big change "transport" to "removal" concern US 3.xx spectrum Technical Waves can have either vector (directional) of scalar "measure of the amount of WAVE representation. Responses are typically scalar. energy... (rest the same). Alternatively, the energy per unit frequency in a signal or response measured at a point. US 3.xx spectrum Technical Note 3 see foregoing comment. NOTE 4 new NOTE 3 Add sentence at end: "For NOTES suggestion action effects the area under the spectrum is a measure of the mean square or the response at a point. ------NOTE 4 Caution is advised to observe the difference between spectra defined in terms of radian frequency and those defined in terms of hertz. US 5.2 Technical Will Annex A and B methods give same reliability? Not possible to vote affirmative on this document without reviewing these annex and better understanding what 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 10 ISO electronic balloting commenting template/version 2001-10 Template for Comments and Secretariat Observations Ballot ID: 697 Date: May 29, 2018 Document:

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

minimum reliability is provided by following these annex in assessments. US 5.3 a) NOTE Technical Why must ULS be evaluated for operating configuration, if configuration can be changed? US 5.4 Technical Mention assessment of spud can interaction with any previous spud can hole as something that could need to be considered. US 5.4.1 Technical "airgaps" is old usage use "hull elevation" US 5.4.1 NOTE Technical E-mail that gets buried in the paperwork doesn't cut it. ADD at the end of note: "..., and practiced in a drill or mock drill for each supervisory tour of duty." US 5.4.7 Technical Some guidance on when these assessments (pile interaction and relative motion)are necessary would be useful - perhaps this will be covered in informative section. US 5.4.8 Technical misses the concept "...a HIGH INTER-GUIDE SHEAR NEEDED TO REACT THE bending moment acting..." US 5.4.8 Technical Now I am REALLY confused. RPD is not defined. Excessive whatever-it-is should not confirm the validity of a previous assessment, but requires re-confirmation or a new assessment. US 5.5.2 and Technical Need to discuss how "sudden hurricane" events are to 5.5.4 be handled. US 5.5.2 c) 2) Editorial add at the end ...for the period of the planned visit. US 5.5.3 and Technical Operator shall take the lead in setting consequence 5.5.4 category and exposure level. Owner of jack-up does not have info to make this decision. US 5.5.3 2nd Technical <<...community...would suffer>> Prolonged economic "...damage to the environment AND

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

bullet NOTE disruption due to infrastructure damage after hurricane TO THE COMMUNITY. The..." Ivan was a BIG deal. US 5.5.3 a) 2) 1st Technical See foregoing comment, "... significant ECONOMIC bullet DISRUPTION OR inintended release..." US 5.5.3 b) 1) Technical This does not address potential "gushers" from wells "...prevent such flow IN THE EVENT being drilled. Does a cement plug qualify for C2? OF RISER/CONDUCTOR FAILURE, Consider how this operation affects evacuation lead and such means..." time. US 5.5.3.b.1 and Editorial Reword to eliminate words "all wells that could flow on 5.5.3.c.1 their own" as this is difficult to interpret - what about a well on gas lift for instance? Instead suggest stating that "all producing wells be equipped with operable and tested downhole shut-in device". Need also some advice then about well being drilled - it will have BOP, but foundation or structural failure could damage casings below BOP, leading to flow. US 5.5.3.b.3 and Technical Seabed safety valve must also be at a location that is 5.5.3.c.3 beyond where damage is likely to occur due to structural or foundation failure. US 5.5.4 Technical Table 5.5.1 should be the same as Table 6.6.1 in ISO 19902. US 5.5.4 Technical What is supporting logic for different load factors with 50 year and 100 year criteria? Also, Operator to define which of the two criteria shall be applicable.

Return periods for L2 and L3 are missing. US 6.4 Technical Define what method is to be used to select extreme deterministic wave height from 100-year (or 50 year) seastate. US 6.4, 3rd par Technical So are we giving any relief or not? "...not compromised BEYOND WHAT 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 10 ISO electronic balloting commenting template/version 2001-10 Template for Comments and Secretariat Observations Ballot ID: 697 Date: May 29, 2018 Document:

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

IS INHERENT IN USING A REDUCED RETURN PERIOD." US 6.5 Technical "airgap" is old usage use "hull elevation" US 7.2 d) Technical cover 100-yr joint as well as 50-yr independent Add at the end: "..., or that the 100-yr load effect for each critical direction has been captured." US 7.3, 2nd par Technical appurtenances add area as well as possibly affecting "... of the load ATTRACTING coefficients PROPERTIES for the legs." US 7.4 Technical Add info on whether kinematics factor for wave spreading to be applied, and whether effects of relative velocity are to be considered. US 7.5 Editorial Seems inconsistent to use the word "shall" and then refer to A.6.4.6 which is informative. US 7.6 Editorial Mention derrick hook pull as a functional load. US 7.7 Technical Are we really supposed to double-dip? ADD at the end: "..., if not already included in the analysis." US 7.8 Technical What about pulsing frequency of nonlinear wave crests hitting the legs in sequence? US 8.8.1 Technical What is the basis for different load factors with 50-year and 100-year? US 8.8.1 Technical Should't there be a second loadset with extreme See 19902 for example. operating loads (e.g. max hookload at max cantilever) with gamma-sub-f,Q >1.0 and reduced operating metocean parameters? US 8.8.8 Technical incomplete US 9.2 Technical Self-evident addition, at the end of 1st par. Blind lateral extrapolation in channelized deposits should not be used. US 9.3.1 Technical Suggested addition at the end of 3rd par, enabling Moment/load redistribution is

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

9.3.3 step 3b. permitted if the factored loadset and factored yield surface provide a stable solution. US 9.4.1 Technical What about the option of precisely re-entering old footprints with the same class rig? This should be feasible using ROVs and staged leg lowering, similar to techniques used for joining multi-piece jackets, and more desirable than near miss or partial overlap. US 9.4.5 Technical Substantial loss of soil capacity occurs well before total "...pore pressure...stage where it liquefaction. APPROACHES the initial..." US 9.4.6 Technical You haven't told the worst of it. "Such failures may COINCIDE WITH SEVERE STORM OR EARTHQUAKE LOADING AND be manifested as LARGE LATERAL AND VERTICAL DISPLACEMENTS OF THE SPUD CANS, continued foundation settlements..." US 9.4.7 Technical More to it. "...(e.g. storm driven currents AND SEAFLOOR WAVE KINEMATICS)..." US 9.4.8, 3rd Technical Using the BOP instead of the diverter can actually Delete 1st sentence. Revise 2nd to para cause cratering... "Fishing for crown block" on the read: "The drilling program should be morning report. We should not be telling drillers how designed in consideration of shallow to do their business. gas to mimimize the risk of seabed cratering... (rest the same) US Figure 5.2-1 Technical What "other aspect" of hydrodynamic condition in no clue mystery clause 7.x causes sudden termination of the assessment? US Figure 5.2-1 Technical Leg fixity would change structural analysis model and move reflux arrow up DAF. US general Technical Negative vote indicates that we consider document too incomplete to submit an affirmative vote. Some specific areas of concern included in comments.

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

US General Other CD presents a good high level approach to the Keep on truckin' problem. It shows signs of many consultative iterations already. Gaps needing further work are duly noted by the editors. Logical structure seems okay, but many key numbers are still missing.

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 10 ISO electronic balloting commenting template/version 2001-10