Comments on ISO/CD'f' 19905-1

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Comments on ISO/CD'f' 19905-1

Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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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

KR G The KATS supports the above document without comments. NL ge While there is definite progress compared to a previous draft, this CD ‘F’ still requires substantial further work to enable a full and detailed review of the draft document, editorially as well as regarding technical content. NL ge In line with the guidance for reviewers by the WG and given at the front of the document, the annexes have only been considered at a rather high level for technical intent. Where applicable, comments on clauses in Annex A are given immediately following the same clause in the normative. However, comments are restricted to main issues. Absence of further comments should not be interpreted as agreement with the text as written. NL ge For certain (sub)clauses editorial corrections or see accompanying Word document suggestions for text changes are proposed that are too cumbersome too describe in the format of this Table. These items are collected in a separate WORD document accompanying the Table, using the text in the document with ‘track changes’. The occasions are marked with “see accompanying Word document” in col. 6. UK ge While there is definite progress compared to a previous draft, this CD ‘F’ still requires substantial further work to enable a full and detailed review of the draft document, editorially as well as regarding technical content. UK ge In line with the guidance for reviewers by the WG and given at the front of the document, the annexes have only been considered at a rather high level for technical intent. Where applicable, comments on clauses in Annex A are given immediately following the same clause in the normative. However, comments are restricted to main issues. Absence of further comments should not be interpreted as agreement with the text as written.

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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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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

US1 ge While there is definite progress compared to a previous draft, this CD ‘F’ still requires substantial further work to enable a full and detailed review of the draft document, editorially as well as regarding technical content. US1 ge In line with the guidance for reviewers by the WG and given at the front of the document, the annexes have only been considered at a rather high level for technical intent. Where applicable, comments on clauses in Annex A are given immediately following the same clause in the normative. However, comments are restricted to main issues. Absence of further comments should not be interpreted as agreement with the text as written. US2 Ge Overall the document appears to be way to complex for the practitioners who might be using the document. In places the document is confusing and requires the reader to constantly be referring back to Annex A to understand the abbreviated terms. US2 Ge This whole document needs to have several more iterations by the authors before being asked to be reviewed. I am also not sure that it shouldn’t be broken down into smaller independent documents that deal with specific topics rather than attempting to make it a catch all document that is both cumbersome and bulky and requires a number of disciplines to review. US2 Ge Providing a list of terms and definitions is a good way to allow users to quickly reference a terms or definition. However, may of the equations are given using these abbreviations as well as not providing an illustrations to represent exactly what these terms are referring. It would be most helpful to simplify the equations and to present an illustration especially in section 9.3 Geotechnical Analysis of independent leg foundations

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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

NL throughout te/ed Symbols and references: Use of symbols and references Follow ISO Directives and usage. should be decided and rationalized. Do not let this wait till the end, as a last resort type of activity. Use symbols as far as possible in accordance with ISO recommended symbols. See also comments to Clause 4 and the Bibliography. Same for references. NL throughout te/ed Use of verbal forms in ISO standards: Follow ISO Directives and usage. - “may” should exclusively be used for a permission, not to express a possibility or uncertainty (neither in the normative nor in the informative); needless to say that “might” is even worse; - informative annexes cannot contain requirements, i.e. If in clauses in Annex A certain provisions are “shall” is normally not permitted (an exception is in the really intended to be requirements, the text description of an alternative method which, if chosen, has containing “shall” should be moved to the mandatory procedures associated with it); normative in the main body of the standard. - “is/are to be” is equivalent to “shall”; the latter form is recommended; the former discouraged; - the word “must” is associated with regulatory provisions and should not be used in an ISO standard; NL throughout ed Use of capitals: Capitals are only used at the beginning of Follow ISO Directives and usage. a sentence, for abbreviations and in names (not for terms or special words). Also, when a list is a continuation of the introductory sentence the bullet points do not begin with capitals. NL throughout ed Units: use only ‘abbreviated’ forms to indicate units, e.g. Follow ISO Directives and usage. m, km, h, s, min; do not write the words out in full. NL throughout ed Decimal comma: use decimal commas, not decimal Follow ISO Directives and usage. points. NL throughout te/ed Precision and clarity: in several places formulations lack Review both normative and informative for precision and clarity. improvements. In some instances change proposals are given in this table or in the accompanying Word 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 **) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 3 of 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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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

NL throughout te/ed Phrases: For clarity and consistency ensure that the - use “extreme storm event” consistently to same terms and phrases are used throughout the refer to assessment situations [a defined term] document. - use “mode” consistently to refer to situations Wherever possible, also ensure consistency with terms in which the ju operates [drilling mode, and phrases used in other ISO 19900 standards. elevated mode, etc.] - use “sea floor” instead of “mudline” [mudline is not used in ISO 19901-4, nor in 19901-7, 19902 or 19903] - “seabed surface” is in many places best replaced by “sea floor” [sea floor and seabed are defined in ISO 19901-4 and these terms are used throughout the 19900 series] - “No guidance is offered.” [is the standard phrase used in all ISO 19900 standards] NL throughout te/ed Terminology: We are pleased to see that the term “action” Review and adjust document as applicable for is increasingly adopted. However, there is not yet correctness and consistency in terminology. consistency throughout the document (neither in the normative, nor in the annexes). Common expressions such as “load arrangement”, “load case”, “loadset”, “load path”, “load transfer”, “load carrying”, etc. are maintained. The distinction between “load” and “force” in the 19900 series is that “load” refers to (externally) applied actions, whereas “force” refers to action effects. Reactions are an action effect, hence reaction forces, as are internal forces in a component, in the soil, and also inertial forces due to accelerations from global response. See also comments on e.g. 7.6 and 9.3.

NL throughout ed Spelling: - 50 year, 100 year [without hyphen] As the SC 7 secretariat is the national standards body in the UK, spelling should be UK English. - e.g. [remove comma after e.g.] Further, apply to the greatest extent possible consistent spelling (including use of hyphens, comma’s, etc.) 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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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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

throughout the document, as well as consistent with other - jackhouse [one word?] ISO 19900 standards. - life-safety [with a hyphen] - long-term [with a hyphen] - non-linear [with hyphen] - sea floor [two words] - sea water [two words] - short-term [with a hyphen] - subclause [no hyphen] - s/z for British spelling - two-dimensional, three-dimensional [with a hyphen] NL throughout ed ISO 19905: 19905 consists of 2 parts; referring to 19905- 1 should be done as “this part of International Standard 19905”, or more simply as “this document”; the use of “this standard” is unspecific and not correct.

NL Introduction ed Use ISO FDIS 19902 as a model for paras 1, 2 and 3. see accompanying Word document Bring the introduction generally in line with other standards in the ISO 19900 series. Use”‘standard phrases” as agreed to by ISO CS earlier. Furthermore, see suggestions for some improvements. NL 1 ed Change “this standard” (see earlier comment). see accompanying Word document Use consistent terminology: the document is all about “site-specific assessment”, not about assessment in general. Further suggestions for some improvements.

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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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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

NL 2 te/ed Use ‘boiler plate text’ for introductory sentence(s) and ISO 19900 is agreed and is normative. include only those standards that are called on in the document in a normative manner (other than Clause 3). ISO 19901-1 is agreed and is normative, but is only called up in Annex A; add an appropriate ISO 19901-3, 19901-5 and 19901-6 may be referred to if reference in the body of the document. useful (in on-binding terms) but should not be normative. ISO 19901-2 and 19901-4 should also be normative, but are presently not called up in the document. Appropriate references should be added. ISO 19902 is agreed and is normative, where applicable. NL 3 ed Definitions should not begin with a capital letter, not with One or more of these errors occur in: an article, and not be closed off with a full stop. 3.9 assessment Defined terms within definitions should not be in italics. 3.10 assessment situation 3.12 assessor 3.20 consequence category 3.29 extreme storm event 3.40 independent leg jack-up 3.44 jack-up 3.46 leaning instability 3.52 load arrangement 3.56 load case 3.58 mat-supported jack-up 3.67 operations manual 3.69 permanent load 3.76 regulator 3.89 skirted spudcan

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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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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

NL 3 te/ed We question the excessive number of definitions. Delete: It can be useful to repeat terms that are already defined in 3.2 abnormal wave crest standards named in the introductory sentence(s) of Clause 3, but it is not necessary to do this for all terms 3.6 direct actions [given within 3.5] that also appear in ISO 19905-1. Use repetition more by 3.7 indirect actions [given within 3.5] exception than as a rule. 3.19 component [use “structural component” (see Clause 3 further unnecessarily includes very common and also comment with 3.103), and use well-known terms, as well as terms that do not have other “component” as shorthand in texts where meanings than in the dictionary. We suggest to delete the there is no possibility for confusion or definitions shown in the next column. uncertainty] 3.27 element [in ISO 19902 element is only used in connection with “finite element”; use otherwise “structural component” or “part”; see also 3.19, 3.61 and comment with 3.103] 3.34 geoscience studies [see also 3.42] 3.35 geotechnical investigation 3.37 hard sloping strata 3.39 individual extreme environmental values [Perfectly clear without definition. Is “in the same direction” always the case, without exception? Specific circumstances can best be noted where these occur or are relevant.] 3.41 independent leg foundation [covered by 3.40 and 3.31] 3.42 integrated study [if really considered essential, then link with 3.34 - geoscience studies] 3.47 leg extraction [obvious and unnecessary] 3.48 leg inclination [obvious and unnecessary] 3.51 liquefaction / cyclic mobility

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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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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

3.57 magnetometer survey 3.61 member [see also 3.19, 3.27 and comment with 3.103] 3.66 open water site [obvious and unnecessary] 3.83 sea floor instability [see also comment with 3.83 further down] 3.86 shallow seismic [unnecessary to define a general technique in this document] 3.87 sidescan sonar [unnecessary to define a general technique in this document] 3.92 sliding resistance [obvious and unnecessary] 3.93 solidification effect [see also comment with 3.93 further down] 3.97 squeezing 3.98 spudcan-pile interaction US2 3 Swiss Cheesing should be added as a term to the definitions defining a method to reduce the potential for a punch through by pre-drilling a grid of hole within each spud can area that has the potential for a punch through situation NL 3 introductory ed Modifications proposed. see accompanying Word document sentences NL 3.1 definition ed “Design” is not part of 19905-1 and is therefore best Change to: deleted. We suggest also deleting the word “conventional”. assessment situation in which conditions exceed conventionally specified design or assessment conditions and which is used to mitigate against very remote events NL 3.1 NOTE te The probability of abnormal assessment situations is Bring in line with ISO 19901-1 and 19902. indicated as “10-4 per annum or lower”. This is not

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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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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

consistent with the definitions of “abnormal events/values” in ISO 19901-1 and 19902, where they are given as typically 10-3 to 10-4 per annum, while extreme values are defined as being of the order of 10-2 per annum. (NB: So far only ISO 19903 uses “10-4 per annum or lower”). NL 3.3 ed The definition is modelled after ISO 19902, replacing Add: “design” by “assessment”. Following the practice used in ISO 19901-7 and 19904-1, a NOTE should be added NOTE Adapted from ISO 19902:200x, giving a reference to their basis (the source). definition 3.2. (200x is likely to be 2007) NL 3.4 ed As for 3.2. Add: NOTE Adapted from ISO 19902:200x, definition 3.3. NL 3.4 and 3.5 ed These are out of alphabetical order. Swap sequence of 3.4 and 3.5. NL 3.5 NOTE 2 te/ed Include these observations/discussion in an appropriate Relocate the contents of the NOTE to e.g. Clause place in the regular text of the document (e.g. Clause 7), 7. not in a NOTE with the definition. NL 3.10 te/ed The text is not consistent with definition in ISO 19900. Change to: assessment situation the set of physical conditions representing situations real conditions during a certain time interval for which the assessment assessment is intended to demonstrate that the acceptance criteria of this standard document for relevant limit states are not exceeded NOTE Adapted from ISO 19900:2002, definition 2.13. NL 3.11 ed Add NOTE giving the source. Add: NOTE Adapted from ISO 19902:2002, definition 2.14.

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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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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

NL 3.15 te/ed Use consistent terminology. Change “combined load” to “combined actions”. NL 3.17 te/ed This refers to the notion of a “basic variable”; we Add: recommend to add this term. basic variable one of a specified set of variables representing physical quantities which characterize actions, environmental influences, geometrical quantities, or material properties including soil properties [ISO 19900:2002] NL 3.20 te/ed Delete the article and be specific about failure of what. Change to: Make definition consistent with the definition in ISO 19902 consequence category (see FDIS) by deleting equal sign and changing “and” to a classification system for identifying the “and/or”. environmental, economic and indirect personnel safety consequences of failure of a jack-up

NOTE Categories for environmental and economic consequences are (see 5.3.3): C1 = high environmental and/or economic consequence C2 = medium environmental and/or economic consequence C3 = low environmental and economic consequence

[ISO 19902:200x] NOTE Adapted from ISO 19902:200x, definition 3.11. NL 3.21 te/ed For consistency within the 19900 series of standards we Use (adapted?) definition from ISO 19901-7 or recommend to change to the notion of “recognized 19904-1. classification society”, as defined in ISO 19901-7 and/or 19904-1, if necessary with an adapted definition. NL 3.23 and te/ed The counterpart of “deterministic” is “probabilistic”, while Delete 3.23 and 3.100. 3.100 “stochastic” is not really synonymous with “probabilistic”. Precise definitions of “deterministic” and “stochastic” are

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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

not easy to give, while we think that all engineers in the industry are broadly familiar with their meaning. We suggest that both definitions are best deleted. If 3.100 - stochastic analysis is maintained we propose to NOTE In general, a linear(ized) stochastic add a NOTE as shown in the next column. analysis can be performed in the frequency domain or in the time domain; non-linear stochastic analysis can only be performed by time domain simulations. This document does not support frequency domain stochastic analysis. NL 3.24 NOTE te/ed Consistency of terminology: use “actions” instead of Change to: “loads”. dynamic amplification factor The NOTE differs from ISO 19902; move the source DAF indicator therefore to a position above the NOTE. ratio of a dynamic action effect to the corresponding static action effect

[ISO 19902:200x]

NOTE For a jack-up the dynamic action effect is best simulated by means of a concentrated or distributed inertial loadset. It is usually not appropriate to factor the static environmental loads actions to simulate the effects of dynamic actions.

[ISO 19902:200x] NL 3.25 and 3.26 te/ed Wrong font and use of wrong term. 1) The definitions should be in regular font, not bold. DAFS and DAFR are special forms of DAF in 3.24. Repeating the NOTE is superfluous. 2) replace the last words “mean effect” by “mean value” 3) delete the NOTES NL 3.28 te/ed Make definition identical with ISO 19902. Change to: exposure level classification system used to define the requirements for a structure based on 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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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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 consideration of life- safety and of environmental and economic consequences of failure

[ISO 19902:200x]

NOTE An exposure level 1 (L1) jack-up is the most critical and exposure level 3 (L3) the least. NL 3.33 te/ed Consistency of terminology. Change “subjected to loading” to “subjected to actions” NL 3.36 te/ed Add the NOTE from ISO 19902 Add: NOTE When a global analysis is of a transient situation (e.g. seismic) the inertial response is part of the equilibrium. NL 3.43 te/ed Improved clarity. Change to: intrinsic wave frequency wave frequency of a periodic wave in a reference frame that is stationary with respect to the wave, i.e. with no current present NL 3.44 NOTE ed Seabed contains the bearing strata; sea floor is the Change “sea floor” into “seabed” (2x). interface between the water column and the seabed.

NL 3.45 ed Plural/singular error and consistency of terminology. Change “…. produces the load level …” into “……... produces the load action level ….”. NL 3.46 te/ed Consistency of terminology. Change “ … increase of foundation load …” into “… increase of actions on the foundation load …”. NL 3.49 ed Be more specific. Change to: Make definition consistent with the definition in ISO 19902 life life-safety category (see FDIS) by deleting the equal sign. Correct spelling. classification system for identifying the applicable level of life- safety of personnel on a jack-up:

NOTE 1 Categories for life life-safety are (see 5.5.2): 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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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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 S1 = manned non-evacuated S2 = manned-evacuated S3 = unmanned

NOTE 2 Adapted from ISO 19902:200x, definition 3.27. NL 3.50 NOTE ed Formulation of NOTE. Change to: [After: ISO 19900:2002] NOTE Adapted from ISO 19900:2002, definition 2.21. NL 3.52 reference ed Wrong source Change “[ISO 19900:2002]” into “[ISO 19902:200x]” NL 3.53 te/ed Make consistent with definition in ISO 19902. Change to: load case a compatible set of load arrangementsload arrangements, sets of deformations and imperfections considered simultaneously with permanent actions and fixed variable actions actions for a particular assessment or verification. NOTE Adapted from ISO 19902:200x, definition 3.29. NL 3.63 te/ed The addition “over a defined period of time (e.g. x hours)” Delete “…. over a defined period of time (e.g. X to the definition in ISO 19901-1 is unnecessary. Make the hours)” definition identical to that in ISO 19901-1. NL 3.64 te/ed This definition of “nominal strength” is modelled after the Change to: definition of “nominal stress” in ISO 19902. If considered nominal strength necessary we recommend some changes to the strength calculated for the a cross-sectional area, formulation. allowing fortaking into acccount the stress raising The definition of “nominal stress” should also be included effects of the macro-geometrical shape of the as this term is referred to in 3.101 (SCF); see further component of which the section forms a part, but down. disregarding the local stress raising effects from the section shape and any weldment or other 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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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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 fixing detail

[after ISO 19902:200x] NOTE Adapted from ISO 19902:200x, definition 3.34. NL 3.69 te Permanent action (not load!!) is one of several types of Delete definition. actions, which are all defined in ISO 19900, Clause 6. These apply to all standards of the 19900 series. They are not redefined in any other ISO 19900 standard; do not do this in 19905-1 either. See also 3.107. NL 3.70 te Do not change the definition from the one given in ISO Adopt definition from ISO 19901-1. 19901-1! Move it to a place between current 394 and 3.95. It is alphabetically out of order. NL 3.71 ed Bring in line with 3.15 and change of a preposition. Change to: preloading vertical load test at on a jack-up leg to ensure sufficient foundation bearing capacity under assessment conditions US2 3.71 3.72 Page 2 Rapid Leg Penetration should be added as a term since it is different than a punch through condition NL 3.72 ed Improved clarity. Change to: punch-through rapid uncontrolled vertical leg movement due to soil failure in strong soil overlying weak soil NL 3.73 te/ed Replace entry by the definition in ISO 19902 (see FDIS). Replace by definition in ISO 19902. NL 3.75 te/ed The definition refers to “non-critical components” Add definition of “critical component” from ISO (highlighted in yellow). This hinges on also defining 19902. “critical component”, which is indeed done in ISO 19902. We recommend adding definition of “critical component” (see ISO FDIS 19902, def. 3.12).

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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

NL 3.76 line 2 ed Adopt definition from ISO 19902. Change “…. territorial waters …” into “…territorial waters jurisdiction ……” NL 3.78 te/ed Adopt definition from ISO 19902. Replace (identically) by definition from ISO 19902. NL 3.79 te/ed 1) The word “capacity” is used here in its normal Change to: language (dictionary) sense, which would be fully acceptable. If in doubt or wishing to avoid the word, then measure of the capacitycapability << But Jan has replace it with “capability”. objected to the use of capacity other than for foundations !! >> of a structural system to 2) The added part “with the unfactored assessment withstand overload wrt the unfactored assessment loading” compared to the definition in ISO 19902 is loading << check final version in 19902 and modify inappropriate as the reference level can vary from one if we don't like it >> case to the next; delete this part. NOTE 2 Note 1 is adapted from ISO 19902:200x, definition 3.45. NL 3.81 NOTE & ed A.5.8 is a subclause. Change “Clause A.5.8” to “subclause A.5.8”. source The definition of scatter diagram is exactly the definition Delete the word “After”: [After ISO 19901-1:2005] from ISO 19901-1. NL 3.83 te/ed Inconsistency: the term is “sea floor instability”, whereas Change term from “sea floor instability” to “seabed the definition refers to “instability of the seabed”. The instability”, or delete 3.58 altogether. correct term should be seabed instability. Also, we doubt this definition is necessary.

NL 3.88 NOTE ed line 2: the subscript of the parameter m0 is a zero, not a Change “mo” to “m0” (2x). letter o. line 3: “Clause 3.31” is wrong formulation. Change “Clause 3.31” to “definition 3.31”. NL 3.90 ed Misspelling. Change “jackup” to “jack-up”. NL 3.91 te/ed Use “spudcan”, which is a defined term, instead of Change “footing” to “spudcan”. “footing”. It is our impression that use of the term “footing” has been Review whole document for occurrence of discontinued and was replaced by the term “spudcan”. “footing” and adjust use of the term as necessary. However, “footing” still appears in several places in the text. US2 3.91, 3.92 Page 12 Is this referencing a mat type supported rig? 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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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NL 3.93 te/ed Consistency of terminology. Change “wave forces” to “actions from waves”, or delete 3.93 altogether. Is this definition necessary? The term “shielding” appears in the NOTE. If “solidification” is included, then “shielding” should also be included. In no other standard of the ISO 19900 series these terms are defined. NL 3.101 te/ed The term “nominal stress” appears in the definition. This Add definition of “nominal stress”. term should also be defined; see ISO 19902 definition 3.34. (see also comment on 3.64 - nominal strength) NL 3.102 ed The definition here is identical to the definition in ISO Delete the observation “Check for changes in final 19902. version.” NL 3.103 definition and te/ed A component can consist of parts with a different Change to definition as in ISO 19902: NOTE configuration and/or from a different material (e.g. “physically distinguishable part of a structure” reinforcement such as ring stiffeners, gusset plates) and can still be dealt with as one component. We see no need to go to the level of detail apparently envisaged here by [ISO 19902:200x] deviating from the definition given in ISO 19902. and reformulate or delete the NOTE. We suggest to reconsider the terminology and adjust the whole document in accordance with the adopted term(s). NL 3.104 te Keep the definition the same as in ISO 19901-1. Change to: sustained wind speed time averaged wind speed with a defined averaging duration of 10 min or longer [ISO 19901-1: 2005] NL 3.105 te/ed Accept the definition from ISO 19904-1 as it stands; do Keep definition from ISO 19901-4 unchanged. not ‘improve’ or reword it. NL 3.106 te/ed Are assessments without exception always made at the Change the term “assessment force” in the force level? We suggest to maintain flexibility by keeping definition and in NOTES 3 and 5 to: the formulation as ‘stress’ or ‘force’, as given in ISO 19902. - “assessment stress (force)”. and Utilizations are as a matter of course always dealing with - “assessment resistance in force units” to action effects due to factored actions. The action effects “assessment resistance in stress (force) units”. 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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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can be expressed in stress terms, in force terms or in Correct text in line 2 of NOTE 5 to: something else. “….reduced to an inequality of the form …”

Change source to: “NOTE Adapted from ISO 19902:200x, definition 3.57. NL 3.107 te Variable action (not load!!) is one of several types of Delete definition. actions, which are all defined in ISO 19900, Clause 6. These apply to all standards of the 19900 series. They are not redefined in any other ISO 19900 standard; neither do this in 19905-1. See also 3.69. NL 3.108 te/ed Add all or most of NOTE 2 from ISO 19901-1. Add NOTE 2 from ISO 19901-1, as it is or adjusted. Add source of definition. Add: NOTE 3 Adjusted from ISO 19901-1:2005, definition 3.41. CA 4 Abbreviation ed SNAME Should be added to Abbreviated Terms s Terms US2 4 Page 15 Suggest adding LAT and MLLW as definitions defining water depth references NL 4.1 te/ed - ALS is the accidental limit state (not accidental damage - ALS: delete the word “damage”; limit state); - MOU does not appear in the document (other than in - delete MOU; this list);

- The definitions of DAFS and DAFR are not consistent - Make definitions of DAFS and DAFR consistent; with 3.25 and 3.26, respectively. - ALS and FLS are listed twice. - Remove 2nd entries of ALS and FLS; - use UK spelling in PSIIP - Change “program” to “programme”. 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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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NL 4.1 ed Several abbreviations appearing in the document are Not currently included are: currently not included in 4.1. They should either be added or use of these abbreviations should be avoided. BOP BSTF FE [generally FEA is used, e.g. in 19902] LRFD MHWS [not in ISO 19901-1, suggest to avoid] MLWS [not in ISO 19901-1, suggest to avoid] MPM MPME OCR PDF ROV SDOF WSD NL 4.2 te/ed Use of symbols should be decided and rationalized. Do Ensure that symbols are well defined and not let this wait till the end, as a last resort type of activity. consistently used in normative as well as the annexes. Do not use different symbols per clause. FDIS 19902 can perhaps be used as an example; main symbols used As far as practically possible they should further throughout the document are collected and defined at the correspond with the ISO recommended symbols front; more specific symbols are defined locally where and be collected as per ISO Directives. they are used. US2 4.9 Page 58 m shows 3 different definitions NL 5.1 and 5.2 ed Proposed editorial improvements. see accompanying Word document NL 5.2 Figure 5.2-1 te The figure needs to be updated to include comments provided earlier, as well as any revisions to reflect the latest version of the document.

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In our opinion the figure should stay in the main body (the normative) part of the document. It fits logically in 5.2.

NL 5.3 a) te/ed - suggest reformulation of 1st line for clarity; Change to: - ”metocean actions” is unfortunate phrasing; these are The site-specific assessment shall include normally called “environmental actions” evaluation of the ULS for assessment situations including extreme combinations of metocean environmental actions and laoding configuration (level of variable load actionslevel, ……..”

- NOTES are purely informative and may not contain In benign areas the ULS environment may requirements or recommendations according to ISO beis sometimes within the defined SLS limits Directives. Convert the NOTE to normal text and for the jack-up. In such cases the assessment reformulate slightly to conform. will be should be made for the ULS environment and the proposed operating configurations. This is because the environmental conditions will not exceed the limits for changing to the elevated storm mode. NL 5.3 b), c) and d) te/ed Use plural forms for limit states. Use SLSs, FLSs and ALSs. NL 5.3 d) heading ed Do not deviate from the defined term. Delete the word “damage”: Accidental damage limit states (ALS). NL 5.3 para 1 te/ed Better to remove reference to specific (sub)clauses in Change to: external documents. “Clause 4.1 of ISO 19900 divides …” nd The 2 sentence is confusing; does it contain a nd contradiction? Reformulate the 2 sentence. NL 5.4.1 NOTE te/ed The NOTE is part of the normal text. Convert the NOTE to normal text. Also suggest deleting the word ‘initial’ from line 1. Delete the word “initial”. Further, any deviations will require buy-in from all Ad at the end: “…… communicated to the stakeholders. personnel operating the jack-up and other 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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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stakeholders.” UK 5.4.1 NOTE te/ed Any deviations will require buy-in from all stakeholders After “personnel operating the jack-up” Add text “and other stakeholders” US1 5.4.1 NOTE te/ed Any deviations will require buy-in from all stakeholders After “personnel operating the jack-up” Add text “and other stakeholders” NL 5.4.2 ed The word “clearly” is unnecessary and we propose to Delete “clearly” (twice). delete it. NL 5.4.3 te/ed Use “extreme storm event”, which is a defined term. Change to: Use sharper formulation. 5.4.3 Extreme Storm storm event approach angle The critical extreme storm event approach angles relative to the jack-up are usually different for the various checks that are shall be made (e.g., strength vs. overturning checks). The critical direction for each check shall be used as appropriate.

NL 5.4.4 ed - Consistency: the terminology used is “elevated storm - Change to: “elevated storm conditionmode” mode”. (twice); - Line 3: the word: “therefore” is unnecessary, if not - delete “therefore”. inappropriate, and best deleted. - Consistency of terminology. - Change to: “variable loadactions”. NL 5.4.7 te/ed Use sharper formulation, and at the end identify the items Change to: at risk more clearly. It may beWhere necessary to consider the interaction of the jack-up with any adjacent structures shall be considered. Possible topics Aspects to be included in the site- specific assessment are the effects of the jack-up's spudcans on the foundation of the adjacent structure, and the effects of 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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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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 relative motions between the jack-up and the adjacent structure on the drill-string, well conductor, well conductor guides, etcwell casing, drilling equipment and well surface equipment (risers, connectors, flanges, etc.). UK 5.4.7 te/ed Identify risk more clearly Replace “drill-string, well conductor, well conductor guides, etc.” With “well casings, drilling equipment and well surface equipment (risers, connectors, flanges, etc) “ US1 5.4.7 te/ed Identify risk more clearly Replace “drill-string, well conductor, well conductor guides, etc.” With “well casings, drilling equipment and well surface equipment (risers, connectors, flanges, etc) “ NL 5.4.8 te/ed Improve formulation. Change to: The assessor should be aware that there may be the characteristics of certain designs that can have impacts on the site-specific assessment that are not specifically addressed in this document. In such cases the validity of the initial assessment as made shall be confirmed once the unit has been installed.

For example, high bending moments in the legs can be caused by lateral displacement of the spudcan or by eccentric vertical footing spudcan reaction due to footprints or other seabed features.

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NOTE The RPD may be usually is a good indicator of the degree of eccentricity and the acceptability of these loads action effects when elevated. NL 5.5 ed Proposed editorial changes for conformity with ISO 19902 see accompanying Word document (with adjustments) and consistency of terminology. NL 5.5.2 b), 2nd te This is a requirement. Change “may” to “shall”. sentence NL 5.5.2 c) te Item 1) from the text in ISO 19902 has been left out. We see accompanying Word document see absolutely no reason for this exclusion and want to reinsert it. NL 5.5.3 1st bullet te The consequence category includes risk of loss of life, for see accompanying Word document point and people other than the jack-up’s own complement. The NOTE (adjusted) 1st bullet point expresses this. The NOTE also requires adjustment to suit, and to express that it is not only the operator who sets the consequence category; all stakeholders should agree to this. NL 5.5.3 a) and b) te A release does not relate only to oil, but also to gas. Change “oil” to “hydrocarbons” (several times); see accompanying Word document NL 5.5.3 c), last te This is a requirement. Change “may” to “shall”. sentence UK 5.5.3 NOTE te/ed All stakeholders to agree Replace “Operator will drive” With “all stakeholders will agree” US1 5.5.3 NOTE te/ed All stakeholders to agree Replace “Operator will drive” With “all stakeholders will agree” NL 5.5.4 Table 5.5-1 te The Table categories are in conflict with the basic Change exposure levels in accordance with 1st premise formulated in the 2nd sentence of para 1. This paragraph of this subclause. principle applies to all structures under the ISO 19900 series (see ISO 19902, 19903, 1904-1). It also applies to jack-ups. NL 5.5.4 text te The partial action and resistance factors, and associated 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 22 of 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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underneath assessment criteria are not yet provided and must be table reviewed when finalized. NO 5.5.4 te In order to be consistent with other ISO standards "If 100 joint probability data does not exist, a for offshore structures we would have preferred a combination of 100 year waves, 100 year 100 year reference level instead of 50 years. If not wind and 10 year current can be applied." revised, an alternative will be to include the 100 year value formulation in a regional annex. We realise that there is a resolution on this in a SC 7 meeting. However, in order to obtain the same reference values in all ISO standards we would recommend also the same here to be consistent. Thus, in principle for Chapter 6.4 the text related to 50 year should be removed. Comment applies also to 6.4, 8.8.1, A.6.4.2.3 and A.7.3.1.1 NL 6 ed Proposed editorial improvements. Several of these see accompanying Word document proposals were given earlier. NL 6.3 te This subclause assumes jack-up placement at an open See accompanying Word document for water location, which then allows hull elevation to be set improvements to the existing text. to achieve adequate air gap. However, it should also address interactions with a platform when placed Add text to describe interface data with the alongside. Add text describing platform interface platform (structure and topsides, risers, pipelines, challenges, such as ability to reach slot positions and umbilicals, slot positions, well surface equipment, clearance between cantilever and weather deck for well etc.), with particular reference to implications for equipment stack. the required cantilever positions and proximity of the jack-up to the adjacent infrastructure. UK 6.3 te/ed This section assumes an open location which then allows Interface data are required (substructure, topsides, jack-up to set hull elevation to achieve air gap. Brief text risers, pipelines, umbilicals, slot position, well describing platform interface challenge (e.g. slot location, surface equipment, etc) with particular reference or cantilever to clear weather deck by x metres to achieve to required cantilever positions and proximity of well equipment stack) is required. jack-up to adjacent infrastructure. US1 6.3 te/ed This section assumes an open location which then allows Interface data are required (substructure, topsides, jack-up to set hull elevation to achieve air gap. Brief text risers, pipelines, umbilicals, slot position, well describing platform interface challenge (e.g. slot location, surface equipment, etc) with particular reference

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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

or cantilever to clear weather deck by x metres to achieve to required cantilever positions and proximity of well equipment stack) is required. jack-up to adjacent infrastructure. NO 6.4 te In order to be consistent with other ISO standards "If 100 joint probability data does not exist, a for offshore structures we would have preferred a combination of 100 year waves, 100 year 100 year reference level instead of 50 years. If not wind and 10 year current can be applied." revised, an alternative will be to include the 100 year value formulation in a regional annex. We realise that there is a resolution on this in a SC 7 meeting. However, in order to obtain the same reference values in all ISO standards we would recommend also the same here to be consistent. Thus, in principle for Chapter 6.4 the text related to 50 year should be removed. Comment applies also to 5.5.4, 6,4, 8.8.1, A.6.4.2.3 and A.7.3.1.1 NL 6.4 te/ed Make sure that the ‘shopping list’ to be added includes wave crest elevation as a key parameter. UK 6.4 te/ed Wave crest elevation is a key parameter for matching a Include in the “shopping list” jack-up to a proposed location ”wave crest elevation” US1 6.4 te/ed Wave crest elevation is a key parameter for matching a Include in the “shopping list” jack-up to a proposed location ”wave crest elevation” US2 6.5 Page 24 Caution might be stated here in proposing taking soil borings from a JU rig before preloading especially in areas where crusts might have occurred as well as where paleo channels may exist. Prior geohazards survey should be a prerequisite before making this call. US2 6.5 Page 24 Modifications may be required to the rig in order to take soil borings prior to skidding out. NL 6.5 para 4, line 2 te/ed Is “are recommended” strong enough? Suggest change to “should be carried out”. NO 6.5 1st section te The text should be more precise and we propose: "Soil investigation for jack-up structures shall 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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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be carried out when: - Soil conditions are not known - Soil seismics show or one may expect a pronounced stratification of the soil - No soil investigations have been carried out in the vicinity that can be linked up with the soil seismics - There is a possibility for dangerous soil conditions, e.g. uncontrolled subsidence due to erosion or weak underlying layers. NO 6.5 te Soil investigation after installation can be very hazardous in the North Sea at the winter season, and should not be a part of a good practice. NL 7 ed Proposed editorial improvements. see accompanying Word document NL 7.2 b) 1) ed Consistency. Change “Permanent loads” to “Permanent actions”. NL 7.2 c) 2) te/ed The indirect actions resulting from dynamic response are Change “Dynamic effects” to “Accelerations from accelerations; see also 7.6 dynamic response.” NL 7.2 and other a) te/ed “metocean actions” is unfortunate phrasing; these actions Change consistently to “environmental actions”. locations, are usually called “environmental actions”. Alternatively, also in Annex one could use something like “actions due to metocean A conditions” if the specific source of the actions needs to be emphasized. However, in our opinion this is not necessary and we prefer the former solution. See also comment on 5.3 a). NL 7.3.1.1 a), 2nd para te The environmental actions in a joint probability model are Remove the part within brackets: “(typically this due to the 100 year wave with an associated current on wind speed may be taken conservatively [?!] as the under water part of the jack-up plus the 100 year wind the 1 hour mean 100 year return period individual action on the above water part of the jack-up. For the extreme wind)” and give clear guidance on what wind action the use of 100 year 1 hour mean wind is not extreme wind speed should be used. acceptable.

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NL 7.3.4 1st sentence ed The 1st sentence is incomplete; it is just a fragment. Change to: Wind actions shall be computed using wind velocity, wind profile and exposed areas. NL 7.6 ed Dynamic response results in accelerations and inertial Change “Indirect actions” to “Inertial forces”. effects; these are all ‘action effects’. The accelerations are the indirect actions (see 3.5); we propose using “inertial forces” (not ‘actions’, which are externally applied (see 3.5) but ‘forces’ as they are an action effect). See also comment at the beginning (before comment on the introduction). NL 7.7 te/ed Include reference to 8.8.8, in addition to 10.7. Change to “… appropriate, see 8.8.8 and 10.7.” NL 8 ed Proposed editorial improvements. see accompanying Word document NO 8.6.1 te If there is "insufficient data available"; the spud should not be used. NO 8.6.3 te Pinned supports is not conservative for all parts of the leg and spud can. NL 8.8.1 te If all partial action factors are included in the normative Replace factors with a cross-reference to Annex B. Annex B they should not be duplicated here. See comment on Annex B for the values of certain factors. NO 8.8.1 te In order to be consistent with other ISO standards "If 100 joint probability data does not exist, a for offshore structures we would have preferred a combination of 100 year waves, 100 year 100 year reference level instead of 50 years. If not wind and 10 year current can be applied." revised, an alternative will be to include the 100 year value formulation in a regional annex. We realise that there is a resolution on this in a SC 7 meeting. However, in order to obtain the same reference values in all ISO standards we would recommend also the same here to be consistent. Thus, in principle for Chapter 6.4 the text related to 50 year should be removed. Comment applies also 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 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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to 5.5.4, 6,4, 8.8.1, A.6.4.2.3 and A.7.3.1.1 NO 8.8.1 In principle there should be two load combinations. One combination as included, giving an additional safety on the environmental actions and one giving additional giving extra safety on the variable and permanent loads, as done in DNV-OS-C104. If not included, the reason for this should be explained by text such that it can be assured that sufficient safety is achieved for all load combinations. NL 8.8.2 title te/ed Maintain terminology and classification of actions from Change to: ISO 19900, which applies to all offshore structures. 8.8.2 Permanent actions and variable loadsactions See further accompanying Word document. NL 8.8.5 te/ed Inertial effects are action responses, hence “forces” see accompanying Word document instead of “actions”; see 7.6 above. [Apologies if comments/modifications to an earlier draft in 2005 have in some cases caused possible confusion.] NL 8.8.8 te/ed Rephrase as shown in column 6. Change to: Earthquake actions shall include global accelerations hull actions associated with due to fundamental modes of vibration in addition to local actions from soil movement on the spudcans and the legs where relevant. , the spudcans and significant drilling facilities.The associated inertial forces on all significant masses shall be taken into account. NL 9 ed Proposed editorial improvements. see accompanying Word document for whole Clause 9. CA 9 and A9 ge, te The document, including the Annex, is in some cases The following path forward is recommended: incomplete in respective of the foundations. There are (Foundations 1) Proceed with the Normative, maybe 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 27 of 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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) inserts such as: editing somewhat so that it is a performance standard that everyone can “Add brief précis of the informative with some shalls..” agree to. (p34) 2) Carry out studies to show how the “reduction for backfill – to be addressed by Templeton” proposed foundation recommendations (p35) compare with existing codes and practice “Randolph to check …..and decide path forward..” (p 112) in different parts of the world, including the latest R&D (centrifuge tests, “GVDZ and ETRD to discuss and recommend….”(p 118) numerical, analytical, etc.) (This may be “Suggest R Dean and R Overy tackle this” (p120) called “calibration studies”, but it could be more than that) “Guy is uneasy about f1 and f2” (p 122) 3) Revisit Annex / Information when a “We use the same for sand & clay – should we? (p 125) consensus amongst the working group has been achieved. “Guy is uneasy about f1 and f2” (p 125) “Text required to address plasticity approach” (p 126) “Reword this para; more to follow…… (p 129) “Bearing and sliding equations to be inserted” (p 130)

The overall appearance is that this is still a “work in progress”. While it is admirable to obtain the most advanced R&D analysis and experimental data, a Standard is of necessity a consensus document that reflects both regulatory, practice and academic views. It is not clear that such a consensus exists. It is also not clear what work has been done to ensure that the recommendations included in the draft compare reasonably with current practice and experience (although we do not want prevent technical advances, we should at least be aware of what the differences are). Also, it is not appropriate to comment or “approve” an incomplete Standard.

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NL 9.1 te/ed There is a difference between “bearing” and “resistance”; see accompanying Word document see 9.3.6. NL 9.2 te/ed There is a difference between “actions” and “forces” see see accompanying Word document 9.3; for “footing” see 3.91. NL 9.2 te Prediction of leg penetration is a key parameter for the rig see accompanying Word document move operation and needs to be added to the list as a separate item. UK 9.2 te/ed This section needs to take the opportunity to highlight leg Above first bullet point penetration prediction as a separate line item, as this is a “ The possibility of punch through” key parameter during the rig move operation. Add ” Leg penetration prediction” NO 9.1 or 9.2 te 9.1 or 9.2 should require compliance ISO 19901-4 on geotechnique, and the subsequent text should refer to and be based on ISO 19901-4. US1 9.2 te/ed This section needs to take the opportunity to highlight leg Above first bullet point penetration prediction as a separate line item, as this is a “ The possibility of punch through” key parameter during the rig move operation. Add ” Leg penetration prediction” US2 9.2 Page In some areas, COP has embarked on a geotechnical investigation where both borings and in situ testing were performed in each spud can prior to the arrival of the JU rig. US2 9.2 Page 32,33 The statement of suggesting that “Applicable information from previous operations may be used” should be qualified. We have seen that crustal layer depths vary over a field as well as from leg to leg so one needs to insure that this is not taken lightly. US2 9.2 Page 33 Assessment should include rapid leg penetration which is different than a punch through situation NL 9.3 te/ed Reactions from the seabed on the spudcan are action see accompanying Word 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 **) 2 Type of comment: ge = general te = technical ed = editorial NOTE Columns 1, 2, 4, 5 are compulsory. page 29 of 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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effects and therefore spudcan forces; soil forces are also action effects and internal to the soil. The following paragraph quoted from the introduction to ISO 19901-4 explains the situation further: ” For an offshore structure and its foundations, the action effects at the interface between the structure's subsystem and the foundation's subsystem(s) are internal forces, moments and deformations. When addressing the foundation's subsystem(s) in isolation, these internal forces, moments and deformations may be considered as actions on the foundation's subsystem(s) and this approach is followed in this part of ISO 19901.” NO 9.3.2 te 9.3.2 should incorporate "rack phase difference" in the UK HSE safety notice 4/2002 on "Jack-up (self- elevating) installations. UK 9.3.2 te/ed Make link between theory and practice At end of 9.3.2 Add ” The use of this data during rig move operations provides essential information on the continuity between theoretical assessment and operational reality.” US1 9.3.2 te/ed Make link between theory and practice At end of 9.3.2 Add ” The use of this data during rig move operations provides essential information on the continuity between theoretical assessment and operational reality.” US2 9.3.2 Page 34 What is meant by “ a lower preload may be acceptable when justified by appropriate geotechnical considerations”? NL 9.3.2 para 1 te The factoring is not applied to the “soil loading” but to the see accompanying Word document actions applied on the jack-up!! Furthermore, use should be made of the opportunity to 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 30 of 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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link theory and practice. CA 9.3.3, 9.3.4 ge Clause is absent, with comment that a brief précis from N/A the Informative to be added. Cannot approve something that is absent. CA 9.3.4 All ge In this section there are statements such as: “The shear Delete the sentences stipulating that equations in modulus for clay and sand shall be determined in Informative sections be used. It is anyway obvious accordance with A9.3.4.3 or A.9.3.4.4”. This in effect that further information is provided in the results in the Informative part becoming part of the Informative part, so there is no need to even say standard. “Guidance is provided…..” CA 9.3.5 Last ge Sentence mandates a clause in Informative part Delete last sentence sentence of paragraph US2 9.3.5 Page 34 Please define or provide an illustration as to vertical- horizontal capacity envelopes NL 9.3.6 te The general term for what can be withstood is see accompanying Word document “resistance”; in the 19900 series resistance of structural components is referred to as “strength” while resistance of foundations is referred to as “capacity. However, “bearing capacity” of a foundation refers (predominantly) to vertical capacity; for sliding the general term “resistance” is used: hence “sliding resistance”; for consistency with ISO 19901-4. FR 9.3.7 te Add “Resistance to penetration and retrieval” US2 9.3.7 Page 35 Is this section mainly referring to mat foundations but calling them spud cans as well? Possible a schematic would be helpful here to better familiarise the reader with exactly what is being discussed. NL 9.4.3 and ed Include References in the informative annex A. and 9.4.7 replace them by referring to A.9.4.3 and A.9.4.7. FR 9.4.4 te Add “in particular for skirted spudcans in cohesive soils” CA 9.4.5 First para, te There is not general agreement about the definition, or Change to: 9.4.5. Cyclic Loading 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 31 of 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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title even mechanics of “liquefaction” and “cyclic mobility”, so Cyclic loads, from earthquakes or severe storms, a description in this Standard is not called for. may cause a progressive buildup of pore pressures within foundation soils. Depending on the extent of pore pressure developed, foundation failure may result. The design shall consider the effects of cyclic loading on stability. FR 9.4.6 te To precise if “continued foundation settlement” mean “continuous jack-up leg penetration” CA 9.4.7 5th para, te This paragraph states that there is no definitive Delete, and move to Informative. “There is procedure, but gives useful references. This is no….” appropriate material for Informative section. NL 9.4.9 te/ed Proximity is “closeness”; greater proximity etc. is therefore see accompanying Word document confusing: it could be interpreted as being closer instead of being farther away, as intended here. Use “distance” instead of “proximity”. CA 9.4.9 2nd para ge States that guidance is given in Annex. This is an Delete unnecessary statement CA 9.4.9 Last ge “…. Owner may wish to consider…” is more appropriate Suggest “When proximity is closer than one sentence of in Informative. spudcan diameter or layered soils conditions are 1st para encountered, the consequences of induced pile loading should be considered.” US2 9.4.10 Page 38 Please add a section on Swiss Cheesing Techniques NL 10 ed Proposed editorial improvements. see accompanying Word document. NL 10 and A.10 throughout te/ed Response is a general term meaning generally the same Review text for appropriate plural forms. as action effect. Response can be used in singular and in plural. However, in most situations ‘response’ and ‘action effect’ both relate to many different variables and the plural forms should be used. The singular form would only be appropriate for a generic description (such as static or dynamic response) or when referring to a specific variable.

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NL 10.1 last line ed Remove 3rd word. Change to “actions are addressed in Clause 8.” NO 10.5.2 te 10.5.2 It should be investigated if the SDOF- method is conservative for larger waves with significant energy at wave periods at the multiple of the eigenfrequency. NL 10.5.3 para 1 te line 2: plural. Change to “multiple realizations” last sentence: Don’t understand this: one simulation reword or clarify. provides only one maximum value of a particular variable; that does not provide the necessary information for determining the most probable maximum. NL 10.5.4 line 1 te/ed ‘moments in plural (e.g. in two planes) and correction. Change to: “The leg moments due to initial leg inclination shall be combined with member forces from “ line 4 te The applied actions are factored, not the vertical reaction. Correct phrasing. Reactions are action effects (the results) of the factored actions. NL 10.7 te There are several important comments on subclause Revise the text to bring 10.7 in line with ISO 10.7. 19901-2. 1) Seismic risk assessment should be based on the site For some preliminary editorial suggestions, see seismic zone and the seismic risk category (SRC), see accompanying Word document. ISO 19901-2. The SRC determines if a simplified or a detailed procedure is required. 2) An ULS assessment is associated with an ELE (not an ALE). Due to the ELE little or no damage shall be sustained. For this the maps in ISO 19901-2, Annex B, may be used, which are based on a 1000 year return period. 3) For exposure level L1 the target annual probability of failure corresponds with a return period of 2500 years. Also, Include reference to 8.6.3 for foundation modelling

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under earthquake excitation. NO 10.7 te An annual probability of 10E-4 should be used for earthquakes. UK 10.7 te/ed Whilst understanding the objective of identifying an Replace 1000 with 2500 onerous assessment as a method of swiftly proving the jack-ups robustness under seismic loading, is the 1000 year ALE appropriate?

For L1 exposure level, ISO 19901-2 Seismic Design procedures & criteria gives a 2500 year return period for an Abnormal Level Earthquake [ALE] US1 10.7 te/ed Whilst understanding the objective of identifying an Replace 1000 with 2500 onerous assessment as a method of swiftly proving the jack-ups robustness under seismic loading, is the 1000 year ALE appropriate?

For L1 exposure level, ISO 19901-2 Seismic Design procedures & criteria gives a 2500 year return period for an Abnormal Level Earthquake [ALE] UK 10.7 NOTE te/ed Seismic energy is usually at frequencies significantly Replace “or due to lateral stability” different from a jack-ups lateral modes of vibration, but may achieve resonance with a jack-ups vertical modes of with vibration, the drilling derrick and ancillary equipment ( pipe stands etc) “or due to resonant response with the rig’s lateral or vertical modes of vibration. The effects of seismic loading on the drilling derrick and ancillary equipment (pipe stands etc) needs to be considered. US1 10.7 NOTE te/ed Seismic energy is usually at frequencies significantly Replace “or due to lateral stability” different from a jack-ups lateral modes of vibration, but may achieve resonance with a jack-ups vertical modes of with vibration, the drilling derrick and ancillary equipment ( pipe stands etc)

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“or due to resonant response with the rig’s lateral or vertical modes of vibration. The effects of seismic loading on the drilling derrick and ancillary equipment (pipe stands etc) needs to be considered. NL 11 ed Proposed editorial improvements. see accompanying Word document. NO 11 te For jack-ups on location for longer periods than the 5 years dry dock periods, the text should be in correspondence with Resolution 222 (Paris, 2006) ISO/TC67/SC7. ("SC 7 requires that WG 3 Editing Panel incorporates Option 3 of N383 for subclause 6.1.4 as amended and attached to the Report of the Meeting that resolves the cross-referencing of jack-up production units within ISO 19902."). NL 11.1 te/ed - title: replace “scope” by “applicability”, as in earlier see accompanying Word document. clauses; - consistency of terminology (“special survey” is a defined term, without the word “classification”); - according to ISO Directives a NOTE may not contain a recommendation; convert NOTE into regular text; - replace “regulator” by all stakeholders (owner, operator or regulator); note that the defined term “regulator” includes CS. NL 11.2 te/ed - for welded structures only time-varying actions are see accompanying Word document. relevant; - “structural resistance” and “fatigue endurance” are specific to a (particular detail of a) structural component; - the cross-reference to 11.3.1 does not add anything in the sense of “other data” and should be deleted as it is more restrictive than helpful; - editorial improvements.

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NL 11.3.1 te/ed - fatigue is a highly local phenomenon associated with a see accompanying Word document. particular location of a structural component; the fatigue life of a whole structure is not a meaningful concept; - the margin of safety is related to criticality and inspectability, not to the planned duration on site; - editorial improvements. NL 11.3.2 te/ed - “weight” is of no direct consequence for fatigue damage see accompanying Word document. assessment of welded structures; it can only have an indirect effect through P-delta influence; - we suggest to use “weight/mass” instead of “weight”; if this is not accepted, then “mass” alone is more appropriate; - “otherwise” is not appropriate wording; the allowance does not come in place of monitoring (which covers past and present, not future), but is additional to this. NL 12 ed Proposed editorial improvements. see accompanying Word document NL 12 and A.12 throughout te/ed Rationalize the nomenclature in accordance with the Modify as required. finally adopted terminology for parts / components / members; see 3.19 - 3.27 - 3.61 and 3.103. NL 12.1.3 ed Move the reference to A.12.1.3 and include it in the Follow ISO Directives. Bibliography. NO 12.5 te Reference should be made to ISO 19902. NL 12.7 te/ed The applied actions are factored, not the internal forces. see accompanying Word document. NL 13 ed Proposed editorial improvements. see accompanying Word document NL 13 throughout te This is a crucially important clause, which is currently not yet finalized, while guidance in A.13 is still completely missing. Combined with lack of completeness in other clauses and the missing informative annex this makes review and evaluation of 19905-1 unsatisfactory and near to impossible. 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 36 of 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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NL 13 throughout te/ed Make clear where all required partial action and To avoid misunderstandings, be specific in cross- resistance factors are given: are they distributed over referencing applicable partial action and resistance various clauses or are they all collected in Annex B? factors. NL 13.1.1 te In the list of issues to be considered, the item on see accompanying Word document foundation integrity should include “leg penetration” (a key parameter for rig acceptability) and “sliding resistance” (which is different from bearing capacity). UK 13.1.1 te/ed Leg penetration is a key parameter for rig acceptability Replace “ preload, bearing capacity” with “preload, leg penetration, bearing capacity”

US1 13.1.1 te/ed Leg penetration is a key parameter for rig acceptability Replace “ preload, bearing capacity” with “preload, leg penetration, bearing capacity”

NL 13.1.2 last para te/ed Change to: - replace “calculations” with “assessments”; “... prior assessments according to …” - “this standard” is an inappropriate formulation; if 19905- adjust as required. 1 is meant then it should be “this document”; if 19905 in its totality is meant it should be “this International Standard” or even better “ISO 19905 parts 1 and 2” NO 13.1.3 te A reference should be made to the ISO 2631/1 and ISO 5349 on vibrations NO 13.1.5 te A section on ALS should be added. The site-specific risk should be evaluated. The collision risk and the risk of mudslide will be location specific NL 13.2 te/ed This subclause needs technical as well as editorial Rethink the general formulation of an assessment, improvements. Our comments relate to: making full use of and complying with definitions. - there is no need to include here descriptions of 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 37 of 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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fundamentals of factoring; this is basic knowledge and also spelled out in the definition of utilization (3.106); - checking for combined forces involves the application of an interaction equation, which does not correspond with the elementary form “action effect due to factored actions divided by factored resistance”; see again the definition of utilization in 3.106; - there are several assessment situations to be checked; for each assessment situation the appropriate action effect(s), which are normally due to several applied and factored actions, need to be specified; the factors relevant to the case considered can vary from case to case; all this needs careful spelling out in an integral manner. NO 13.3.1 ed Is referring to resistance factors in chapter 12. The reference must be wrong NO 13.3.2 te Should be deleted; working stress design is not in accordance with ISO 19900. An opening for using other method can be put in, provided it gives the same safety level. NL 13.3.1 te/ed - as for Clause 12 and A.12: rationalize the nomenclature Reformulate as necessary. in accordance with the finally adopted terminology for parts / components / members; see 3.19 - 3.27 - 3.61 and 3.103; - be specific in cross-referencing applicable partial action and resistance factors, and include these cross- references in normal text, not in an informative NOTE; - the factors shall be normative, not informative (Annex B shall be normative). NL 13.3.2 te Subclause still to be provided. Provide the text. NL 13.6 te/ed - para 2: this is unclear and vague as written; the - define “extreme wave crest” and delete para 2’ extreme wave crest height should be clearly defined in a definition or a (sub)clause; when done para 2 should be 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 38 of 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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deleted as para 1 covers all; - para 3: rephrase in a simpler and stricter manner as - change to “The hull elevation shall shown in column 6; account for ……”

st - 1 NOTE: the length of a wave crest is near to - delete the 1st NOTE. impossible to determine and should not be used as a condition or an additional criterion; nd - 2 NOTE: The definition of air gap in ISO 19900 as nd given below should be quoted as such rather than - rephrase the 2 NOTE. paraphrased: ”clearance between the highest water surface that occurs during the extreme environmental conditions and the lowest exposed part not designed to withstand wave impingement”. NO 13.6 te 50-year return period plus a deck clearance of 1.5m gives It is suggested to replace the text by using a 10E-4 an inadequate safety. When hitting the deck the loading probability of event consept. will increase significantly. NL 13.7 te Leg length reserve should reflect any uncertainty in the see accompanying Word document prediction of leg penetration. The minimum value of 1,5 m is only applicable for locations where a high degree of certainty can be achieved. UK 13.7 te/ed A leg length reserve should reflect any uncertainty in the Replace 1st sentence with prediction of leg penetration, with the minimum value of 1,5m only applicable for locations where a high degree of certainty is achievable. The leg length reserve above the upper guides should reflect the uncertainty in the prediction of leg penetration and account for any settlement. A minimum value of 1.5 m may be applicable for locations where a high degree of certainty is achievable. US1 13.7 te/ed A leg length reserve should reflect any uncertainty in the Replace 1st sentence with prediction of leg penetration, with the minimum value of 1,5m only applicable for locations where a high degree of certainty is achievable. The leg length reserve above the upper guides should reflect the uncertainty in the prediction of 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 39 of 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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leg penetration and account for any settlement. A minimum value of 1.5 m may be applicable for locations where a high degree of certainty is achievable. NL 13.8 te/ed - editorial suggestions; - see accompanying Word document - the cross-ref to the CoG position is incorrect; there is no - in view of its importance it should be ensured specific subclause on CoG; 5.4.4 is the only one and that the relevant position of the CoG is specified discusses weight and CoG together;

- the partial resistance factor R, OTM is solely intended to - reconsider the value of R, OTM account for the uncertainty in determining the stabilizing moment; a factor of I,0 would suggest that there is no uncertainty involved, which is unrealistic. As far as we are aware a factor of 1,0 is neither supported by SNAME 5- 5A rev. 2. A departure from partial resistance factors in the SNAME document requires justification. NO 13.8 te a resistance factor of 1.0 does not give any additional safety. A higher factor should be evaluated. UK 13.8 te/ed - the partial resistance factor R, OTM of I,0 is not - reconsider the value of R, OTM supported by SNAME 5-5A rev.2 Any departure from the partial resistance factors presented in that document requires justification. US1 13.8 te/ed - the partial resistance factor R, OTM of I,0 is not - reconsider the value of R, OTM supported by SNAME 5-5A rev.2 Any departure from the partial resistance factors presented in that document requires justification. NL 13.9.1 2nd para te spudcan reactions are not factored; they are due to the Change to “spudcan reactions due to factored application of factored actions actions” see also accompanying Word document US2 13.9.1 Page 54 Statements made pertaining to bearing capacity utilization are proposed to be checked. Not sure what is exactly being requested here with the “utilization” term. Also

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what are factored spud can reactions? NL 13.9.2 line 1 te same comment as for 13.9.1 Change to “reactions on any spudcan due to factored actions”

NL Annex A heading and ed - Use the ‘standard’ heading as in other 19900 - Change heading to “Additional information and NOTE documents; guidance” - use phrasing of the NOTE as in other 19900 - copy 5 NOTES from ISO 19904-1. documents, e.g. as in FDIS 19902 or NOTE 1 of ISO 19904-1; it is worth considering copying all 5 NOTES in ISO 19904-1, giving clarification of the use of terminology in the document. NL 13.10 te/ed This statement is in our opinion a requirement, which is Change “should” to “shall”. expressed by “shall”. NO 13.10 te Add: "And the 100 year temperature shall be in accordance with the limitations in the certificate." NL Annex A throughout ed Ensure that titles are identical with titles of corresponding (sub)clauses in the body of the document. US2 A.4.9 Page 57 Both a and b are titled “bearing capacity squeezing factor” as well as f1 and f2 being referred to as “factor used in yield surface equation for embedded footings on clay” NL A.6.4 te/ed Large parts of the contents of A.6.4 deal with actions and Bring most of A.6.4 over and integrate with A.7. are consequently strongly related to A.7, where these parts would be better placed. UK A.6.4.1 2nd para Strong preference for seasonal extremes not smaller all- Reconsider the use of smaller return period year return periods, which may achieve same result, but extremes is not sufficiently explicit as to the risk identification and management. US1 A.6.4.1 2nd para Strong preference for seasonal extremes not smaller all- Reconsider the use of smaller return period year return periods, which may achieve same result, but extremes is not sufficiently explicit as to the risk identification and

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management. NO A.6.4.2.1 te The relation between HS and Hmax should be increased from 1.86 to 1.92. The order of magnitude of 1.90 to 1.92 is substantiated in several calculations of Norwegian data by different persons/companies. NO A.6.4.2.2 te Describes that the wave height can be reduced with a factor of 0.86. It should be stated that this value should not be used in calculating waves against the deck, substructures or slamming loads. Site Specific Assessment of Mobile Jack-Up Units (1994), commentaries point C3.5.4 page 19, states that assuming long-crested sea when significant spreading exists may be non-conservative. The 0.86-factor is similar to a kinematics reduction factor of 0.93. This value is not always conservative. The number is reasonable for small waves (less than Hs of 10m), but is not always conservative for waves above 10m. This is based on measurements at Magnus, Valhall and Ekofisk. In stead of one number a range of numbers should be stated, instructing the user to use the most conservative value. NL A.6.4.2.3 te Include appropriate text on the determination and Amend/complete as required. application of extreme wave crest elevation for ensuring adequate air gap. A suggested reference for the North Sea is “A recommended approach for deriving ISO- compliant 10 000 year extreme water levels in the North Sea” by I.M. Leggett et al, OMAE 2007 - 29559. NO A.6.4.2.3 te In order to be consistent with other ISO standards "If 100 joint probability data does not exist, a for offshore structures we would have preferred a combination of 100 year waves, 100 year 100 year reference level instead of 50 years. If not wind and 10 year current can be applied." revised, an alternative will be to include the 100 year value formulation in a regional annex. We realise that there is a resolution on this in a SC 7 meeting. However, in order to obtain the same reference values in all ISO standards we would 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 42 of 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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recommend also the same here to be consistent. Thus, in principle for Chapter 6.4 the text related to 50 year should be removed. Comment applies also to 5.5.4, 6,4, 8.8.1, A.6.4.2.3 and A.7.3.1.1 UK A.6.4.2.3 te/ed For the North Sea, a suggested reference is Include text on the use and application of extreme wave crest calculation for ensuring sufficient air OMAE2007-29559 A RECOMMENDED APPROACH gap FOR DERIVING ISO-COMPLIANT 10,000 YEAR EXTREME WATER LEVELS IN THE NORTH SEA I M Leggett et al UK A.6.4.2.3 te/ed The use of the 1-hour wind speed to approximate joint Delete probability wind speed is not acceptable and shall be removed ” This wind speed may be conservatively taken as the 100 year return period individual extreme 1 hour mean wind << Review Panel query Jan 06 : IS THIS STILL ACCEPTED ?? “ US1 A.6.4.2.3 te/ed For the North Sea, a suggested reference is Include text on the use and application of extreme wave crest calculation for ensuring sufficient air OMAE2007-29559 A RECOMMENDED APPROACH gap FOR DERIVING ISO-COMPLIANT 10,000 YEAR EXTREME WATER LEVELS IN THE NORTH SEA I M Leggett et al US1 A.6.4.2.3 te/ed The use of the 1-hour wind speed to approximate joint Delete probability wind speed is not acceptable and shall be removed ” This wind speed may be conservatively taken as the 100 year return period individual extreme 1 hour mean wind << Review Panel query Jan 06 : IS THIS STILL ACCEPTED ?? “ NL A.6.4.2.4 te/ed Use information and data by preference from ISO 19901- Use ISO 19901-1 to the greatest extent possible. 1 instead of from the TR (19905-2). There are 2 reasons for this: - ISO 19901-1 is part of the ISO 19900 series and applies therefore to all offshore structures; - the standard is available now, while it could be quite a 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 43 of 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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while before the TR is issued as ISO 19905-2. NL A.6.4.2.9 te/ed A fatigue analysis for dynamically responding jack-ups should be performed using random waves and response, either in the frequency or in the time domain; see e.g. ISO 19902. NO A.6.4.3 te ISO 19901-1 should be referenced as the main formulation. If it is appropriate to add other alternatives for jackups, it should be explained that this is a conservative alternative approach. NL A.6.4.4 te/ed Consistency: use water depth(s) defined in ISO 19901-1; MHWS and MLWS do not appear in ISO 19901-1. NL A.6.4.6.1 and te There is an inconsistency between para 2 of A.6.4.6.1, A.6.4.6.2 which refers to the logarithmic wind profile, and A.6.4.6.2 which gives a power law profile. (NB: if a power law profile is used the exponent is usually of the order of 1/8.5 rather than 1/10). NO A.6.4.6.2 te ISO 19901-1 should be referenced as the main formulation. If it is appropriate to add other alternatives for jackups, it should be explained that this is a conservative alternative approach. US2 A.6.5.1 Page 69 Even JU rigs with lower bearing pressures than previous used could still result in a punch through or rapid leg penetrations ? US2 A.6.5.1 Table A6.5.1 Add Swiss cheesing as one of the preventative measures Page 70, 71, for punch through 72 US2 A.6.5.1 Table A6.5.1 Sliding failure – should this be qualified as mat type Page 70, 71, foundation so as to not confuse it with a an independent 72 legged spud can? US2 A.6.5.1.1 Page 69 Line spacing may be more dependent on water depth or overlap than just recommending a 100m line spacing and

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not qualifying a water depth? FR A.6.5.1.3 2nd para ed …with existing soil boring data in the vicinity and “showing” similar stratigraphy US2 A.6.5.1.3 Page 69 Should different types of seismic equipment be mentions as to frequency and depth vs. accuracy? FR A.6.5.1.4.2 Last para te Delete “pressure-meter test” which is not a recognized test in offshore soil investigations US2 A.6.5.1.4.2 Page 70 What is the definition of “transition zone”? US2 A.6.5.1.4.2 Page 70 May want to mention that penetration calculations may be required during the course of the boring to insure that adequate depth is achieved US2 A.6.5.1.4.2 Page 70 Suggesting that T-bar and/or pressure meter tests in the same sentence as PCPT and vane shear would infer that these are routine tests. It is hard enough to get drilling departments to pay for PCPT test let alone T-bar or pressure meter tests that most geotechnical vessel do not have or cannot operate in the first place. US2 A.6.5.1.4.3 Page 70 Again, the statement of providing shear moduli and cyclic/dynamic behaviour needs to be better qualified than just a general statement suggesting that it may be required if soil strength may deteriorate under cyclic loading. US2 A.6.5.1.4.3 Page 70 Unless specified beforehand (i.e. field program) performing consolidation tests are not routine procedure for JU rig investigation studies. Suggest you provide reasoning why OCR are required for this analysis and what benefit it may produce. Most drilling departments who might commission such a site investigation are not interested in research or other than an answer as to when and how long it will take to get the rig onsite and ready to spud the first well.

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NL A.7.3.1.1 te/ed Rephrase “metocean actions”, “extreme metocean action Change to “environmental action” and make use of model”, and similar phrases. the defined term “extreme storm event”. NO A.7.3.1.1 te In order to be consistent with other ISO standards "If 100 joint probability data does not exist, a for offshore structures we would have preferred a combination of 100 year waves, 100 year 100 year reference level instead of 50 years. If not wind and 10 year current can be applied." revised, an alternative will be to include the 100 year value formulation in a regional annex. We realise that there is a resolution on this in a SC 7 meeting. However, in order to obtain the same reference values in all ISO standards we would recommend also the same here to be consistent. Thus, in principle for Chapter 6.4 the text related to 50 year should be removed. Comment applies also to 5.5.4, 6,4, 8.8.1, A.6.4.2.3 and A.7.3.1.1 UK A.7.3.1.1 te/ed The use of the 1-hour wind speed to approximate joint Delete probability wind speed is not acceptable and shall be removed ”(typically this wind speed may be taken conservatively as the 1 hour mean 100-year return period individual extreme wind), “ US1 A.7.3.1.1 te/ed The use of the 1-hour wind speed to approximate joint Delete probability wind speed is not acceptable and shall be removed ”(typically this wind speed may be taken conservatively as the 1 hour mean 100-year return period individual extreme wind), “ NL A.7.3.1.2 te Mention that a stochastic analysis that should include non-linearities should be a time domain stochastic analysis. NL A.7.3.1.2 te The hydrodynamic coefficients for deterministic and stochastic analysis should usually be chosen differently. NL A.7.3.2.4 ed Consistency: use water depth(s) defined in ISO 19901-1; MWL does not appear in ISO 19901-1. See also comment on A.6.4.4.

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NO A.7.3.2.4 table A.7.3.3 te The CD-factor of rough members should be increased to 1.05 in accordance with DNV-OS-C104. NO A.7.3.3.3.2 table A.7.3-4 te Based on measurements at Gullfaks C (S Haver : A discussion of the wave conditions in the Northern North Sea, Technical note, Shell, Troll project, 18.12.1992.) it was found an average skewness of 0.15 with a standard deviation of 0.07. Further a kurtosis on 3.09 with a standard deviation of 0.24. The limits in the table are to narrow Ref. : Sverre Haver : A discussion of the wave conditions in the Northern North Sea, Technical note, Shell, Troll project, 18.12.1992 NL A.8.3-1 Figure A.8.3- ed We do not support the panel suggestion to move the 1 figure to the TR. The figure is a logical part of A.8 and we recommend to let it stay there. NL A.8.6.3 te/ed Is “footings” in para 1 the correct term to use, or should it Adjust terminology as necessary. be replaced by “spudcans”? (see also comment to 3.91). In para 2, make use of the defined term “extreme storm event” instead of “maximum storm” (leg moment). Also in para 2, “loads” and “loading” on the spudcan or foundation are better replaced by “forces”; see the overall comments at the beginning of this table (before comment on the introduction) and comment on 9.3. NL A.8.8 te/ed Adjust terminology: Adjust terminology. - throughout: use “action(s)” instead of “load(s)” and “loading”, except in “inertial forces” (A.8.8.5) - use “permanent and variable actions” instead of “self- weight and non-varying loads, variable and drilling loads” (A.8.8.1 a)) and instead of “self-weight and variable loads” (A.8.8.3).

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NL A.9 te Provisions for several items still need to be provided, Complete the provisions. while some other issues still need to be resolved.

NL A.9 throughout te/ed - Use correct terminology: verbal forms, appropriate Follow ISO Directives and maintain consistency. and consistent terminology, phrasing, correct use of NOTES, etc. - Introduce equation numbers. - Introduce references as per the Directives and collect them in a Bibliography. FR A.9.3.2.2 6th para te Add “In areas with carbonate soils, the presence of a weakly cemented strata at or below mudline may involve additional uncertainties regarding the assessment of the punch-through risk” NO A.9.3.2.2 te Should be based on, and refer to ISO 19901-4 on geotechnique. Only additions should be stated US2 A.9.3.2.2 Page 111 Possibly a better word can be used in place of “crusts” to descried a layer of stronger soil resulting from a pause in preloading. CA A.9.3.2.3 3rd line after te States preference to be given to strength data from Propose to replace with statement along the lines equation in unconsolidated undrained triaxial tests, miniature vane of: “Qualified geotechnical engineer to use most 1st para tests or torvane tests. The state of practice has moved appropriate method to determine su.” beyond these tests, although it is recognized that much experience in GOM has been built-up on these tests, and there are much more reliable methods available. Preference should probably be given to in situ tests in the first instance. US2 A.9.3.2.3 Page 112 Include definition of terms here so reader does not have to refer back to pages 56-60 when describing an equation. It would also be useful to number each equation. May want to express second term as Gamma’ V where v is limited to the total volume of the spud can. Also need to propose over what depth that Su should be averaged? ( 0.09B below the level of the plate does not 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 48 of 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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make sense.)

US2 A.9.3.2.3 Page 114 It would be most helpful to provide a schematic to better illustrate all the discussion on how Vlo is calculated and how Hcav is considered in the equation. The whole paragraph pertaining to backflow show be re-written to allow the reader a better understanding of what is being implied US2 A.9.3.2.3 Page 114 Figure 9.3-5 is not shown even though it is referenced. US2 A.9.3.2.3 Page 114 The last two sentences concerning NC clays and GOM seems out of place here. One might also want to suggest that an upper and lower bound be considered in calculating the bearing capacity where Su is averaged at B, B/2 or possibly B/4 beneath the footing diameter. FR A.9.3.2.4 2nd para and te The range of friction angle should be reduced to better Table A.9.3.2 reflect the actually measured values, i.e. 20-50 degrees US2 A.9.3.2.4 Page 114 Equation needs to be checked. There is mixing of terms and it is confusing to reader whether this is net or gross bearing capacity. Should be consistent with how bearing capacity is expressed. (i.e. whether adding in volume of soil displaced to equation and whether this should be limited to total vol. of spud can) US2 A.9.3.2.4 Page 115 Maximum preload should be described as the temporary load that the rig adds to account for expected loading conditions while the rig is on site. Describing maximum preload as equal to the ultimate vertical bearing capacity is a little misleading. US2 A.9.3.2.7.2 Page 116 The equations are very confusing and require the reader to rewrite the equation after looking up what all the terms mean. In place of all the abbreviations, please writ the equation as to how they should appear or provide all 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 49 of 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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terms below the equation. Better definition and illustration are required to explain these equations. Equation and text mix Cu and Su. Is added gamma’ V limited to vol. of spud can FR A.9.3.2.7.3 3rd para ed Delete the sentence about “man-made punch-through risk”, which is already mentioned in clause A.9.3.2.2 US2 A.9.3.2.7.3 Page 117 Examples and equations mix Cu & Su and do not include volume of soil displaced by spud can. It appears that the way this whole section is portrayed is confusing and needs work. FR A.9.3.2.7.4 Fig. A.9.3.8 ed Delete “Dense” at the sand/clay interface US2 A.9.3.2.7.4 Page 118 Maybe I am missing something here but it would appear that AH gamma’ should be added and that A l gamma’ should be subtracted? Are equations dependent upon the spreading factored selected? US2 A.9.3.2.7.4?? General Suggest that the author provides a GOOD example of Comment computations for each method presented so that the practitioner can understand how terms and averaged values are used and how these different equations should be applied. US2 A.9.3.3 –9.5 Page 120 While the author may know and understand how this to134 section is supposed to be used it leaves the reader wondering what this is all about and where and how to apply all these equations. There are no figures to help in the explanation and terms such as Capacity Envelopes are mentioned with out presenting what these are suppose to resemble or how they can be used. Very disappointing! FR A.9.3.3.3 Last para ed Delete the last paragraph since deep penetration of spudcans in sand is very unlikely or impossible US2 A.9.3.3.7.4 Page 118 I believe that most practitioners would prefer to see the actual equation using terms which can be related to

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versus substituting another term which must be looked up under terms and definitions which may be 50 or more pagers away. (Ex Qu,b in place of 6 Su) FR A.9.3.4.3 te Add “When results of CPT tests are available, the shear modulus G can be determined from by correlation with the measured in-situ cone resistance (Lunne, Robertson and Powell, CPT in geotechnical practice,1997) CA A.9.3.4.3 Equation and te Guidance is given on relating rigidity index to plasticity Delete guidance on values of Ir. Maybe provide guidance on index. These correlations are just that – empirical guidance on how to determine su (see A.9.3.2.3) IrNC correlations without much physical basis. Their and G (from shear wave velocity) applicability beyond the area they were developed (GOM?) is unknown. Also note that Ir is a well defined and measurable parameter (ratio of small strain modulus to undrained shear strength). FR A.9.3.4.4 te Add “When results of CPT tests are available, the shear modulus G can be determined by correlation with the measured in-situ cone resistance (Lunne, Robertson and Powell, CPT in geotechnical practice, 1997) CA A.9.3.4.4 Equation and te The method proposed for shear modulus is based on the State: For sands the initial, small strain shear guidance “seabed vertical reaction under still water conditions”. A modulus is best determined from measured shear much better method is to measure shear wave velocity wave velocity and Gmax = Vs2. If such data are and determine G directly from it. Also no guidance is not available, suitable empirical or semi-empirical given on how to estimate “seabed vertical reaction under methods may be used to estimate shear modulus. still water condition”, and it is not at all clear what it is. FR A.9.3.6.4.1 ed Reference “Andersen [36]” to be checked (noted Andersen [18]in clause A.9.3.4.1 and Anderson [55] in the legend of Fig. A.9.2-1) FR A.9.3.6.6 1st para ed …due to bearing capacity failure during (to) preloading… FR A.9.3.6.6 5th para ed …due to local bearing failure or (due) to local increase… NL A.9.3.7 te/ed Subclause A.9.3.7 is missing from the annex. Add “A.9.3.7 Skirted spudcans”. FR A.9.4.9 ed Siciliano et al 1991 (not 1990)

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Add Hossain et al OTC 17770 2006 (already to be used in Fig A.9.3.2-5 of clause A.9.3.2.3) NL A.9.5 - te/ed There is no corresponding 9.5 in the normative. Introduce 9.5 if A.9.5 is needed. Analysis of single (mat) The two diagrams at the end (Figures A.9.5-10 and A.9.5- Link the figures to the text at the appropriate place foundations 6) do not belong to A.9.5. They are currently “loose” and describe them adequately. additions that are nowhere referenced in the text. NL A.10.4.4 ed The subclause in Annex A is a duplication of 10.4.4. Delete, or replace the current subclause by different text. NL A.10.4.5 ed There is no corresponding 10.4.5. Delete. NL A.10.5.2 ed The text between the headings for A.10.5.2 and Restructure the subclause avoiding hanging A.10.5.2.1 is a hanging paragraph. paragraphs. NL A.10.5.2.1.2 2) and 3) te We don’t understand items 2) and 3). Clarify items. NL A.10.5.2.1.2 para 2 (in te The dynamic problem (also for a SDOF) is actually a Rephrase appropriately. yellow) forced excitation problem, due to applied and distributed wave and current actions on the legs. The dynamic response modifies (generally enhances) the action effects. This is represented by adding inertial forces on the hull (if necessary augmented by inertial forces on the legs) to the applied wave and current actions in a (quasi-) static analysis. NL A.10.5.3 ed The text between the headings for A.10.5.3 and Restructure the subclause avoiding hanging A.10.5.3.1 is a hanging paragraph. paragraphs. NL A.11 throughout te/ed Bring the text fully in line with Clause 11 after the Reword as appropriate. adjustments are made. Ensure that editorial observations made at the beginning of this comments table are implemented and that ISO Directives are agreed with. UK A.11.3.1 S-N Curves te/ed Since some codes have design factors built-in to the SN Reconsider the reference list of S-N curve and curves (e.g. 2.5 for weld with CP in seawater) the fatigue ensure compatibility with design factors. Consider design factors need to reflect this. use of BS 7608 as a useful reference for the original F-2 to B S-N curve series.

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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

US1 A.11.3.1 S-N Curves te/ed Since some codes have design factors built-in to the SN Reconsider the reference list of S-N curve and curves (e.g. 2.5 for weld with CP in seawater) the fatigue ensure compatibility with design factors. Consider design factors need to reflect this. use of BS 7608 as a useful reference for the original F-2 to B S-N curve series. NL A.12 throughout te/ed As per the note of the authors at the beginning of A.12, this clause needs substantial further work to bring it in line with Clause 12 and ISO Directives. NL A.13 te A.13 is still completely missing. Provide A.13 as this is essential as further clarification/discussion and guidance on Clause 13.

NL Annex B - Adjust the title for terminology. Change to “Summary of partial action and resistance factors” - Partial action factors for permanent and variable actions (Re)consider the various factors. of 1,0 mean that these actions are precisely known. We acknowledge that good weight/load control is normal practice and that the factors should therefore be only slightly larger, but 1,0 is in our opinion unrealistic. -- We do not understand and question a factor of 0,9 for inertial forces due to ALE ground motions. - As long as Clause 12 + A.12 has not been finalized no opinion on resistance factors can be given. NL Annex C Not reviewed; review is not possible/meaningful as long as the annex has not been completed and is not properly linked to the rest of the document. NO C.1.1.1.1.1 Give a damping up to 7%. This is higher than the experienced damping of jackup-structure. Measurements give significantly lower damping. Reference is made to Sterndorff M J: Note on ringing effects for the Maersk Guardian, DHI, Hørsholm, 24.9.1993 and Brekke J N, J D Murff, R B Campbell og W C Lamb: Calibration of jackup structural analysis procedure using field measurements

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 53 of 54 ISO electronic balloting commenting template/version 2001-10 Template for comments and secretariat observations Date: 2007-04-16 Document: ISO/CD’F’ 19905-1

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

from a North Sea jack-up, OTC 6465, Houston, 1990. NL Annex D Not reviewed; review is not possible/meaningful as long as the annex has not been completed and is not properly linked to the rest of the document. NL Bibliography Collect all references in the bibliography. Follow ISO Directives for references and Bibliography.

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 54 of 54 ISO electronic balloting commenting template/version 2001-10

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