30 CFR Ch. II (7–1–12 Edition) § 250.616

Total Page:16

File Type:pdf, Size:1020Kb

30 CFR Ch. II (7–1–12 Edition) § 250.616 § 250.616 30 CFR Ch. II (7–1–12 Edition) (2) You may use a set of hydrau- a well under pressure utilizing equip- lically-operated combination rams for ment specifically designed for that pur- the blind rams and shear rams. pose, i.e., snubbing operations, shall in- (3) You may use a set of hydrau- clude the following: lically-operated combination rams for (1) One set of pipe rams hydraulically the hydraulic two-way slip rams and operated, and the hydraulically-operated pipe rams. (2) Two sets of stripper-type pipe (4) You must attach a dual check rams hydraulically operated with spac- valve assembly to the coiled tubing er spool. connector at the downhole end of the (h) An inside BOP or a spring-loaded, coiled tubing string for all coiled tub- back-pressure safety valve and an es- ing well-workover operations. If you sentially full-opening, work-string plan to conduct operations without downhole check valves, you must de- safety valve in the open position shall scribe alternate procedures and equip- be maintained on the rig floor at all ment in Form BSEE–0124, Application times during well-workover operations for Permit to Modify and have it ap- when the tree is removed or during proved by the District Manager. well-workover operations with the tree (5) You must have a kill line and a installed and using small tubing as the separate choke line. You must equip work string. A wrench to fit the work- each line with two full-opening valves string safety valve shall be readily and at least one of the valves must be available. Proper connections shall be remotely controlled. You may use a readily available for inserting valves in manual valve instead of the remotely the work string. The full-opening safe- controlled valve on the kill line if you ty valve is not required for coiled tub- install a check valve between the two ing or snubbing operations. full-opening manual valves and the pump or manifold. The valves must § 250.616 Blowout preventer system have a working pressure rating equal testing, records, and drills. to or greater than the working pres- (a) BOP pressure tests. When you pres- sure rating of the connection to which sure test the BOP system you must they are attached, and you must in- conduct a low-pressure test and a high- stall them between the well control pressure test for each component. You stack and the choke or kill line. For must conduct the low-pressure test be- operations with expected surface pres- fore the high-pressure test. For pur- sures greater than 3,500 psi, the kill poses of this section, BOP system com- line must be connected to a pump or ponents include ram-type BOP’s, re- manifold. You must not use the kill lated control equipment, choke and line inlet on the BOP stack for taking kill lines, and valves, manifolds, strip- fluid returns from the wellbore. pers, and safety valves. Surface BOP (6) You must have a hydraulic-actu- systems must be pressure tested with ating system that provides sufficient water. accumulator capacity to close-open- close each component in the BOP (1) Low pressure tests. All BOP system stack. This cycle must be completed components must be successfully test- with at least 200 psi above the pre- ed to a low pressure between 200 and 300 charge pressure, without assistance psi. Any initial pressure equal to or from a charging system. greater than 300 psi must be bled back (7) All connections used in the sur- to a pressure between 200 and 300 psi face BOP system from the tree to the before starting the test. If the initial uppermost required ram must be pressure exceeds 500 psi, you must flanged, including the connections be- bleed back to zero before starting the tween the well control stack and the test. first full-opening valve on the choke (2) High pressure tests. All BOP system line and the kill line. components must be successfully test- (g) The minimum BOP-system com- ed to the rated working pressure of the ponents for well-workover operations BOP equipment, or as otherwise ap- with the tree in place and performed by proved by the District Manager. The moving tubing or drill pipe in or out of annular-type BOP must be successfully 130 VerDate Mar<15>2010 13:23 Aug 17, 2012 Jkt 226121 PO 00000 Frm 00140 Fmt 8010 Sfmt 8010 Y:\SGML\226121.XXX 226121 erowe on DSK2VPTVN1PROD with Safety & Environmental Enforcement, Interior § 250.616 tested at 70 percent of its rated work- or the collapse pressure of the coiled ing pressure or as otherwise approved tubing, whichever is less. by the District Manager. (f) Recordings. You must record test (3) Other testing requirements. Variable pressures during BOP and coiled tubing bore pipe rams must be pressure tested tests on a pressure chart, or with a dig- against the largest and smallest sizes ital recorder, unless otherwise ap- of tubulars in use (jointed pipe, seam- proved by the District Manager. The less pipe) in the well. test interval for each BOP system com- (b) Times. The BOP systems shall be ponent must be 5 minutes, except for tested at the following times: coiled tubing operations, which must (1) When installed; include a 10 minute high-pressure test (2) At least every 7 days, alternating for the coiled tubing string. Your rep- between control stations and at stag- resentative at the facility must certify gered intervals to allow each crew to that the charts are correct. operate the equipment. If either con- (g) Operations log. The time, date, and trol system is not functional, further results of all pressure tests, actuations, operations shall be suspended until the inspections, and crew drills of the BOP nonfunctional, system is operable. The system, system components, and ma- test every 7 days is not required for rine risers shall be recorded in the op- blind or blind-shear rams. The blind or erations log. The BOP tests shall be blind-shear rams shall be tested at documented in accordance with the fol- least once every 30 days during oper- lowing: ation. A longer period between blowout (1) The documentation shall indicate preventer tests is allowed when there is the sequential order of BOP and auxil- a stuck pipe or pressure-control oper- iary equipment testing and the pres- ation and remedial efforts are being sure and duration of each test. As an performed. The tests shall be con- alternate, the documentation in the ducted as soon as possible and before operations log may reference a BOP normal operations resume. The reason test plan that contains the required in- for postponing testing shall be entered formation and is retained on file at the into the operations log. facility. (3) Following repairs that require dis- (2) The control station used during connecting a pressure seal in the as- sembly, the affected seal will be pres- the test shall be identified in the oper- sure tested. ations log. For a subsea system, the pod used during the test shall be iden- (c) Drills. All personnel engaged in well-workover operations shall partici- tified in the operations log. pate in a weekly BOP drill to famil- (3) Any problems or irregularities ob- iarize crew members with appropriate served during BOP and auxiliary equip- safety measures. ment testing and any actions taken to (d) Stump tests. You may conduct a remedy such problems or irregularities stump test for the BOP system on loca- shall be noted in the operations log. tion. A plan describing the stump test (4) Documentation required to be en- procedures must be included in your tered in the operation log may instead Form BSEE–0124, Application for Per- be referenced in the operations log. All mit to Modify, and must be approved records including pressure charts, oper- by the District Manager. ations log, and referenced documents (e) Coiled tubing tests. You must test pertaining to BOP tests, actuations, the coiled tubing connector to a low and inspections, shall be available for pressure of 200 to 300 psi, followed by a BSEE review at the facility for the du- high pressure test to the rated working ration of well-workover activity. Fol- pressure of the connector or the ex- lowing completion of the well- pected surface pressure, whichever is workover activity, all such records less. You must successfully pressure shall be retained for a period of 2 years test the dual check valves to the rated at the facility, at the lessee’s filed of- working pressure of the connector, the fice nearest the OCS facility, or at an- rated working pressure of the dual other location conveniently available check valve, expected surface pressure, to the District Manager. 131 VerDate Mar<15>2010 13:23 Aug 17, 2012 Jkt 226121 PO 00000 Frm 00141 Fmt 8010 Sfmt 8010 Y:\SGML\226121.XXX 226121 erowe on DSK2VPTVN1PROD with § 250.617 30 CFR Ch. II (7–1–12 Edition) (h) Subsea BOPs. Stump test a subsea (2) You must visually inspect your BOP system before installation. You BOP system and marine riser at least must: once each day if weather and sea condi- (1) Test all ROV intervention func- tions permit. You may use television tions on your subsea BOP stack during cameras to inspect this equipment. The the stump test. You must also test at District Manager may approve alter- least one set of rams during the initial nate methods and frequencies to in- test on the seafloor.
Recommended publications
  • Wellcap® IADC WELL CONTROL ACCREDITATION PROGRAM WELL SERVICING OPERATIONS – SNUBBING CORE CURRICULUM and RELATED JOB SKILLS
    WellCAP® IADC WELL CONTROL ACCREDITATION PROGRAM WELL SERVICING OPERATIONS – SNUBBING CORE CURRICULUM AND RELATED JOB SKILLS FORM WCT-2SS SUPERVISORY LEVEL The purpose of the core curriculum is to identify a body of knowledge and a set of job skills that can be used to provide well control skills for well servicing operations. The curriculum is divided into three certification types: Coiled Tubing, Snubbing, and Wireline (Wireline is presented in document WCT – 2WSW) and within each certification, three levels: Introductory, Fundamental, and Supervisory. Students may complete an individual certification (e.g., Coiled Tubing) or combination certifications (e.g., Coiled Tubing and Snubbing). All knowledge and skills for each individual certification must be addressed when combining certifications. The suggested target students for each core curriculum level are as follows: INTRODUCTORY: New Hires (May also be appropriate for non-technical personnel) FUNDAMENTAL: Helpers, Assistants, “Hands” involved with the operational aspects of the unit and who may act/operate the unit under direct supervision of a certified Unit Operator or Supervisor. SUPERVISORY: Unit Operators, Supervisors, Superintendents, and Project Foreman Upon completion of a well control training course based on curriculum guidelines, the student should be able to perform the job skills in italics identified by a "!" mark (e.g., ! Identify causes of kicks). Form WCT-2SS WellCAP Curriculum Guidelines – Well Servicing - Snubbing Revision 040416 Supervisory Page 1 CORE CURRICULUM
    [Show full text]
  • Oil and Gas Operator Representative Workover and Intervention Well Control
    Oil and Gas Operator Representative Workover and Intervention Well Control Curriculum, Course Delivery Requirements, and Related Learning Objectives Form WSP-02-WS-OGO Revision 0 27 September 2017 © IADC 2017 COPYRIGHT PROTECTED DOCUMENT All rights reserved. No part of this document may be distributed outside of the recipient’s organization unless authorized by the International Association of Drilling Contractors. Related Learning Objectives for WellSharp® Oil and Gas Operator Representative-Workover/Intervention Well Control Contents 1.0 Oil and Gas Operator Representative Course Overview........................................................................................................................................ 3 2.0 Curriculum .............................................................................................................................................................................................................. 5 2.1 Risk Awareness and Management ................................................................................................................................................................. 5 2.2 Organizing a Well Control Operation ............................................................................................................................................................. 7 2.3 Well Control Principles & Calculations ........................................................................................................................................................... 7 2.4
    [Show full text]
  • How to Solve Your Long Lateral Problems
    A Deep Well Services White Paper in Conjunction with SPE Penn State How to Solve Your Long Lateral Problems Trevor Heyl, Senior Petroleum and Natural Gas Engineering Student at The Pennsylvania State University & Matt Tourigny, VP of Marketing at Deep Well Services www.deepwellservices.com Table of Contents Executive Summary..……………...……………………………………….……….…..….. 2 Challenges with Longer Laterals ……………………………………….…………..……. 2 Existing Solutions ……………………………..…………………………………….….….. 3 Coiled Tubing …….………….….……….…….……………………………………..… 3 Rig-Assist Snubbing Units.……………..………..................................................… 4 Hydraulic Completion Units..….………………………………………………….……..… 5 Cost Comparison ……………………………………………………………………..... 7 HCU Technologies …………………………………………………………………....... 8 Case Studies ……………………………..……..……..………………………….……….. 11 What to Look for in a Solution …….………………………………...…………….…….. 17 Conclusion …………..……………..…..…..….……….……………………………..….... 17 Deep Well Services ………….……..…...……..………………………………………….. 18 Page | 1 Executive Summary Longer laterals impose challenges with current completion methods. The low-price environment in the oil and gas field forces operators to focus on cost-saving methods anywhere practical. Wells with longer laterals have become more prominent in the industry due to their additional contact with the formation, increased productivity and the ability to save money. However, conventional completion methods are a limiting factor due to their decreasing efficiencies with respect to lateral length and problems that thereby
    [Show full text]
  • IRP 13: Wireline Operations an Industry Recommended Practice (IRP) for the Canadian Oil and Gas Industry Volume 13 – 2020
    IRP 13: Wireline Operations An Industry Recommended Practice (IRP) for the Canadian Oil and Gas Industry Volume 13 – 2020 EDITION: 2 SANCTION DATE: February 19, 2020 Copyright/Right to Reproduce Copyright for this Industry Recommended Practice is held by Energy Safety Canada, 2020. All rights reserved. No part of this IRP may be reproduced, republished, redistributed, stored in a retrieval system, or transmitted unless the user references the copyright ownership of Energy Safety Canada. Disclaimer This IRP is a set of best practices and guidelines compiled by knowledgeable and experienced industry and government personnel. It is intended to provide the operator with general advice regarding the specific topic. It was developed under the auspices of the Drilling and Completions Committee (DACC). IRPs are provided for informational purposes. Users shall be fully responsible for consequences arising from their use of any IRP. The recommendations set out in this IRP are meant to allow flexibility and must be used in conjunction with competent technical judgment. It is recognized that any one practice or procedure may not be appropriate for all users and situations. It remains the responsibility of the user of this IRP to judge its suitability for a particular application and to employ sound business, scientific, engineering and safety judgment in using the information contained in this IRP. If there is any inconsistency or conflict between any of the recommended practices contained in this IRP and an applicable legislative or regulatory requirement, the legislative or regulatory requirement shall prevail. IRPs are by their nature intended to be applicable across industry, but each jurisdiction may have different or unique legal requirements.
    [Show full text]
  • Snubbing Operations
    IRP 15: Snubbing Operations An Industry Recommended Practice (IRP) for the Canadian Oil and Gas Industry Volume 15 - 2020 EDITION: 4 SANCTION DATE: February 2020 Operational Practices and Procedures IRP 15 Snubbing Operations Copyright/Right to Reproduce Copyright for this Industry Recommended Practice is held by Energy Safety Canada, 2020. All rights reserved. No part of this IRP may be reproduced, republished, redistributed, stored in a retrieval system, or transmitted unless the user references the copyright ownership of Energy Safety Canada. Disclaimer This IRP is a set of best practices and guidelines compiled by knowledgeable and experienced industry and government personnel. It is intended to provide the operator with general advice regarding the specific topic. It was developed under the auspices of the Drilling and Completions Committee (DACC). IRPs are provided for informational purposes. Users shall be fully responsible for consequences arising from their use of any IRP. The recommendations set out in this IRP are meant to allow flexibility and must be used in conjunction with competent technical judgment. It is recognized that any one practice or procedure may not be appropriate for all users and situations. It remains the responsibility of the user of this IRP to judge its suitability for a particular application and to employ sound business, scientific, engineering and safety judgment in using the information contained in this IRP. If there is any inconsistency or conflict between any of the recommended practices contained in this IRP and an applicable legislative or regulatory requirement, the legislative or regulatory requirement shall prevail. IRPs are by their nature intended to be applicable across industry, but each jurisdiction may have different or unique legal requirements.
    [Show full text]
  • Service Company Equipment Operator Snubbing Well Control
    Service Company Equipment Operator Snubbing Well Control Curriculum, Course Delivery Requirements, and Related Learning Objectives Form WSP-02-WS-SN-EO Revision 0 17 August 2017 © IADC 2017 COPYRIGHT PROTECTED DOCUMENT All rights reserved. No part of this document may be distributed outside of the recipient’s organization unless authorized by the International Association of Drilling Contractors. WellSharp® Service Company Equipment Operator Snubbing Well Control Contents 1.0 Overview of Service Company Equipment Operator Snubbing Well Control ........................................................................................................ 3 2.0 Curriculum .............................................................................................................................................................................................................. 5 2.1 Risk Awareness and Management ................................................................................................................................................................. 5 2.2 Well Control Principles & Calculations ........................................................................................................................................................... 6 2.3 Barriers ......................................................................................................................................................................................................... 10 2.4 Influx Fundamentals....................................................................................................................................................................................
    [Show full text]
  • NORSOK STANDARD D-010 Well Integrity in Drilling and Well Operations
    NORSOK STANDARD D-010 Rev. 3, August 2004 Well integrity in drilling and well operations This NORSOK standard is developed with broad petroleum industry participation by interested parties in the Norwegian petroleum industry and is owned by the Norwegian petroleum industry represented by The Norwegian Oil Industry Association (OLF) and Federation of Norwegian Manufacturing Industries (TBL). Please note that whilst every effort has been made to ensure the accuracy of this NORSOK standard, neither OLF nor TBL or any of their members will assume liability for any use thereof. Standards Norway is responsible for the administration and publication of this NORSOK standard. Standards Norway Telephone: + 47 67 83 86 00 Strandveien 18, P.O. Box 242 Fax: + 47 67 83 86 01 N-1326 Lysaker Email: [email protected] NORWAY Website: www.standard.no/petroleum Copyrights reserved NORSOK Standard D-010 Rev 3, August 2004 Foreword 4 Introduction 4 1 Scope 6 2 Normative and informative references 6 2.1 Normative references 6 2.2 Informative references 7 3 Terms, definitions and abbreviations 7 3.1 Terms and definitions 8 3.2 Abbreviations 12 4 General principles 13 4.1 General 13 4.2 Well barriers 13 4.3 Well design 19 4.4 Risk assessment and risk verification methods 20 4.5 Simultaneous and critical activities 20 4.6 Activity and operation shut-down criteria 21 4.7 Activity programmes and procedures 22 4.8 Contingency plans 24 4.9 Personnel competence and supervision 24 4.10 Experience transfer and reporting 25 5 Drilling activities 26 5.1 General 26
    [Show full text]
  • The Defining Series: Well Intervention
    THE DEFINING SERIES Well Intervention— Guide arch Maintenance and Repair (gooseneck) Rick von Flatern CT string Senior Editor Reel Injector head Few oil and gas wells perform efficiently and produce uninterrupted from Stripper BOP initial production to abandonment. Moving parts and seals wear out, tubu- lars develop leaks, sensors fail and formation pressures decline. To address these and other problems, operators rely on well intervention specialists. Interventions fall into two general categories: light or heavy. During light interventions, technicians lower tools or sensors into a live well while pres- > Coiled tubing unit. Coiled tubing (CT) is flexible pipe that may be spooled sure is contained at the surface. In heavy interventions, the rig crew may on and off a large reel using an injector head. The hydraulically driven need to remove the entire completion string from the well to make major injector head uses a series of slips to grip and pull the tubing off the reel or from the well and through an arched guide called a gooseneck. The changes to the well configuration, which requireskilling the well by stop- gooseneck bends the tubing toward the wellhead or for spooling back onto ping production at the formation. the reel. The coiled tubing enters and exits the wellbore through a stripper blowout preventer (BOP), which contains components that seal against the tubing to contain well pressure. A second set of sealing rams (not shown) in the BOP may be closed against the coiled tubing to provide a pressure barrier alternative in the event the stripper BOP fails. Sheave The Lighter Side Pressure- Well service personnel typically perform light interventions using slickline, control wireline or coiled tubing.
    [Show full text]
  • (Wireline, Coiled Tubing & Snubbing) Core Curric
    WellCAP® IADC WELL CONTROL ACCREDITATION PROGRAM WELL SERVICING OPERATIONS (WIRELINE, COILED TUBING & SNUBBING) CORE CURRICULUM AND RELATED JOB SKILLS FORM WCT-2WSI INTRODUCTORY LEVEL For information on how an Introductory Level course should be delivered and documented, refer to Form WCT-21. The purpose of WellCAP core curriculum is to identify a body of knowledge and a set of job skills, which can be used to provide well control skills for wireline operations. The curriculum is divided into three course levels: Introductory, Fundamental, and Supervisory. The suggested target students for each core curriculum level are as follows: INTRODUCTORY: New Hires (May also be appropriate for non-technical personnel) FUNDAMENTAL: Helpers, Assistants, “Hands” and personnel involved with the operational aspects of the unit SUPERVISORY: Supervisors, Superintendents, and Project Foreman Upon completion of a well control training course based on curriculum guidelines, the student should be able to perform the job skills in italics identified by a "n" mark (e.g., n Identify causes of kicks). Form WCT-2WSI WellCAP Curriculum Guidelines – Well Servicing Operations Revision 030627 Introductory Level Page 1 CORE CURRICULUM & JOB SKILLS – TABLE OF CONTENTS TABLE OF CONTENTS I. REASONS FOR WELL SERVICING OPERATIONS ..................................................................................................................... 5 A. Definitions of well-servicing operations........................................................................................................................................
    [Show full text]
  • Snubbing Field Operations - Potential Trapped Air and Explosive Hydrocarbon Mixtures on Surface
    University of Calgary PRISM: University of Calgary's Digital Repository Graduate Studies The Vault: Electronic Theses and Dissertations 2013-06-20 Snubbing Field Operations - Potential Trapped Air and Explosive Hydrocarbon Mixtures on Surface Prebeau-Menezes, Leon Jerome Prebeau-Menezes, L. J. (2013). Snubbing Field Operations - Potential Trapped Air and Explosive Hydrocarbon Mixtures on Surface (Unpublished master's thesis). University of Calgary, Calgary, AB. doi:10.11575/PRISM/27808 http://hdl.handle.net/11023/761 master thesis University of Calgary graduate students retain copyright ownership and moral rights for their thesis. You may use this material in any way that is permitted by the Copyright Act or through licensing that has been assigned to the document. For uses that are not allowable under copyright legislation or licensing, you are required to seek permission. Downloaded from PRISM: https://prism.ucalgary.ca UNIVERSITY OF CALGARY Snubbing Field Operations - Potential Trapped Air and Explosive Hydrocarbon Mixtures on Surface by Leon Jerome Prebeau-Menezes A THESIS SUBMITTED TO THE FACULTY OF GRADUATE STUDIES IN PARTIAL FULFILMENT OF THE REQUIREMENTS FOR THE DEGREE OF MASTER OF SCIENCE DEPARTMENT OF CHEMICAL AND PETROLEUM ENGINEERING CALGARY, ALBERTA JUNE, 2013 © Leon Jerome Prebeau-Menezes 2013 Abstract Snubbing is a widely used drilling, completion and work-over method. It is especially useful in HPHT reservoirs and in unconventional reservoirs such as the Marcellus, Haynesville, Bakken oil and Eagle Ford shale plays. During
    [Show full text]
  • Texas Oil Tools Well Intervention Equipment Leading Specialty Manufacturers and Suppliers of Pressure Control Equipment
    Texas Oil Tools Well Intervention Equipment Leading specialty manufacturers and suppliers of pressure control equipment. At NOV, we’ve come a long way in establishing ourselves as one of the leading specialty manufacturers and suppliers of pressure control equipment. While you respond to your industry challenges, we’re working to develop new and more efficient solutions to your problems. We understand just how important uptime is to overall success. That’s why we built a state-of-the- art service and repair facility that can get your equipment back into the field as quickly as possible. From simple redress to full recertification, our proven track record of excellence in design, manufacturing and service will help you keep your operations running at maximum efficiency, 24/7. [email protected] nov.com/tot Coiled Tubing Stack Regardless of how demanding your operations are, our coiled tubing pressure control equipment can meet your needs and leads the industry with a proven track record of innovation and performance. We provide a variety of equipment used in the pressure control stack, including the vertical style single side door and dual over/under or the two- Surface Well door stripper. If height or thru bore capabilities are an issue, then the sidewinder horizontal coil stripper could be an option. We can meet your needs with any adapter flange, flow cross or lubricator needed - from the wellhead to the injector head. Our BOPs consist of different sizes, working pressures and Intervention configurations. The most common model, our ES Series, has hydraulic ram change, which improves safety when servicing your BOP.
    [Show full text]
  • View Annual Report
    PDar01DR10 3/28/01 3:02 PM Page 83 Precision Drilling Corporation Canadian eh... 2000 Annual Report Cover 4/5/01 11:10 AM Page 2 OUR GUIDANCE AND SUPPORT This year’s annual report celebrates 15 years of robust growth for Precision. It focuses on the critical goals we have set and met over the last year and the factors crucial to the continued growth of our company. It is no accident that today, Precision is at the forefront of the drilling and service industry in Canada and making inroads globally. Our achievement is the result of a decade of hard work, careful planning, bold strategic moves and, as in any business, some good fortune. Precision Drilling Corporation is an international oilfield services Our Officers: from left to right Michael J. McNulty, Vice President Finance; Hank B. Swartout, Chairman, President and Chief Executive Officer; W. Bruce Herron, Senior Vice President Rental and Production company. In a 15 year span, Precision has grown from a three rig Services; Dale E. Tremblay, Senior Vice President Finance and Chief Financial Officer; Jan M. Campbell, Corporate Secretary; Larry J. Comeau, Senior Vice President Oilfield Speciality Services. drilling contractor in western Canada, with $4 million in revenue to a multi-service international oil and gas service company with revenues exceeding $1.3 billion. Through a series of targeted acquisitions, the Corporation has expanded its suite of services and now provides them on five continents. In its steadfast pursuit of operational excellence in every endeavour, Precision has emerged in this, a new millennium, as a strong and tenacious competitor.
    [Show full text]