OTC-27533-MS

Strengths and Weaknesses in the HP/HT Design Verification Process within

Gulf of Mexico

Harish Patel, Jing Ji, Satya Meruva, and Jessie Lin, ABS

Copyright 2017, Offshore Technology Conference

This paper was prepared for presentation at the Offshore Technology Conference held in Houston, Texas, USA, 1–4 May 2017.

This paper was selected for presentation by an OTC program committee following review of information contained in an abstract submitted by the author(s). Contents of
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Abstract
Technology advancements applied to the design of high-pressure, high-temperature (HP/HT) equipment
for offshore drilling and production during recent years has increased. Now being manufactured, installed
and operated on producing wells in the Gulf of Mexico (GOM), this HP/HT equipment has enabled the
development of fields that were previously considered to be unviable. Regulations require an independent
third party (I3P) verification process to be conducted on HP/HT equipment. The verification process
is to assure conformance with applicable industry codes and standards. The mandated verification and
validation raises some questions: What can be learned by these processes? Are there opportunities for design
improvements in any of the HP/HT equipment?
The industry is learning how to apply advanced analysis methods which are based on the American
Society of Mechanical Engineers (ASME) Section VIII, Division 3 methods for pressure vessels. These
advanced methods require detailed equipment design verification. Regulatory officials and operators alike
need assurance that the technology qualification process addresses all of the appropriate failure modes.
Likewise, are hazards associated with these HP/HT operations fully identified and mitigated by appropriate
procedures? Are the design analyses performed accurate, complete, and do they provide a high degree of
confidence for each stakeholder?
In the text of this paper, details on how the appropriate verification process is being applied to each of the
various HP/HT equipment systems are discussed. The paper will detail a list of common issues that have
arisen, and describe how each has been addressed. The actions being taken to assist the offshore industry
with a verification process to fully comply with the intent of several applicable design codes are addressed.
It will also show how the identified risks are being addressed during verification. These descriptions will
assist in creating focused discussions with subsequent improvements for HP/HT environments and new,
advanced technology for future HP/HT equipment being applied.
The views expressed in this paper are of the authors in their individual capacities and do not reflect the
positions or opinions of the authors' employer – American Bureau of Shipping (ABS).
2 OTC-27533-MS

Introduction
As high pressure high temperature projects (HP/HT) progress and move into operations, the industry
attempts to keep up to date with applicable codes and standards to assist in properly verifying associated
equipment. In the Gulf of Mexico (GOM), HP/HT equipment design is mandated by BSEE to be verified
by an independent third party (I3P). The industry is yet to finalize the appropriate codes and standards that
completely encompass the guidance of verifying HP/HT equipment design. This paper will detail the I3P
design verification process within GOM along with discussions on the lessons learned of the implemented
process.
In HP/HT environments, the conditions demand for higher structural load capacity, fatigue sensitive
design and higher reliability for the equipment being designed. These conditions have pushed traditional
subsea design practices used in current API standards and specifications (6 series, 16 series, and 17
series, etc.) to theoretical limits and beyond. The model assumptions at HP/HT are increasingly challenged
in predicting failure modes. In addition, the design ratings of the equipment has pushed manufacturing
processes and material mechanical properties beyond previously accepted limits to meet new HP/HT
conditions and predicted loads while resisting aggressive corrosive environments.
Due to the new HP/HT design conditions, the critical equipment failure mode that needs attention is
fatigue and related fast fracture. As a result of all these changes, a more rigorous and in-depth stress analysis
and material selection is necessary to address additional failure modes which are not considered in existing
codes and standards that the industry uses. Simultaneously, the elevated design temperatures have decreased
margins for the steel's strength and has higher susceptibility to corrosion related failures. For more discussion
on fatigue, refer to referenced OTC paper (Satya Meruva H. P., 2017).
Consequences of failure in offshore HP/HT environments are extremely high and due to this reason,
regulators such as the Bureau of Safety and Environmental Enforcement (BSEE) in the US GOM has
developed regulation/guidelines for HP/HT offshore oil and gas exploration and production. They have
published the draft guidance notes, "Guidance on Obtaining BSEE Approval to Implement a High Pressure
and/or High Temperature Project in the Conceptual and Final DWOP" to assist operators in developing those
HP/HT resources. All operators who are working in the GOM are required to comply with these guidelines.
BSEE regulation require operators to appoint an Independent Third Party (I3P) to independently review the
design of various equipment and submit reports to BSEE for acceptance. This process is similar in scope to
Technology Qualification (TQ), which is applied for the development of new technology/equipment where
there are no clear codes/standards or regulatory requirements to confirm safety. For more information on
BSEE guidance notes, refer to referenced BSEE document ((BSEE), 2016).
As these regulations and processes are new to existing industry practices, all involved parties will go
through a learning curve and improve the overall process. As an independent class society, our company
has been involved in many TQ projects in a variety of applications and can assist the oil and gas industry
to achieve the goal of compliance with the newly established regulatory requirement while simultaneously
developing confidence in all parties involved to achieve safe field development offshore for HP/HT
discoveries.
The recent increase in interest in HP/HT reservoir exploration in the GOM has prompted all concerned
parties to look into the possibilities and challenges associated with offshore HP/HT drilling, completions,
and production. Of the several challenges of HP/HT drilling, this paper will focus on the challenges,
particularly strengths and weaknesses in the HP/HT Design Verification Process within GOM for the
intended design.

Design Verification Process in GOM for HP/HT System and Equipment

As per API TR 1PER15K-1 and Q1, each new product model should go through a design verification
analysis to confirm that the design meets the requirements specified in the technical specification. If the
OTC-27533-MS 3

environment and/or application changes for a product model, the design verification process should be
repeated to verify conformance to the new requirements. The design verification analysis should be reviewed
and verified by a qualified individual(s) other than the individual(s) who did the original analysis. Typically
this is done within the company and there is no independent outside verification carried out unless demanded
by a regulator or equipment user/owner. In GOM, BSEE demands that an I3P performs verification for each
HP/HT equipment as detailed in their TAS document. The design verification process is shown in Fig. 1
– GOM HP/HT Design Verification.

Figure 1—HP/HT Regulatory Design Verification Process

The significance of design verification is to gain better confidence in the new technology/equipment
design and its ability to meet all stakeholder safety goals. Per API TR 17TR8 and API TR 1PER15K-1, the
TQ process is defined as a combination of design verification and design validation:
Qualification is process of validation and verification that the technology will function safely within
specified limits with all risk identified.

Qualification = Risk reduction through risk study (e.g. HAZID/HAZOP/FMECA) + Design

Verification + Validation Testing

Verification is to confirm that the HP/HT equipment design or development activity is in compliance
with its functional specifications and there is adequate protection against failure modes identified.
Validation is to demonstrate that the equipment meets the mechanical integrity and functionality/
operability requirements as per the functional/design specifications.
When designing existing equipment, manufacturers perform verification and validation in accordance
with applicable standards and codes. For new unproven HP/HT equipment, a higher level of Verification
and Validation (V&V) is necessary since the most applicable codes and standards have limitations due to
various reasons.
Few of those reasons are:

• Failure modes differ due to extreme loadings

• Need for lower safety margin due to weight, manufacturing constraints, space availability, etc.

• Material uncertainty in exposed HP/HT environments at higher pressure and loading.

• Uncertainty in performance of equipment

• Additional failure modes require design methods which are new to the industry
4 OTC-27533-MS

• Major need for clarity when establishing the correct design margins to adequately assess the
combined equipment loading conditions as well as clarity on the details of what design standards
to follow
Due to HP/HT conditions, the pressure containing elements of equipment are also being stretched beyond
their limits. The required redesigns and major material upgrades of the equipment also require verification
through the new advanced analysis techniques and validation through expanded testing. Establishing
reliability is key to validating these new designs in HP/HT conditions. Simultaneously, due to these
same considerations, the pressure controlling components of HP/HT equipment are also being called into
question. Those limiting aspects of the current equipment designs must be redesigned and rigorously tested
since they will require major modifications to both design and material selection. Their seal reliability needs
further review since the elastomers will have to be totally redesigned in order to be effective under these
new HP/HT conditions to meet specified reliability targets.
Due to all of these ongoing issues in design and manufacturing of new HP/HT equipment, a systematic
technology qualification is needed for HP/HT equipment. TQ process is a method for providing evidence
that equipment will function within specified operational limits and with an acceptable level of confidence.
Figure 2 and Figure 3 below show the overall TQ process along with American Society of Mechanical
Engineers (ASME) code application to HP/HT equipment design verification and validation process.

Figure 2—Design verification and validation of equipment

OTC-27533-MS 5

Figure 3—Design verification associated codes with ASME Section VIII, Division 3

The design verification process focuses on the analytical methods to achieve design verification by
calculating the performance limits of a design (system, subsystems, and components), including its service
life, material selection and identification of potential failure modes. The design validation process focuses
on evaluating the effects/consequences of the failures and defining the appropriate test methods to evaluate
the reliability of the equipment against the identified failure modes including validation of material
performance. The material selection process includes defining the input parameters for the verification
process as well as the recommended procedures necessary to evaluate the material fitness-for-service in the
proposed environment.
For HP/HT equipment design, verification design check is performed by using ASME B&PV Code
Section VIII, Div. II and Div. III. Analysis process is shown in Figure 3. Key aspects per ASME are to
validate the computational model for proper design verification. These activity involves numerous steps
to have proper design verification. As per ASME V&V 10, "Guide for Verification and Validation in
Computational Solid Mechanics", as shown in Figure 4. It is important to understand that the computational
model need to be validated by physical testing and model calibration needs to be performed based on actual
test results to gain confidence in model for design.
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Figure 4—–ASME V&V Model Courtesy of ASME B&PV (ASME, 2015)

For more discussion about design challenges, refer to referenced OTC paper (Patel, Ji, Lin, & Bruton,
2016).

Risk Studies
Risk assessments and reliability studies form an integral part of the TQ process to assess hazards related to
introduced technology and the ability of the system to reliably meet its functional requirements and defined
goals. They supplement any existing prescriptive requirements and help verify that all the potential risks
have been identified and to confirm that appropriate mitigation measures are provided. Figure 5 below
presents the typical risk and reliability studies for TQ of HP/HT equipment and systems and any additional
technologies associated with HP/HT projects.

Figure 5—Typical Risk and Reliability Studies for HP/HT System

OTC-27533-MS 7

The potential failure modes related to HP/HT equipment and system along with corresponding failure
mechanisms and consequences need to be identified along with an evaluation of the failure criticality.
This is accomplished by means of FMECA/FMEA studies applied at different levels, namely functional,
procedural, and component levels as required. A functional-level FMECA is carried out with the entire
HP/HT drilling, completion, production and intervention system as the scope of study and component
level FMECAs are conducted for individual equipment. FMEA study will verify that no single failure of
component or within the system can lead to a hazardous situation with potential for injury to persons, damage
to facility, or environmental damage. The Technology Readiness Level (TRL) as defined in API RP17N
can also be assessed during the study to gauge equipment readiness for application.
Based on experience gained most manufacturers/designers who are involved in HP/HT product
development are proposing or performing FMECA studies for their equipment, to satisfy design verification
process. FMECA is somewhat new to this industry and some vendors are learning and some are very
familiar. FMECA is a very good tool in identifying failure modes but it has its own limitations and
drawbacks. FMEA is a design review tool and does not by itself eliminate failure modes or related effects. It
is important that the FMECA study is done properly and that all involved parties understand their limitations.
Some limitations are:

• Only as good as the team member • Detailed analysis is necessary for FMEA
∘ Not including suppliers
∘ Not Including experienced operators,
• Controls are not tested adequately and credit
taken
customer
• Bias towards assuming controls are better
• Unknowns are still unknown
• Assuming controls apply when they don't
• Bias toward severity ratings
• Failing to update the FMEA
• Not defining scope correctly
• Forgetting there are Internal- and External-
• If FMEA is not started at the design stage, its Related Failure Modes
effectiveness is weakened

BSEE Expectations
BSEE has requested that all HP/HT equipment design and prototype testing be reviewed by an I3P party.
These requirements and requests are applicable to any HP/HT equipment that is being manufactured and
used in the GOM. The BSEE TAS Guidance notes is the document that is being used currently to move
forward with HP/HT projects. As the document is a draft version, BSEE is open to discussion on feedback
from the industry on how to efficiently and effectively perform I3P design verification and validation.
((BSEE), 2016)
The guidance notes outlines how the verification and validation process must be applied to each
categorized equipment for each involved party. The categorization will be up to the operator with input from
supplier and I3P. The categorization structure is as follows:
8 OTC-27533-MS

Figure 6—HP/HT Equipment Categorization per BSEE HP/HT Guidance

The expectation from BSEE is that all new technology which is outside of the current standards limit
needs to be reviewed by I3P.
I3P is to review design verification and validation proposed by client and generate reports as describe in
BSEE TAS document. Basic duty of I3P include review of:

• Basis of design summary

• Design verification analysis

• Review of risk studies

• Material selection and qualification

• Review and of design validation plan and witness validation testing

• Review of manufacturing and quality plan

• Generate 1A through 1G report

Strengths of the Design Verification Process

As stated above, typically verification is performed internally by the manufacturer unless demanded by
operator/buyer or regulation. This is perfectly acceptable per applicable API codes. This process has its
strength and weaknesses. As this is a code requirement therefore manufacturers are expected to perform all
necessary verification checks in API Q1 requirements. This requirement alone forces the manufacturer to
invest time and money to make sure that they meet code mandated requirements. (Also, failure can lead to
loss of reputation and this process help them to reduce possibility of failure in actual application.) Process
also requires to document and maintain record of all verification activity performed. Current verification
process is the minimum specified by code regarding what manufacturers are required to perform and usually
work for known equipment very well.
I3P provides an added level of confidence to a project in many ways. The extra level of review that is
provided can assist in fine tuning all processes within the review path. The I3P can also assist in providing
the documentation required for all the BSEE requirements listed in the BSEE TAS Guidance document.
OTC-27533-MS 9

These reports must be generated with great detail and information for not only for documentation purposes
but also a clear understanding of the entire design methodology and process. The I3P typically is involved
in the codes and standards development committee that are directly applicable to HP/HT equipment such as
API and ASME codes and standards that develop the requirements for design verification and validation.
This enables the I3P to be in a unique position to provide guidance and insight on "how to" apply these
codes and standards on the projects involved. The I3P also plays a key role in understanding the concerns
of the operator and design manufacturer while working with the regulators to provide the best path forward.
Many I3Ps are also involved in Joint Industry Projects (JIPs) to progress research efforts for the industry
in this area. JIPs are extremely helpful during economically challenging times. It promotes the efforts of
sharing technical data from manufacturers/equipment designers, operators, and contractors similar to how
the codes and standards development committee function. These efforts can also help guide government
research and development activities for additional areas that need support. BSEE often conducts independent
research efforts to benefit the industry in understanding their requests however they may need input
regarding certain manufacturing and operating aspects. I3Ps can assist by providing their knowledge and
input for these research and development projects.
Another benefit to having I3P involvement is that they can participate in risk studies such as Failure
Mode Effects Criticality Analysis (FMECA), Hazard Identification (HAZID), and Hazard and Operability
Study (HAZOP) early in the design stages. This helps the designers confirm that the appropriate loads and
failure modes are evaluated for each component and assembly.

Weakness of the Design Verification Process

The self-verification process been working for quite long time in industry for all published coded and
standards. Sometime internal conflict can compromise intent of the system and will fail in achieving desired
goals. The process of verification is costly and time consuming for manufacturers; and not all necessary
steps been completed as stated in ASME V&V document. Often credit for past experience has been stretched
to take credit in verification, risk study etc. and there was no check against this practice. Also, there is
no independent check there for we have seen that verification process widely vary from manufacturer
to manufacturer and across regions. Sometime codes lack in clear guidance on how to perform proper
verification and that is one major gap in industry.
As the design of the equipment becomes more complex, current practices are not adequate. Typically
manufacturers will choose an economically beneficial standard or code that will satisfy minimum
requirements. Often times this means the standards chosen do not require risk studies or additional work.
Testing for validation failure modes activity has increased however still not widely practiced. Complex
model verification is often where major gaps are seen given the large safety margin. Due to past failures,
these practices have been questioned by various stakeholders. One such entity is BSEE in GOM and they
require that I3P be appointed and perform validation/verification. By bringing an outside entity to perform
certain duties for BSEE, the regulators can benefit by reducing bottlenecks for drill well approvals along
with gain confidence in the equipment design and operation of HP/HT projects.
Many manufacturers within the oil and gas industry have not previously engaged with an I3P for
reviewing design and validating their products. Often times, this is a new experience that may not be seen
as productive. The operator, manufacturer/designer, and I3P must meet to set roles and responsibilities prior
to working together. This basic culture of working together with an I3P must be addressed at the start of
project to progress work efficiently. Regulatory involvement can also be seen as a concern. The interaction,
communication, and direct involvement of key personnel of BSEE is a crucial portion of all parties being
on the same page.
Personnel involved must all be informed and familiar with the codes and standards requested by BSEE.
They must be informed of the intention and interests as well. Often times, certain parties are not familiar
10 OTC-27533-MS

with the certain new codes and standards that are being recommended to be used for the design of their
products. The lack of understanding of the BSEE expectations is a gap where I3P often has to inform them
of. The associated codes and standards are in itself not fully developed and clear. The gaps are where in lies
the weakness of designers picking and choosing which codes and standards to design to. The standards are
not specific for certain validation testing and this can be an issue for manufacturers to meet when unfamiliar
with newly expected codes for HP/HT application. These can cause concerns when the design verification
and validation process has already started for some manufacturers.
Some other potential issues that could be improved include:

• I3P Reviewer is unaware of changes in requirements, scope, approach/strategy, or schedule

• Operator fails to approve/update methodology

• Work is incomplete or incorrect

• Documentation is lacking (non-existent, incomplete, out-of-date, untraceable) or inconsistent in

content and format
• Multiple design iterations prolong review process

• Methodology is new / unfamiliar to one or more parties

• Analysis methods have not been validated

• Manufacturer does not follow own procedures and guidelines

• Sub-vendors do not follow established procedures and guidelines

• Personnel changes / lack of continuity

• Schedule conflicts / I3P reviewer falls behind schedule

Suggestions to Improve the Design Verification Process with I3P

Improvements have been seen and noted as the process and projects progress. Within the past year, an
increase in collaboration has been seen between operators, designers/manufacturers, I3P and regulatory
agencies. This improvement will only help facilitate the progression of key objectives within the industry. As
this process progresses, the need to keep this as a priority is always a constant. The communication between
all involved parties is the key to success. Along the same lines of communication, issue management and
establishment of processes are other items that must be addressed. As issues arise amongst the parties,
how are issues dealt with? These often become a concern without a process already laid out. Establishing
processes early on helps promote efficient progression of work. The best method of conducting all work
associated with minimal rework and delay is to plan ahead. Simple tasks such as defining the roles and
responsibilities, accountability, and who must be informed regarding all tasks associated with I3P can benefit
greatly.
Another example of a suggested improvement in the process is that post prototype testing results must
be utilized to calibrate verification design envelopes. The first round of design criteria envelopes must be
checked with post prototype testing data to assist in creating the accurate loads for design. This process may
not be thought of until late into the process in the event the planning phase is condensed to accommodate
production schedules. This is a key item to note as the I3P process continues to work with manufactures
in the design of their HP/HT products.
Streamlining documentation from manufacturers is an improvement area that as projects progress will
need some attention. The documents arriving from the manufacturer are quite intensive and a meticulous
tracking system must be implemented to track and progress deliverables. The documents must also be
maintained to ensure all versions are up to date. Incidents have occurred where multiple versions of the
OTC-27533-MS 11

same document have been sent without notice. Other times, the document is reviewed however an updated
version exists but was not sent to the I3P. These are all issues that can be addressed quickly and efficiently
if discussed up front and early in the process.
These items mentioned are a few of the suggested improvements from the I3P perspective for general
feedback. A few more specific suggestions for the manufacturing side include:

• Develop and agree to V&V plans early (materials and equipment)

• Submit only proven designs and complete work for the I3P to review

• Provide adequate time for reviews to take place

• Provide necessary administrative assistance to the I3P in terms of document retrieval, document
control, etc.
• Create a master equipment and materials list up-front

• Listing requirements for review and supporting documentation

• Maintain independent nature of the review but include I3P reviewer in design kick off meetings,
reviews, etc.

◦ This helps familiarize the reviewer with the equipment and keep up with design changes

These are suggested areas of improvement that have been encountered within the past two years. These
suggestions are a work in progress as all involved parties are climbing the learning curve. These are best to
be documented to assist future processes, parties involved, and work.

Summary
HP/HT projects are an emerging topic for scope of work in the GOM. The newly requested regulations have
introduced this new process of I3P reviewing design verification and validation. Many parties involved have
moved into the operational phase of the process and at this point have identified strengths, weaknesses, and
lessons learned to improve the process. The overall strength of having an I3P involved is that another set of
eyes are assigned to review the design work of associated equipment. This often times can be cumbersome
when reviewing mass amounts of data however ultimately it brings a level of review to assist in turning
every stone in the design aspect. The goal is to provide a proven reliable design that can be safely used in
the field during operations.
The weaknesses such as lack of communication, incomplete codes and standards, lack of appropriate
involvement of key participants, limitations in resources both financially and personnel wise, and unfamiliar
design methodologies are all issues that over time will improve. It is important to note these weaknesses
and gaps to assist in applying them to future processes and work. The lessons learned with suggested
improvements are intended to assist the industry in increasing activities in HP/HT environments.

Acknowledgements
The authors would also like to thank the management and technical staff of ABS for permission to publish
this paper and for providing a constructive critique of its contents.
The views expressed in this paper are of the authors in their individual capacities and do not reflect the
positions or opinions of the authors' employer – American Bureau of Shipping (ABS).

Abbreviations
ABS American Bureau of Shipping
API American Petroleum Institute
12 OTC-27533-MS

ASME American Society of Mechanical Engineers

BSEE Bureau of Safety and Environmental Enforcement
FMECA Failure Modes, Effects and Criticality Analysis
GOM Gulf of Mexico
HP/HT High Pressure High Temperature
I3P Independent Third Party
JIPs Joint Industry Projects
TQ Technology Qualification
V&V Verification &Validation

Applicable Codes and Standards

 API 6A – Wellhead and Christmas Tree Equipment
API 16A – Specification for Drill-Through Equipment
API 16C – Choke and Kill Equipment
API 17D – Subsea Wellhead and Tree Equipment
API 17TR8 – High-Pressure High-Temperature Design Guidelines
American Society of Mechanical Engineers ASME Section VIII, Division 3

Works Cited
(BSEE), R. H. (2016). Guidance on Submitting a Conceptual Plan (CDWOP) and Deepwater Operations Plan (DWOP)
to Obtain BSEE Approval to Implement a High Pressure and/or High Temperature Project. Houston: Bureau of Safety
and Environmental Enforcement.
ASME. (2015). 2015 ASME Boiler & Pressure Vessel Code-Section VIII - Pressure Vessels. ASME International.
H. Patel, J. B. (2015). OTC-25974-MS Systematic Technology Qualification for HPHT Subsea BOP Stack Equipment and
System to Improve Safety, Reliability, and Availability. Houston: Offshore Technology Conference.
Patel, H. N., Ji, J., Lin, J., & Bruton, J. (2016). OTC-27262-MS Lessons Learned from HPHT Equipment Verification and
Validation Process. American Bureau of Shipping. Houston: Offshore Technology Conference.
Satya Meruva, H. P. (2016). OTC-27266-MS Challenges in Material Selection and its Qualification for use in HPHT
Environments for Drilling Equipment. Houston: Offshore Technology Conference.
Satya Meruva, H. P. (2017). Adequate Fatigue Design for HPHT. Houston: Offshore Technology Conference.