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6 Summary of Recommendations
Pages 125-132

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From page 125...
... New regulatory action would be guided not only by the statutory requirement to determine which best available and safest technology options meet an economic feasibility hurdle. But also by working within the standards development process, by promulgating new regulations to supplement standards, or by requesting statutory changes.1 1    ureau of Safety and Environmental Enforcement, "Statutory Requirements of OCSLA Regarding B the Use of BAST," https://www.bsee.gov/what-we-do/regulatory-safety-programs/statutory-requirements, accessed November 13, 2017.
From page 126...
... In dustry should have a large role in determining the priority for addressing potential improvements. The roadmap could be divided into several sections: • Investigate bolting cluster failures using a large-scale fully instrumented flange test rig that simulates subsea conditions on fasteners in bolted joints including structural loads, environmental conditions and cathodic protection.
From page 127...
... (Appendix J lists some alternative bolt pre-tensioning methods.) • Consider commissioning engineering design studies to determine realistic tension loading safety margins for flange bolts.
From page 128...
... Option 2.6: BSEE could take steps to incorporate the following API specifications and recommended practices, (in total or in part) into CFR 30 section 250 by refer ence to ensure that the best known maintenance practices are instituted: • API Spec 16F, "Specification for Marine Drilling Riser Equipment" • API RP 17G, "Recommended Practice for Completion/Worker Risers" • API RP 16Q, "Recommended Practice for Design, Selection, Operation and Maintenance of Marine Drilling Riser Systems" Recommendation 2.7: The oil and gas industry should establish a comprehen sive methodology and or program to optimize the cathodic protection (CP)
From page 129...
... Option 2.9: The committee suggests that cluster failures be investigated by BSEE in large-scale fully instrumented flange test rig that simulates subsea conditions on fasteners in bolted joints including structural loads, environmental conditions, and cathodic polarization. These investigations are necessary to definitively estab lish the origins of these cluster failures and to prove the effectiveness of mitigation strategies.
From page 130...
... Option 3.3: Safety critical standards and specifications could be enforced by BSEE throughout the supply chain by incorporation of such standards into the Code of Federal Regulations. Option 3.4: The committee agrees with the BSEE 2016 QC-FIT report, Evaluation of Fastener Failures Addendum that recommended that all bolts used in critical service in US OCS waters shall be manufactured by organizations that main tain sufficient quality certifications.3 BSEE could consider fully implementing this recommendation.
From page 131...
... BSEE, using the recommendations of the consortium, could also initiate research and development efforts for those innovations that may offer considerable safety advantages but are not currently available as products or systems. Two recent BSEE Quality Control-Failure Incident Team (QC-FIT)
From page 132...
... The review should also include a comprehensive analysis of manufacturing best practices and environmental service conditions for subsea fasteners. 2016 BSEE should consider incorporating API Spec 20E First Edition, 3.1 August 2012 "Alloy and Carbon Steel Bolting for Use in the Petroleum and Natural Gas Industry" into regulations to provide consistency in material property requirements for use of subsea fasteners on the OCS.


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