1. API 17 – Subsea HPHT Discussion HPHT Design Materials Design Performance Test 1 Design Methodology has been in review and development for 5+ years and relies on ASME BPVC, Section VIII, Division 2 or 3. – But no clear guidance when/where to switch from Div 2 – “Thin wall” to Div 3 – “Fracture Mech.” No industry (operator) guidance on Validation Testing. – What constitutes “acceptance”? Is it Annex F or something tied to fatigue life/fracture mechanics? Material Properties for pressure containing and pressure controlling components showing clarity on what’s needed in last 2 years. – But no data on material ‘s HPHT properties published for widespread use. – No clear path yet on seal technology. PER 15K : “… should be used as a guide by the various API Subcommittees to develop future documents on equipment specifications for HPHT service. This report is not intended to replace existing API equipment specifications. … intended to illustrate accepted practices and principles that may be considered…”

2. Elastic vs. Elastic-Plastic The question: How do we balance between 6A which has 20k and 350 and 17D which has 15k and 350? Most agree that for HPHT, E-P or Load-Limit + FAD (fracture mechanics) is way to go. The question: When do we switch?

3. Validation Testing The question: When is Annex F testing is no longer valid? Is Annex F only valid for elastic design / functional testing? What level of testing is desired when fatigue design life is identified?

4. Materials Issues What pressure containing/controlling properties need to be met? Tensile, Yield, modulus @ elevated temperatures Tensile/yield ratio da/dn @ temperature & environment K1C, J1C, K1SCC for ranking Fatigue life at temperature Affect of cathodic protection - hydrogen Seals - creep resistance Fasteners - stress relaxation Main material use groups for HPHT Pressure Containing Pressure controlling Fasteners Seals

5. API 17 – Subsea HPHT Discussion HPHT Design Materials Design Performance Test 5 30 CFR 250.807(a), if you plan to install subsurface safety valves (SSSV) and related equipment in an HPHT environment, you must submit detailed information (APD, APM, DWOP) that demonstrates that the SSSV’s and related equipment are capable of performing in the applicable HPHT environment. 30 CFR 250.807(b) HPHT environment means the completion of the well requires completion equipment or well control equipment an assigned pressure rating greater than 15,000 pounds per square inch gauge (psig) or a temperature rating greater than 350 degrees Fahrenheit. 30 CFR 250.807(c), related equipment includes wellheads, tubing heads, tubulars, packers, threaded connections, seals, seal assemblies, production trees, chokes, well control equipment, and any other equipment that will be exposed to the HPHT environment. We’ve been at it for 5+ years How much time do we have left? When do we need 17TR8? When do we need to update 17D?

6. API 17 – Subsea HPHT Discussion HPHT Design Materials Design Performance Test Purpose of discussion: 1.Where we are with PER 15K and what it is and is not 2.Discuss where 17TR8 task group is and its current challenges Talking Points: – Immediacy – 30CFR 250.807 requires industry analysis for >15k or 350F – Methodology suggested by ASME BPVC, but disagree on when to invoke – List of material (metals) properties are gelling but no data available – No guidance as yet on seal technology and their material properties – No guidance as yet on Validation Testing. Manufacturers reluctant to come up with solid R&D schedules and scope if they don’t know what will be accepted. How have Operators adapted qualification processes to project requirements and timelines?

7. HPHT Issues HPHT Design Materials Design Performance Test 7 GoM Lessees and lease operators planning completions of HPHT wells requiring completion and well control equipment with RWP > 15,000 psig. Current API design standards do not address subsea equipment with RWP > 15,000 psig or surface equipment > 20,000 psig. Technical advancements evolve to fill a need and generally precede the development of engineering standards. It is not the intention of BOEMRE to attempt to create design standards but rather to point to existing standards that address design methodologies and failure modes for HPHT equipment design. It is not the intention to hinder technical development, but BOEMRE will take a conservative approach to approving the use of HPHT completion and related equipment until applicable standards catch up with technical development. Draft NTL 263 on HPHT

8. We are not aligned with Brian on application of PER-15K and/or API 6A approach for 20K tree systems. Brian feels it is time to make a clean break, and start using the fracture mechanics approach. Conversely, we feel there is merit in using the classical 6A approach for 20K and temperatures 250 F and lower, including water injection. BOMRE requires the operator to define the approach/code to be used (30CFR – 250.807) for anything over 15ksi or 350F. This doesn’t necessarily mean PER-15K approach. I am concerned about the timing required to get consensus on a PER-15K approach for subsea tree systems. I envision very new and different specifications for a fracture mechanics approach, that perhaps impact everything from raw material processing to product qualification, and everything in between. It could easily take several years to write and develop a specification and get it balloted. We did agree that it would not be a good idea to let the manufactures lead this initiative. There’s too much risk that the operators wouldn’t buy in to the proposal. That means the operators (maybe Shell and bp in this case) need to find resources to take the lead on whatever approach (could be a combination of both) for a “greater than 15K” specification. I personally believe that for the 20K applications I see on the horizon, the “classical 6A” approach is the only approach that could fit the likely timeline. In any event, we need to make management aware of the urgency of committing resources to address this issue.