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SPE 147904

Risk Based Management of Hydrocarbon Sub-Sea Pipeline Free Spans


Christopher B. White, Dhian Ekawati and Ria Kartika, ExxonMobil Oil Indonesia Inc.

Copyright 2011, Society of Petroleum Engineers

This paper was prepared for presentation at the SPE Asia Pacific Oil and Gas Conference and Exhibition held in Jakarta, Indonesia, 20–22 September 2011.

This paper was selected for presentation by an SPE program committee following review of information contained in an abstract submitted by the author(s). Contents of the paper have not been
reviewed by the Society of Petroleum Engineers and are subject to correction by the author(s). The material does not necessarily reflect any position of the Society of Petroleum Engineers, its
officers, or members. Electronic reproduction, distribution, or storage of any part of this paper without the written consent of the Society of Petroleum Engineers is prohibited. Permission to
reproduce in print is restricted to an abstract of not more than 300 words; illustrations may not be copied. The abstract must contain conspicuous acknowledgment of SPE copyright.

Abstract
Sub-sea pipeline free spans occurring from inadequate seabed support can lead to static and vortex induced
loading which results in pipeline failure. At best, this could effectuate a small crack at overstressed welded field
joints, at worse, pipeline rupture. The latter may have significant safety, environmental and business impacts, and
as a consequence free span management is necessary for incident avoidance and operational reliability.

This paper describes a risk based approach to the management of multiple free spans that exist on the 30” gas
pipeline that traverses the Malacca Straits from the NSO-A offshore platform to the gas processing facility at PT
Arun, Aceh, northern Sumatra, Indonesia. It draws from an intensive data collection campaign and technical
assessment allowing characterization of exposure and tolerances. Remotely operated vehicle (ROV) and
Metocean surveys, together with Finite Element Analysis (FEA) conducted on more than one occasion since
pipeline commissioning in 1999, has provided the necessary base data inputs.

Pivotal to the analysis is utilization of industry best practices (in particular the DNV Recommended Practice F-105
Free Spanning Pipelines), together with risk assessment tools. Several dozen critical length spans have an
elevated risk of fatigue cracking due to duration exposure.

Span management recommendation identifies grout bag pipeline supports as being the most affective
remediation solution, amongst others considered.

The literature for actual case trial publications on sub-sea pipeline free span management is limited. This paper is
considered to contribute to the emerging understanding of static loading and vortex induced vibrations impacting
on the fatigue life of critical assets.
2 SPE 147904

INTRODUCTION

The 30” NSO-A pipeline is a weight coated carbon steel pipeline with a capacity of 467 mcfd, and design life 33
years. The dense concrete weight coat provides negative buoyancy and impact resistance. Installed in 1999, the
pipeline accounts for 70% of Aceh gas production, and is strategically located in the Malacca Straits. It transports
sour gas and condensate from an unmanned platform offshore to a sulphur recovery unit, and LNG plant at the
PT Arun facilities onshore.

ASEAN MALACCA
ACEH HUMPUSS
FERTILIZER P.T. PUPUK AROMATI
ISKANDAR MUDA
(PIM) NSO-A
NSO ONSHORE
30" SUBSEA
ARUN LNG GAS
PLANT

AAF
HOUSING

MALIKUSSALE PT. PIM


H HOUSING LHOKSEUMAW

PT. ARUN
HOUSING BUKIT
AREA INDAH
PANTON
PT. KERTAS
KRAFT CL-I SIMPANG
LANDIN
CL-II B.
PIPELINES
42” SEP. GAS A-13
20” INACTIVE POINT-A LHOK
16” RESIDUE GAS TO NAT. PROJECTS
16” POINT ‘B’ FUEL GAS
CL-III
10” CONDENSATE CL-IV
100
m
TO MEDAN
NSO
-A
30" GAS
NSO PIPELIN
Plant

50
ROAD ACEH m
SLS -
PIPELINE KUALA LUMPUR

SOUTH LHOK SUKON- „ SOUTH LHOK SUKON-


SU

SINGAPORE
SOUTH LHOK SUKON-D
M

KALIMANTAN
AT
AR

SULAWESI
PAPUA PASE - B 12" GAS
JAKARTA
JAVA
S.LHOK SUKON-B1 CLUSTER

·
EM OPERATED BLOCK

Aceh Production Operations

Multiple unsupported pipe lengths (free spans) 100 M


exist along the pipeline at locations where it does
not rest on the seabed. Free spans can result in
failure via static buckling and dynamic vibration. NSO-A 30” Pipeline (102 KM)
There are significant benefits in performing an ~50 - 90 m

engineering analysis, rather than rushing out and


rectifying spans unnecessarily, or adopting span
management strategies that will have little, if at
all any, affect in the long run. The costs associated with vessel, ROV and qualified workforce to execute repairs
based on a total free span count can be at best exorbitant, a citing case being data associated with this repair.
From an initial count of 1446 spans, only 44 ( or 3%) were deemed critical in terms of a “must repair” strategy.

Intensive data collection and technical assessments have allowed for a more focused analysis. Results from ROV
and Metocean surveys provide input to an increasingly complex fit for purpose evaluation, from basic span length
checks based on design criteria, through empirical relationships, to finite element analysis (FEA).
SPE 147904 3

30” NSO-A PIPELINE & ASSOCIATED FACILITIES

The pipeline is a longitudinal welded grade API 5L X65 pipe, nominal thickness 15.9 mm. It runs unburied along
the seabed at a depth of 110m of water, and distance 102 km from the NSO-A platform to the onshore Sulphur
Recovery Unit (SRU) at PT Arun LNG facility.

The platform is a four-leg jacket structure


designed to API RP 2A. It has 9 production wells
and separator/dyhydaration facilities to minimize
wet gas entry to pipeline. Continuous amine
inhibition provides added protection from internal
corrosion.The SRU relies on Sulfinol to strip the
incoming gas of H2S, and then a Claus Reactor
unit to remove elemental sulphur.

SPAN BEHAVIOUR CHARACTERISTICS

After commissioning in 1999, 164 grout bags were installed following an ROV survey. The positioning of the grout
bags was based on free span lengths calculated per the original pipeline design code. Further ROV surveys in
2005 and 2009 confirmed the free span count to vary, 503 versus 337 respectively. The assessment criteria on
that occasion was the original pipeline design code and/or the DNV Recommended Practice F 105 requirements
[Ref 1]. Spans Distribution - Repeatability
70

2006 Spans
60

Evidence emerged from the data that span


2010 Repeat Spans
50

behaviour was dynamic in nature and, as such,


# of Spans

40

due consideration had to be given to deciding 30


54
33 31

whether spans with such characteristics were 20


29
40
40

30

cause for concern. The chart illustrates the span 10 23


15 15 4

distribution over the assessment period 2006 6 4


1 3 2 2
0 0 0 0
NSO-A 10 20 30 40 50 60 70 80 90 100 NSO

and 2010. It would be a prudent judgement call Platform


Pipeline Traverse
Onshore

to conclude that spans that were dynamic in


nature, i.e. those that existed for relatively short periods of time, were not candidates for further analysis. More
importantly however, those spans that were repeat spans had exposed the pipeline to longer vortex induced
vibration (VIV) and static loading conditions. Repeat spans were therefore candidates for further analysis. These
spans appeared to be concentrated in a 20 km section of the pipeline, mid-way between platform and onshore
facility.
4 SPE 147904

FREE SPAN ANALYSIS

The following section details the free span assessment process. Conventional free span assessment consists of
comparing the actual span length to an allowable span length, determined by the shorter of either the calculated
Ultimate Limit State (ULS) limits, or the screening/onset lengths for VIV.

This approach is generally based on the assumption that spans can be idealized with simple end conditions,
resting on a flat seabed, and with a given pipe / seabed gap. Interacting spans are also modelled as resting on a
flat seabed. However, pinned-pinned end conditions are used to model the behavior of the spans as they interact
with one another [Ref 2], as a screening approach. For the analysis of this pipeline, the validity of this assumption
was verified by comparing the results of the L3 analysis with the level 2 (idealized) span lengths obtained with
pinned-pinned end
constraints. A more accurate approach is to consider axial loading, bending moment and other loads at each span
on a case by case basis (for static criterion), or determine the expected fatigue life of a span that may be
experiencing VIV, which is typically done using the most up to date DNV RP-F105 code [Ref 1], in the case of this
analysis, the 2006 edition.

The maximum allowable span length is location-specific due to variations in effective axial force, temperature
profiles, wave effects by changing depth, changes in coating thickness, weight coating, safety factors, soil type,
and pipeline directionality, among other environmental factors.

The approach adopted for the review of the NSO–A free spans follows a methodology accepted and used by
many operators, and described in DNV RP-F105, utilizing a 3-level approach to analysis, with analysis time and
complexity increasing at level 2 and Level 3 analysis. This methodology, as detailed in Reference 3, has been
reviewed, accepted and used by ExxonMobil on other pipeline analysis projects, including SYU Project 12” line in
offshore California, the Bass Strait pipelines - Australia (2008), and the Sable Project – Canada (2008).

The table below summarizes the criteria and methodology for the three levels of assessment. The flow charts that
follow, detail the logic sequence as applied to determine when the next, more complex, level of analysis is
required.
SPE 147904 5

Summary of Criteria and Methodology

Static Free Span Engineering Assessment


6 SPE 147904

VIV Free Span Engineering Assessment

LEVEL 1 FREE SPAN ASSESSMENT

Fatigue Limited Spans

A Level 1 fatigue free span assessment involves assessing the interactivity of all spans reported. Then the span
length is compared with allowable (design calculated) span length as follows:

• Single spans that are isolated on the seabed are screened by comparing span lengths with the allowable
span length derived for single spans (whichever is the governing length, in-line or cross-flow);
• Interacting spans are screened by comparing the effective lengths of an interacting span pair (or
multiples) with the derived allowable span lengths.

The allowable span length for fatigue limit is calculated based on 2 categories: screening fatigue criteria and
amplitude response model. For screening fatigue criterion, both of in-line and cross flow natural frequency design
condition below is required [based on section 2.3.3 and 2.3.4 of Ref.1]:
SPE 147904 7
8 SPE 147904

If a comparison between the actual and allowable span lengths reveals that the span is anomalous, a Level 2
fatigue analysis will be performed.

ULS Static Limited Spans

A Level 1 static free span assessment screens all spans based on allowable lengths governed by allowable
bending moments (BM) for static stress calculated using a simplified span model (these lengths are generally
determined at the pipeline design stage). There is no Level 2 assessment for static free spans; if the free span
exceeds the allowable length based on bending moment criterion (which assumes a straight beam model), a
detailed Level 3 analysis is required, or rectification may be
performed without any further engineering assessment.

Note: Level 1 assumes that allowable limits are applicable for a given KP region.

LEVEL 2 FREE SPAN ASSESSMENT

A Level 2 fatigue free span assessment screens those spans greater than the Level 1 allowable lengths based on
fatigue life criterion using a simplified response model. The Level 2 assessment considers each anomalous span
on an individual basis, by assessing the span length, its end conditions (whether it is interacting or not), and the
span gap (determined by assessing the average height over the centre 1/3 of the span (RP-F105 1.12.3 [Ref 1]),
based on the ROV seabed cross-profile depth data. If the remaining fatigue life is less than the required criteria (in
the case of this analysis, the design life of the pipeline + 10%) a more detailed Level 3 analysis is
required, which uses FEA to determine the expected natural frequencies (i.e., determination of the eigen values
and eigen vectors) of the span (or interacting spans).

For the acceptance criterion of fatigue life (Fatigue Limit State criteria), a 10% allowance is included to account for
potential fatigue damage in the temporary phases. For example for a pipeline with a desired 30 year fatigue life,
the Fatigue Limit State (FLS) criterion is set at 33 years.

Spans are deemed acceptable following Level 2 analysis provided:

• The calculated fatigue life exceeds the design life of the pipeline plus an additional 10% for temporary
phases; or
• The calculated fatigue life exceeds the exposure time (te), but is less than the total pipeline design life. In
these cases, spans are noted, and additional attention given to them during the next survey and analysis
period. The exposure time (te) is defined as the operating life of the pipeline to date (or since the span
was first detected), including the 10% allowance for temporary phases, plus the time to the next survey,
plus the time to the next inspection/rectification opportunity (considered as 2 years). Thus the exposure
time for this pipeline is 3 years (temporary phases) + 11 years (exposure time to date) + 2 years
(conservative time till next inspection/rectification opportunity) = 16 years

Note: Both Level 1 and 2 analyses are based on the assumption that the spans can be idealized as single-spans,
each resting on a flat seabed, and with a given pipe / seabed gap. If the span is outside the limits of applicability
of DNV RP-105, such as spans on a non-flat seabed, or where the length is greater than 140 times the diameter,
then the frequency response cannot be empirically determined, and FEA analysis is needed.

LEVEL 3 FREE SPAN ASSESSMENT

A Level 3 free span analysis individually assesses those spans not meeting the requirements of a Level 1 and 2
assessment using detailed three dimensional (3D) finite element (FE) modeling (ABAQUS software with JPKenny
Pipeline model). This methodology is used for VIV (dynamic) and Static / ULS assessments.

Following the approach recommended in DNV RP-F105, the FEA analysis is used to determine the expected
natural frequencies (i.e., determination of the eigen values and eigen vectors) of the span (or interacting spans)
and deflected shape of different vibration modes (normally called mode shapes). This approach follows RP-F105
(clause 6.5.2), and is particularly critical for interacting spans (clause 6.6.2). Clause 6.7.1 states that the
“Approximate response quantities are considered relevant in performing efficient screening of survey results in
order to identify critical spans to be assessed with methods that are more accurate” (i.e., Level 3 analysis).
SPE 147904 9

Note that the fatigue lives assessed in Level 2 are typically more conservative (shorter) due to its idealized and
simplified response model, than those derived using Level 3 analysis.

For spans exceeding the allowable length for static/ULS, a Level 3 assessment (ABAQUS FEA analysis) involves
the assessment of the bending moments for the spanning section of the pipeline (including sufficient lengths to
either side of the pipeline to remove any end-effects), taking into account the actual surveyed pipeline and seabed
profile from the ROV onboard data. For pipelines designed to a limit state code (ULS) such as DNV OS-F101 [Ref
4], the Static/ULS FEA analysis requires consideration of all dynamic and static load cases. For the NSO-A
Pipeline, design limit state (ULS) calculations were performed as needed on spans that did not meet the L1
allowable length static criteria.

SPAN INTERACTION

Span interaction (for fatigue limited spans) is checked during the level 1 assessment, using the span interaction
methodology given in RP-F105 [Ref 1]. A determination is made whether two or more adjacent free spans interact
when the pipeline undergoes VIV, and to thus assess these spans at Level 2 using modified end-constraints. The
sketches below illustrate a single span (non-interacting) vibrating case, and cases where two and three interacting
free spans vibrations occur.

Single Span

Two Interacting Spans

Three or More Interacting Spans


10 SPE 147904

FREE SPAN ANALYSIS OUTPUT


503 Freespan Analysis
525

2006 (1337 total spans)


425
372
337
2010 (1446 total spans)
As a result of intensive data collection and

# of Spans
325

extensive fatigue modelling since commissioning 225

in 1999, rationalization of spans of interest 125


146

occurred. The chart illustrates the distribution of 66


44

spans failing the Level 1, 2 and 3 assessment 25


Length Check Empirical Formula FEA Design Life FEA End of PSC

criteria. Increasing Analysis Accuracy

The discrepancy in count between the assessment


period 2006 and 2010 are primarily the result of
updated Metocean data, and to a large extent
the dynamic behaviour of some spans which, in
the latter inspection period, evolved as non-critical.
The pipeline has an average free span growth rate
of – 0.531 m/year, indicative of free spans shrinking
in length. However there is a range of different span changes as illustrated in the chart. With span growth being
almost equally offset by span shrinkage, a state of dynamic equilibrium in span length change may have been
attained.

Three levels of free span assessment have been completed for all detected free spans on NSO-A pipeline. This
analysis included Level 1 screening and interactivity check, Level 2 VIV analysis, and Level 3 Finite Element
Analysis.

The 2009 ROV surveys have detected 1446 free spans on the NSO-A pipeline. The table below shows the result
numbers of L1, L2, and L3 analysis of all spans in NSO–A pipeline.

\\

Note: 1) Includes 125m span at KP 55.61, which also fails ULS criteria, if found to be 125m long. 2) Assumes that
all 4 spans which appear to have intermediate touchdowns from the FEA analysis are actually the reported
lengths.

As can be seen in the table, some L2 failing spans are failing L3 (Finite Element Analysis) analysis also.
SPE 147904 11

FACTORS AFFECTING PIPELINE FATIGUE LIFE

Standard SN-curves are typically generated from dedicated laboratory test data, accepted fracture mechanics
theory, or DNV-RP-C203 “Fatigue Strength Analysis of Offshore Steel Structures” [Ref 5].

SN-curves have to be applicable to the material, construction detail, location of defects, and corrosive
environment. One other key contributor determining fatigue life in the case of sub-sea pipelines, is current.

Metocean data typically relies on representative current sampling along the length of pipeline. In the case of the
NSO-A 30”, four separate moorings, each with an upward and downward looking Workhorse Acoustic Doppler
Current Profiler (WH ADCP) were deployed to measure current speed and direction throughout the water column.
The locations of the moorings were at KP1 (platform end), KP33, KP63, and KP101 (shore end).

Further scrutiny of critical spans defined from a Level 3 assessment can be made based on the argument that the
Metocean current data may not be representative at the particular span in question. To illustrate the impact on
fatigue life as a function of current speed, the chart below highlights the effect of decreasing current. The lower
the current, the longer the fatigue life.

A business option clearly exits to conduct further sea current monitoring at critical spans failing Level 3
assessment, or which fail with the exposure time (te).
12 SPE 147904

RISK ANALYSIS

Having determined from the Level 3 assessment the number of critical spans of interest, an assessment of risk of
failure for each of the spans can be determined.

The assessment uses a risk matrix of probability and consequence to rank potential events in order to prioritise
targeted activities which will prevent those events from occurring. The assessed risk may be business, safety,
health, environment or security in nature.

The risk matrix is therefore one of the key tools

Probability Category
used to justify drivers for mitigative measures. A Higher

A variety of matrix formats exits, but the model B Medium Risk


captured in API 580 [Ref 6] provides the general C
layout and ranking common to all. Whether the
Lower Risk
matrix is a “5-by-5”, “4-by-4” configuration or D

where on the matrix risk is differentiated as high, E Risk

medium or low, is largely user driven. 5 4 3


Consequence Category
2 1

In order to avoid a subjective assessment of probability and consequence rating, a rule set is established for both
these components of risk.

In the case of probability, a Composite Probability Score aggregates a value assigned to key components
affecting the pipeline. Leveraging off DNV OS F101 [Ref 4], the components are summarized as follows:

Code Check: From DNV RP F105 (clause 2.6), safety factor 1.0 has been used as a result of span
characterization being very well defined, and safety class designated “low”. Score
increases when screening criteria fails Code with all partial safety factors at 1.0.

Analysis Complexity: The more complex the analysis is, viz Level 1 versus Level 3 assessment, the higher the
score.

Seabed Stability: The more dynamic the span lengths and locations, the higher the score.

Metocean Quality: The more understood the waves and sea currents are, the lower the score.

CP Effectiveness: The score ranges from low (CP very effective) to high (no CP).

Inspection History: The less inspection history, the higher the score.

Depending on the aggregate score, a probability rating can be assigned using the following guide:

Probability Aggregate Score

A 80 < CPS
B 60 < CPS ≤ 80
C 40 < CPS ≤ 60
D 20 < CPS ≤ 40
E 0 < CPS ≤ 20

Consequence assessment guidelines provide a Start

series of decision tree flow charts covering


events such as explosion, fire, toxicity, burns, Facility
Shutdown? N

environment, regulatory, and business. The


determination of the leak rate plays an
License
Req'm ent?
N

important role for SHES related exposure, Y


Internal

whilst the level of production loss will affect


Req'ment? N

the consequence ranking from an economic Y


Request
N

perspective.
Details &
Actions?

Y
No Report
No Consequence
Req'ment?
1 2 3 N

4 5
SPE 147904 13

The chart below shows typical data fields that would be populated for each span failing the Level 3 assessment.
Results are then converted to a risk ranking which provides the user the basis for determining when remedial
action should take place, and what mitigative measures in the interim can be initiated to ensure pipeline integrity.
CPS (Composite Probability Score) Consequence (Rupture/Crack)
Metocean Media Media
Analysis Seabed Inspection Probability Probability Public Margin
Code Check Complexity
Data CP Effectiveness Total Toxic Response Response Environmental
Stability History (Crack) (Rupture) Disruption Impact
Quality (Crack) (Rupture)

SPAN MANAGEMENT

A number of hardware solutions to manage the


critical spans were investigated, including grout
bags, rock dumping, and mass flow jetting.

Although all three techniques, or a combination


thereof, are common practice in industry, the
rock dumping and mass flow jetting options were
discounted for application on this pipeline.
Grout Bags Stabilization
Although mass flow jetting (the use of a forced
stream of seawater to lower the shoulder of the
span anchor point) is the cheaper option when
multiple spans need to be corrected, a prerequisite
pipe stress analysis assessment will be necessary
to determine whether any adverse loading of the
pipeline occurs.

Rock dumping is a relatively higher cost option, and


Mass Flow Jetting
requires tighter control during deployment.

The chart below illustrates a pipeline and seabed profile conducive to the use of the mass flow jetting technique.
The touch down point KP 55.74 would be the candidate focus location to lower the shoulder.

Grout Bag Performance


180
160 4
17
140
53

The performance of grout bags installed on this 120 49


# of Grout Bag

100
pipeline in 1999 has not been 100% reliable. 70% 80 164

remained in place in 2005, and an additional 6% 60


40
107 98

became ineffective in the period 2005-2009. 20


0
1999 2005 2009
Grout bags that were no longer supportive were Inspection Year
Supporting Non-Supporting Undetermined
indicative of settlement issues rather than a direct
result of the 2004 Tsunami, or other earthquake
related events. There was no evidence for any lateral movement of the bags relative to the pipeline, a feature you
would expect to see had earthquake activities been dominant.
14 SPE 147904

In order to ensure better performance of grout bags, the installation of scour mats, stringent QA/QC controls on
grout curing times and deployment location (s) on a span by span basis, will be necessary.

Grout bag location is critical and needs to consider span shape, allowable span length, and potential future span
growth. As a guide, the following should be considered:

• Grout bags should be offset from the center by at least 10% to prevent potential higher mode excitation
and free span interaction.
• No spans should be within 4m of the allowable length (to allow for some growth in the future before any
re-rectification is needed).
• If the above two are not satisfied, then two or more grout bags are recommended, with spacing between
them approximately – 3m the allowable length.
Lspan

Allows for at least


4m of span growth at
shoulder before
Lallow is exceeded
1/3Lspan < Lallow – 4m
Lallow – 3m

L2 L2
L2 ? (Lspan – (Lallow – 3m))/2

CONCLUSIONS

Investment in fatigue modelling and risk evaluation of free spans failing the Level 3 assessment has resulted in a
significant reduction in the number of spans that require management in order to avert integrity related issues.

The risk assessment tool is a powerful means of assessing both the consequence and probability of failure, thus
providing the necessary information to allow business decisions to be made.

The fatigue life is influenced by many parameters, one of which is the sea current. Further screening of candidate
free spans for rectification can be made by close to pipe current monitoring at the spans of interest.

There are a number of techniques available to manage spans exceeding the critical length. The use of grout bags
over other methods provides a non-intrusive conventional means of supporting spans. Critical to the success of
grout bags is tight QA/QC during deployment, and the installation of scour mats to prevent in-service subsidence
of the seabed around the grout bag.

Industry practice is to stabilize spans failing complex analysis, and the low incident rate of pipeline ruptures
attributed to static loading or VIV may well be the result of the implementation of span rectification work.
SPE 147904 15

ACKNOWLEGEMENTS

The authors appreciate management support from ExxonMobil Oil Indonesia Inc. in allowing this paper to be
prepared and presented at this conference. Particular thanks to the Corrosion and Integrity Group for having the
insight to fund projects that allowed intensive data collection, and technical assessments to be made.

REFERENCES

1. DNV, 2006, Free Spanning Pipelines, RP-F105


2. Kristiansen, N.O., Tornes, K., Nystrom, P.R., and Damsleth, P., 1998. Structural Modelling of Multi-
Span Pipe Configurations Subjected to Vortex Induced Vibrations
3. JP Kenny, “Simulator Engineering Software User Guide for FE Span Analysis”, Rev.01, Feb 2008,
Doc.No. 85133.02-03-P-TN-001
4. DNV, 2000. Submarine Pipeline Systems, Offshore Standard OS-F101
5. DNV, 2010. Fatigue Strength Analysis of Offshore Steel Structures, RP-C203
6. API, 2009. Risk Based Inspection, RP 580

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