API SC 6 SUBCOMMITTEE ON VALVE AND WELLHEAD EQUIPMENT TASK/WORK GROUP STATUS REPORT API RP14H 15 MAY 2011 TABLE OF CONTENTS 1. SCOPE OF WORK & BACKGROUND... 1-1 2. PREVIOUS STATUS REPORT DATE... 2-2 3. MEMBERSHIP... 3-2 4. MAJOR ISSUES AND DATES... 4-2 5. FUTURE WORK PROGRAM... 5-3 6. FUTURE MEETINGS DATES... 6-3 7. RESOURCE NEEDS... 7-3 1. SCOPE OF WORK & BACKGROUND API RP 14H was last revised in 2007. According to S1, it is due for re-affirmation in 2012. The TG was convened to determine if changes should be made to the document prior to re-affirmation. The document is currently referenced in the CFR [30CFR250.802 (d) and 30CFR250.804 (a)(5)]; 250.802 Design, installation, and operation of surface production-safety systems. (d) Use of SSV's and USV's. All SSVs and USVs must be inspected, installed, maintained, and tested in accordance with API RP 14H, Recommended Practice for Installation, Maintenance, and Repair of Surface Safety Valves and Underwater Safety Valves Offshore (incorporated by reference as specified in Sec. 250.198). If any SSV or USV does not operate properly or if any fluid flow is observed during the leakage test, the valve shall be repaired or replaced. 250.804 Production safety-system testing and records. (4) All SSV's and USV's shall be tested for operation and for leakage at least once each calendar month, but at no time shall more than 6 weeks elapse between tests. The testing shall be in accordance with the test procedures specified in API RP 14H. If the SSV or USV does not operate properly or if any fluid flow is observed during the leakage test, the valve shall be repaired or replaced. -1-27-Jun-07
2. PREVIOUS STATUS REPORT DATE None 3. MEMBERSHIP Name Company E-mail Austin Freeman (chair) Halliburton austin.freeman@halliburton.com David Comeaux GE david.comeaux@ge.com Henry Wong FMC Henry.wong@fmcti.com Jim Brinkley WoodGroup Jim.brinkley@woodgroup.com Darine Aghnim Lamons Darine.aghnim@lamons.com Sterling Lewis* Exxon sterling.f.lewis@exxonmobil.com Mahesh Udipi* GE Oil & Gas mahesha.udipi@ge.com Dennis Kaminski* BP Dennis.Kaminski@bp.com David Pang* Doris, Inc davidpang2004@yahoo.com *Not present at TG meeting 4. MAJOR ISSUES AND DATES The taskgroup met on May 11 hosted by Lamons. We reviewed the document including the reference in the CFR. Key findings and questions were the following: 1. Should the title of the document be changed from Recommended Practice (RP) to Standard for safety purposes to prevent confusion in application of the document? It was noted the API RP53 on Well Control was changed from RP to Standard at the last revision. 2. In the Scope section, rewording is suggested since there are several repetitions in 1.2 and 1.3. 3. The document does not have a Normative references section and 6A appears to be normatively referenced. 4. There are no references to the CFR. Should there be? 5. Many uses of the word should when what we really mean is shall in many cases. o Section 4 (Installation and Maintenance) o Section 5 (Repair) 6. Leakage rates mentioned are not consistent with CFR requirements. 7. Appendix A contains a typo on page 11; 261.1 should be 267.1 8. When two or more valves are present, some regulators (such as Norwegian PSA) require independent testing. Do we want to include this situation? 9. Repair may need distinction between field vs. shop repairs to be consistent with 6A. 10. In section 6 (Testing Procedures), suggest to have the operator go back to the operating manual and follow its procedures at every stage. Valve testing should be included in the operator manual and have acceptance criteria. Could consider adding ultrasonic leakage test option. -2-27-Jun-07
11. In section 7 (Failure Reporting) and 8 (Documentation Requirements) we questioned whether or not failure reporting actually happens and who does it. Forms were seen of little value. Web application might be more useful. 5. FUTURE WORK PROGRAM The TG recommends the document be opened for editing. An SR3 form is attached for SC6 voting. 6. FUTURE MEETINGS DATES None planned pending SC6 action on SR3. 7. RESOURCE NEEDS For the TG to function effectively, an operator presence is required. David Comeaux is willing to lead the TG if a re-write is required. Potential SR3 form below: Prepared by: Austin Freeman, D.E., P.E. -3-27-Jun-07
Document Information Standard Designation: Title: Edition: 14H Recommended Practice for Installation, Maintenance and Repair of Surface Safety Valves and Underwater Safety Valves Offshore 5 th edition Budget Year: 2011-2012 Committee / Subcommittee: Priority Matrix Ranking: (to be completed by API) Proposed Action: SC2 SC5 SC6 X SC8 SC10 SC11 SC13 SC15 SC16 SC17 SC18 SC19 SC20 ECS Class 1 (Rank 11-15) Class 2 (Rank 6-10) Class 3 (Rank 1-5) New Standard X Revise Current Standard Withdraw Current Standard Research Only Proposed Funding Type: Budget Request Special Solicitation Total Funding Request (Parts A & B): Name of Submitter(s): Date: May 15, 2011 $ 0 none other than volunteer time from employees of API member companies working on the document preparation Austin Freeman Halliburton Part A Resource Plan I. Background and Information: 1. Explain the business need for the proposed action. Indicate potential cost savings to industry where possible. API RP14H (5 th edition) was issued August, 2007. It comes up for systematic review according to S1 in 2012. A TG was formed in SC6 to investigate whether or not changes to this document were required in light of recent events. The TG met and concluded changes were needed to obviate additional regulations. 14H is currently referenced in the CFR [30CFR250.802 (d) and 30CFR250.804 (a)(5)]. The document is currently written in the should vernacular and should be moved into shall language where appropriate. 2. What is the scope of the standard? Requirements (not guidance) for the installation, operation, maintenance, inspection and repair of Surface Safety Valves and Underwater Safety Valves. 3. Is this standard on the work program of another standards development organization (check all that apply)? ISO IADC ASME SAE Other, please provide: If yes, is the work being coordinated with the appropriate group? Are there special circumstances that would justify independent API initiation of the proposed action?
4. Are a volunteer chair and group of experts available to perform the proposed action? Please include names and company affiliation and indicate chair, if available. See table below: Name Company E-mail Austin Freeman Halliburton austin.freeman@halliburton.com David Comeaux GE david.comeaux@ge.com Henry Wong FMC Henry.wong@fmcti.com Jim Brinkley WoodGroup Jim.brinkley@woodgroup.com Darine Aghnim Lamons Darine.aghnim@lamons.com Sterling Lewis Exxon sterling.f.lewis@exxonmobil.com Mahesh Udipi GE Oil & Gas mahesha.udipi@ge.com Dennis Kaminski BP Dennis.Kaminski@bp.com David Pang Doris, Inc davidpang2004@yahoo.com 5. Is there a need to commit resources to supplement the development of the draft? Would a paid content specialist accelerate progress on the development/revision? Is there a readily available content specialist? No. 6. Are there special format requirements for final document, i.e. knowledge of ISO template required), significant graphics, photos or equations) required that would need extraordinary resources? Yes No X If Yes, please provide details: 7. Please provide any other information that is pertinent to the proposed action. 8. What are the implications of not initiating the proposed action? Include potential safety, reliability, environmental and financial impacts that may arise. Safety valves of all types are at the forefront of attention in light of recent events. This standards action in advance of that required by API S1 normal operating procedures shows commitment from the industry to maintain our documents and to increase the diligence paid to our safety operating systems. 9. Is there research proposed to accomplish the proposed action? Yes No X If yes, complete Part B of this form. II. Project Timing Proposed start date: July 2011 TG/WG: (estimated number of volunteers needed) 10 Proposed date draft will be ready for letter ballot: Content Management: ($ amount "if needed" or volunteer) February 2011
PART B Research Plan I. Background and Information 1. Proposed Research Title: 2. Proposed Project Scope: 3. Research Amount: $ 4. What is the business need for the proposed research? 5. Is the proposed research edition-specific for a single standard or will it result in technology enhancement for multiple standards? Yes No If multiple standards, please cite the standards effected: 6. Research Timing: Research is necessary prior to scheduled revision. Research can be done concurrent with revision. 7. How does the research support the proposed action identified in Part A? 8. Is a joint industry project (JIP) a possibility? Yes No If Yes, with who? 9. Are there opportunities for leveraged research with other organizations? Yes No What organizations? 10. What are the implications of not performing the proposed research? II. Dates and Funding: Estimated Completion Date Prior Research Anticipated Future Research Funding Needs Funding Requested $ Year 2: $ Year 3: $ Year 4: $
PART C Proposal Feedback/Approval Information For API Use ONLY SC comments to Proposer/WG: Date approved by subcommittee: CSOEM comments: Date approved by CSOEM: Date entered into API Publications DB: