API SC 6

SUBCOMMITTEE ON VALVE AND WELLHEAD EQUIPMENT

TASK/WORK GROUP STATUS REPORT

API RP14H

14 JUNE 2012

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...... 5-4

6. FUTURE MEETING DATES...... 6-4

7. RESOURCE NEEDS ...... 7-4

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.

2. PREVIOUS STATUS REPORT DATE

22 FEBRUARY 2012

3. MEMBERSHIP

Name / Company / e-mail
Austin Freeman / Halliburton /
David Comeaux(Chair) / GE Oil & Gas /
Henry Wong / FMC /
Jim Brinkley / Cactus Wellhead /
Darine Aghnim / Lamons /
Sterling Lewis / Exxon /
Mahesh Udipi / GE Oil & Gas /
David Pang / Foster Wheeler Upstream /
Sergio Meyberg / GE Oil & Gas /
Mike Moy / Shell /
Shane Siebenaler / Southwest Research Institute /
Arturo Trejo-Hernandez / Cameron /

4. MINUTES

The taskgroup met a total of seven times:

8/11/11, 10/27/11, 12/07/11, 1/19/12, 3/08/12, 4/6/12, and 5/17/12.

Mike Moy, Shane Siebenaler, Arturo Trejo-Hernandez and Sergio Meyberg joined the team.

Issues determined by the reaffirmation TG meeting of 05/15/11 were addressed as follows:

  1. ISSUE: 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.

RESOLUTION: Task group acknowledges the safety implications of 14H to critical processes. It was decided that the task-group would review/re-write of 14H under the presumption that the document would qualify for a re-classification as a standard, with language to match.

  1. ISSUE: In the Scope section, rewording is suggested since there are several repetitions in 1.2 and 1.3.
    RESOLUTION: Clauses 1.2 and 1.3 were reworded to eliminate repetition and improve clarity of document.
  1. ISSUE: The document does not have a normative references section and 6A appears to be normativelyreferenced.

RESOLUTION: Normative references section was added to the document, citing API 6A, API 17D, API 6AV1, and API RP 14C.

  1. ISSUE: There are no references to the CFR. Should there be?

RESOLUTION: No references to the CFR were added. CFR covers operations in the OCS. Specific referencing of the CFR would require 14H to reference the regulatory documents of all government entities using 14H.

  1. ISSUE: Many uses of the word “should” when what we really mean is “shall” in many cases.
  • Section 4 (Installation and Maintenance)
  • Section 5 (Repair)

RESOLUTION:

Language of entire document was strengthened through replacement of “should” with “shall” and through complete re-write of some of the clauses.

Clause 3 (Receiving Inspection): 2 out of 2 sub-clauses modified to increase strength of statements and modified to improve clarity.

Clause 4 (Installation and Maintenance): 11 out of 11 sub-clauses modified to read as requirements instead of recommendations. 5 of the sub-clauses underwent significant rewording.

Clause 5 (Repair): 4 out of the 5 sub-clauses were modified to read as requirements, the other was removed and its contents were addressed elsewhere in the document. 2 of the sub-clauses underwent significant rewording.

Clause 6 (Testing Procedures): This clause was re-written in its entirety, as outlined in item 10, below.

Clauses 7-9 (Failure Reporting, Documentation Requirements, and Miscellaneous): all sub-clauses underwent significant modification.

  1. ISSUE: Leakage rates specified in 14H are not consistent with CFR requirements.

RESOLUTION: In accordance with MMS Contract No. 1435-01-97-CT-30880 SwRI report “Allowable Leakage Rates and Reliability of Safety and Pollution Prevention Equipment” (SwRI Project 18-1298), team deems current leakage criteria (14H, 5th edition) are adequately justified in the sense of managing SSV/USV safety requirements. Per this report, zero leakage acceptance requirements specified in 30 CFR 250 may not significantly increase the level of safety (fire, toxic, and environmental) when compared to the leakage rates specified in 14H, 5th Ed.A possible reason for the stringent requirements in the CFR may be the ease to discern presence of leakage of SSVs/USVs in field without having to quantify it.

Note: Maximum credibility of 14H will be achieved when the acceptance criteria presented in 30CFR250 and 14H are aligned. Team is unsure on course of action required to realize this alignment.

  1. ISSUE: Appendix A (now Annex A) requires review/rewrite.

RESOLUTION: Annex A was restructured as follows:

  • Flow/Process Diagram
  • Nomenclature
  • Assumptions
  • Procedure
  • Example

Theflow/process diagram, streamlines the equations used in the Pressure Build-up methodology (as illustrated in the example found in the 5th Edition). As presented in the 5th Edition, the pressure build-up makes the implicit assumption that the leak rate is constant throughout the duration of the test. In the 6th Edition, a check was added to ensure that the implied assumption was indeed met in the test set-up. This was done by requiring the Allowable pressure limit to be below the critical pressure of the cavity. As a result, the assumptions section was added to explicitly specify the limitations of the presented method.

  1. ISSUE: When two or more safety system valves are present, some regulators (such as Norwegian Petroleum Safety Authority, PSA) require that each valve’s ability to close under flowing conditions be validated independently. Do we want to include this validation test in 14H?

RESOLUTION: The team resolved that this validation testing is not in the scope of 14H, and that any design considerations and their respective validation are in the scope of API 6A. Clause 10.20 “Specific Requirements for Surface and Subsea Safety Valves” in API 6A should be enhanced to include validation requirements related to closing under field flowing conditions. Alternatively, as per the discussion in the SC6 winter meeting, the independent closure testing requirements have been proposed to the 6AV1 task-group for inclusion in the latest edition of the 6AV1 document.

  1. ISSUE: Clause 5 on Repair may need strengthening and alignment of definitions withAPI 6A.

RESOLUTION: All references to on-site repair were changed to field repair, aligning the terminology with 6A. Similarly, offsite repair was realigned under 6A normative Annex J: “Repair and remanufacture requirements”.

  1. ISSUE: 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.

RESOLUTION:

Suggested addition of “Testing shall be performed in accordance with government regulations, manufacturer operating manual, and section 6 of API 14H.”

Additionally, the following is a summary of the changes made to the Operation/Pressure Holding Test:

  • Operation and Pressure Holding tests consolidated into a single procedure.
  • Test procedures for SSV and USV were consolidated into a single procedure.
  • Specified a total of 3 cycles comprising the operation test (not specified previously).
  • Operation/Pressure Holding test modified to allow operators to use equipment/methods having the required precision to measure leakage across the SSV/USV and compare this leakage against the acceptance criteria. Pressure Build-up Methodology presented in the document in Annex A is being re-written and evaluated by the TG.
  • Minimum duration of pressure-holding period was changed from 5 minutes to 3 minutes.
  • Added explicit requirement for zero leakage of pressure-containing components.
  • Changed the units in which the allowable leakage is expressed.
  • Added requirement that “the pressure holding period, test cavity volume, pressure change, temperature change, and sensitivity of pressure measuring devices shall be sufficient to demonstrate compliance to the acceptance criteria” when an indirect leakage measurement method is used.
  • Added explicit instructions that after testing, the well should be returned to production in a way that minimizes the pressure differential across the SSV/USV valve.

Furthermore, testing after Field Repairs Section was reviewed and updated.

The following changes were also incorporated into the document:

  1. Installation and Maintenance,
  2. Clause 4.1, 5th Ed (Clause 5.1 and 5.2, 6th Ed.):
    The requirements for SSV and USV location in the tree architecture were broken out into two separate clauses. Requirements for USV were modified to more accurately describe Subsea tree architecture.
  3. Clause 4.7, 5th Ed (Clause 5.8, 6th Ed.):
    “Note: Control systems are out of the scope of this document. Testing and operation of control system is defined in the control system operating manuals.” was added to ensure continuity between the control system and the SSV/USV is maintained when there are changes in control systems, such as a change between the controls of a workover rig to those of the production system, and vice-versa, acknowledging that the testing of this continuity should be covered in the operating manuals of the control systems designed per API 17G, API 17H, etc.
  1. Failure Reporting Clause (Clause 7 in 5th Ed.,Clause 8 in 6th Ed):Changed from

“User Recommendation: The operator of SSV/USV equipment repaired to this standard should provide a written report of equipment failure to the manufacturer. This report should include, as a minimum, the information in Exhibit 1 and a copy of the SSV/USV Repair Record Sheet (Exhibit 2).”

to

“The operator of SSV/USV equipment covered by this standard shall provide a written report of equipment failure to the manufacturer, and, as applicable, to the provider(s) of associated goods and services. Tables 9.1 through 9.3 lists the information required, but do not preclude the operator from compiling and reporting this information in other formats. A failure report consists of:

•Table 9.1: Failure Report

•Table 9.2: Field Repair Record Sheet

•Table 9.3: Functional Test Data Sheet”

This ensures that manufacturer is always aware of equipment failures, not just when the equipment has been repaired.

  1. The following:
  2. Exhibit 1: Failure Report for Surface Safety Valves (SSVs) and Underwater Safety Valves (USVs)
  3. Exhibit 2: SSV/USV Repair Record Sheet
  4. Exhibit 3: SSV/USV Functional Test Data Sheet For Onsite Repairs

wereconverted into Tables 9.1, 9.2, and 9.3, respectively.

5. FUTURE WORK PROGRAM

  1. July 2012: Complete Committee Draft and circulate to SC6 for comments.
  2. October 2012: Document sent out for Ballot.

6. FUTURE MEETING DATES

TBA after release of Committee Draft.

7. RESOURCE NEEDS

  • Need operator representatives at all meetings.
  • Service Engineering Personnel.

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