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API 14H Task Group Status. Proper Classification of Document Review for Clarity Acceptance Criteria (Leakage rate conflicts, 30 CFR 250) Independent Closure Valve Repair Onsite vs. Offsite Failure reporting Process. Austin Freeman Sterling Lewis Mike Moy

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api 14h task group status

API 14H Task Group Status

Proper Classification of Document

Review for Clarity

Acceptance Criteria (Leakage rate conflicts, 30 CFR 250)

Independent Closure

Valve Repair Onsite vs. Offsite

Failure reporting Process

Austin Freeman Sterling Lewis Mike Moy

David Comeaux (Chair) Mahesh Udipi Shane Siebenaler

Henry Wong Dennis Kaminski Darine Aghnim

Jim Brinkley David Pang Sergio Meyberg

14H Status - 2/22/2012

proposed significant changes
Proposed Significant Changes
  • 14H has significant safety implications to critical processes. Task-group decided to review/re-write of 14H under the presumption that the document would qualify to be re-classified as a standard, with language to match.
  • Added Normative References Section
  • Most clauses modified to read as requirements instead of guidance:
    • Examples:
    • Clause 4: “installation procedures outlined in the operating manual should shall be followed”
    • Clause 5: “Replacement Parts should be qualified parts…”  “Replacement parts shall meet or exceed OPD (Original Product Definition) requirements…”
    • Clause 8: Repair documentation “shall be maintained for the possession period of the equipment, and shall accompany the equipment during transfer of ownership.”
  • Alignment of terminology with 6A:
    • Onsite repair  Field repair

14H Status - 2/22/2012

proposed significant changes1
Proposed Significant Changes
  • Testing
    • 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).
    • Added requirement for duration of pressure-holding period to be sufficient to demonstrate compliance to the acceptance criteria when an indirect leakage measurement method is used.
    • 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.
    • Added explicit requirement for zero leakage of pressure-containing components.
    • Pressure Build-up Methodology being reviewed and modified in Annex A. (still being developed)

14H Status - 2/22/2012

proposed significant changes2
Proposed Significant Changes
  • Failure Reporting
    • No longer a “User Recommendation”
    • Added requirements:
      • “Manufacturer must respond to the failure report per API 6A requirements.”
  • Documentation Requirements
    • Exhibits 1 through 4 being revamped (still being developed)
      • Exhibit 1: Failure Report for Surface Safety Valves (SSVs) and Underwater Safety Valves (USVs)
      • Exhibit 2: SSV/USV Repair Record Sheet
      • Exhibit 3: SSV/USV Functional Test Data Sheet For Onsite Repairs
      • Exhibit 4: SSV/USV Functional Test Data Sheet For Offsite Repairs

14H Status - 2/22/2012

slide5
Gaps
  • An international regulatory body requires verification of independent closing capability (i.e. Against flowing conditions)
  • TG resolved that this is out of scope of 14H.
    • Design considerations and their respective analysis/verification requirements are in the scope of API 6A.
  • Leakage rates specified in 14H are not consistent with CFR.
    • 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.

14H Status - 2/22/2012

timeline
Timeline
  • Several working meetings since May 2011:
    • 8/11/11, 10/27/11, 12/07/11, and 01/19/12
  • Complete Committee Draft of API 14H
    • Send out for comments – July 2012
  • Out for Ballot
    • October 2012

14H Status - 2/22/2012