API 14H Task Group Status Proper Classification of Document 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 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 Summer meeting on the re-affirmation vote for RP 14H it was voted to form a task team to address identified issues related to document rev 5. These issues included, proper classification of document, lack of celerity issues, Leakage rate conflict with CFR, independent closing, field repair vs. shop repair, failure reporting solidifying communication between user and manufacturer. 12/4/2018 14H Status - 2/22/2012

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 Normative References API Spec 6A API Spec 17D API Spec 6AV1 ISO 10423 API RP 14C  12/4/2018 14H Status - 2/22/2012

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) Clause 6 (Testing Procedures): This clause was re-written in its entirety. 12/4/2018 14H Status - 2/22/2012

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 Clause 6 (Testing Procedures): This clause was re-written in its entirety. “Operator to provide written report of failure of equipment repaired to  covered by 14H to the manufacturer.” 12/4/2018 14H Status - 2/22/2012

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. Definition of SSV/USV as well barrier and therefore the need to verify independent performance through validation testing against full-flow conditions. (i.e. Independent Closing Testing Requirements). This was originally identified as possible gap in 14H, but TG 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. 12/4/2018 14H Status - 2/22/2012

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 12/4/2018 14H Status - 2/22/2012