API 18LCM

(Life Cycle Management)

Report back to SC17
August 27, 2015

Review Team: Dave Wilkinson, John Strut, Smarty John, David Saul, Peter Moles
 What is API 18LCM?
• Newly drafted API standard – likely to be
balloted prior to YE’15
• Goal : “provide a means of maintaining and
demonstrating continued conformance of
product to original and/or current product
definition” from cradle to grave.
• Scope: “to address the management life cycle for
products in the petroleum and natural gas
industry”
 How does it work? (1/2)
• Applied to products in the petroleum and natural gas industry
• It is not clear which equipment it is to be applied to or who will make
this determination – user, owner, regulator, API?
• Unclear if use is intended to be restricted to only products
manufactured in accordance with API standards & specifications;
could apply to any product regardless of pedigree.
• Interpreted as requiring data tracking to lowest component level

• Requires development of LCM plans for management of data

pertaining to each product
– Implemented by LCM Service Provider (LCMSP) of whom these
entities are is intentionally left to be defined

• Five levels of requirement are currently defined in the draft

document – but next draft may only include three levels
 How does it work? (2/2)
• Determination of ongoing LCM status will be by LCMSP based
on:
• Product identification
• Product definition
• Technical specifications, verification & validation tests, acceptance
criteria, assembly & testing requirements, preventative
maintenance requirements
• Manufacturing records
• Traceability
• Usage history
• Repair and maintenance history
 Where does it fit in?
• Because it defines and manages hardware
compliance, it must be a higher level
document:
• Q1 > Q2 > 18LCM > 17D > 17N > 17Q….?
• 18LCM > Q1 > Q2 > > 17A?

• If hardware is modified, the need for

qualification is not identified in 18LCM;
perhaps add verbage for qualification per RP
17N?
 What’s missing?
• What are the criteria for determining what equipment
should be managed per 18LCM?
• Related to well control/integrity?
• Hydrocarbon pressure containing?
• All API equipment?
• All equipment?
• How is the appropriate LCM level determined?
• HES risk based?
• Production loss / downtime risk based?
• Transition plan
• Deployment to be defined outside of API 18LCM
• Can existing equipment be “grandfathered”?
• Lead in time for application?
 How will it impact the market?
• Changes to hardware offshore become very difficult
– Spotlight on MOC requirements
– Potentially send some modifications underground and unreported
– Tend to encourage continued conformance to OEM specified parts.
• Implementation
– Initially difficult due to incomplete documentation of systems – huge demand on
manufacturers (costs)
– Grandfathering would be required for existing hardware
– Rolling deployment on critical new hardware to start – Monogrammable?
• Management
– Once enacted, becomes an unstoppable train - probably put into law
– Success dependant on strong documentation collection (discipline) and ongoing
management (software)
• Silver lining
– Massively improved access to data for integrity and risk assessments
 Subsea Equipment Examples
Tree SCM Manifold Subsea Tree Tree USV (1) C/WO Riser

API Document Std 17F RP 17P Spec 17D Spec 17D RP 17G (2)

Monogrammable? No No No Yes No

Hydrocarbon No Yes Yes Yes Yes

containing?
Part of well No No Yes Yes Yes
containment
envelope?
Routinely retrieved Yes No No No Yes
to be maintained
or modified?
Typically owned by Operator Operator Operator Operator Contractor

Effort required to High Low Low Medium High

track LCM status (Often repaired) (Usage history) (Often repaired)
Recommend No. Yes.
application of Not a critical part of well Critical part of well containment envelope, therefore
18LCM? containment envelope. consequence of life cycle failure potentially high.

(1) Including valve actuator

(2) Being upgraded to Standard?
 Next Steps
•CSOEMR
– Need co-ordinated approach
• Across all relevant SCs
• Evaluate benefits versus costs
• Define grandfathering process and limits on initial
application - to HSE critical equipment?
• Defer publishing until co-ordinated implementation plan in
place
•SC17
– Define applicable hardware
– Define appropriate LCM levels
– Prepare detailed application examples
 Take aways
• Potentially huge cost and operational impact
on the industry – once deployed, never
removed
• How widely deployed in industry? What really
matters – qualitative cost versus benefit
analysis required
• Need a co-ordinated and predefined
application plan prior to publishing document