What are the requirements for a subsea BOP stack?
One commenter asked why didn’t MMS identify the costs associated with the subsea accumulator requirements. Response: MMS did not specify any costs for this requirement because lessees/operators were already required by the regulations to have an accumulator that provided for fast closure. API RP 53 now provides guidelines for determining the minimum requirements and performance for the subsea accumulator. Comment on § 250.442What are the requirements for a subsea BOP stack? A commenter noted that section 13.3 of API RP 53 does not include subsea accumulator volume requirements that can be audited other than the specific response times. Response: MMS will review BOP test records, including documentation of the closing times of ram and annular preventers, in evaluating BOP system performance. Comment on § 250.443What associated BOP systems and related equipment must my BOP system include? MMS should clarify that this section applies to both surface and subsea BOP equipment. The commenter
