30 CFR § 250.732 - What are the BSEE-approved verification organization (BAVO) requirements for BOP systems and system components?
(a) BSEE will maintain a list of BSEE-approved verification organizations (BAVOs) on its public website that you must use to satisfy any provision in this subpart that requires a BAVO certification, verification, report, or review. You must comply with all requirements in this subpart for BAVO certification, verification, or reporting no later than 1 year from the date BSEE publishes a list of BAVOs.
(1) Until such time as you use a BAVO to perform the actions that this subpart requires to be performed by a BAVO, but not after 1 year from the date BSEE publishes a list of BAVOs, you must use an independent third-party meeting the criteria specified in paragraph (a)(2) of this section to prepare certifications, verifications, and reports as required by §§ 250.731(c) and (d), 250.732 (b) and (c), 250.734(b)(1), 250.738(b)(4), and 250.739(b).
(2) The independent third-party must be a technical classification society, or a licensed professional engineering firm, or a registered professional engineer capable of providing the certifications, verifications, and reports required under paragraph (a)(1) of this section.
(3) For an organization to become a BAVO, it must submit the following information to the Chief, Office of Offshore Regulatory Programs; Bureau of Safety and Environmental Enforcement; 45600 Woodland Road, Sterling, Virginia, 20166, for BSEE review and approval:
(i) Previous experience in verification or in the design, fabrication, installation, repair, or major modification of BOPs and related systems and equipment;
(ii) Technical capabilities;
(iii) Size and type of organization;
(iv) In-house availability of, or access to, appropriate technology. This should include computer programs, hardware, and testing materials and equipment;
(v) Ability to perform the verification functions for projects considering current commitments;
(vi) Previous experience with BSEE requirements and procedures; and
(vii) Any additional information that may be relevant to BSEE's review.
(b) Prior to beginning any operation requiring the use of any BOP, you must submit verification by a BAVO and supporting documentation as required by this paragraph to the appropriate District Manager and Regional Supervisor.
|You must submit verification and documentation related to:||That:|
|(1) Shear testing,||(i) Demonstrates that the BOP will shear the drill pipe and any electric-, wire-, and slick-line to be used in the well, no later than April 30, 2018;|
|(ii) Demonstrates the use of test protocols and analysis that represent recognized engineering practices for ensuring the repeatability and reproducibility of the tests, and that the testing was performed by a facility that meets generally accepted quality assurance standards;|
|(iii) Provides a reasonable representation of field applications, taking into consideration the physical and mechanical properties of the drill pipe;|
|(iv) Ensures testing was performed on the outermost edges of the shearing blades of the shear ram positioning mechanism as required in
|(v) Demonstrates the shearing capacity of the BOP equipment to the physical and mechanical properties of the drill pipe; and|
|(vi) Includes relevant testing results.|
|(2) Pressure integrity testing, and||(i) Shows that testing is conducted immediately after the shearing tests;|
|(ii) Demonstrates that the equipment will seal at the rated working pressures (RWP) of the BOP for 30 minutes; and|
|(iii) Includes all relevant test results.|
|(3) Calculations||Include shearing and sealing pressures for all pipe to be used in the well including corrections for MASP.|
(c) For wells in an HPHT environment, as defined by § 250.807(b), you must submit verification by a BAVO that the verification organization conducted a comprehensive review of the BOP system and related equipment you propose to use. You must provide the BAVO access to any facility associated with the BOP system or related equipment during the review process. You must submit the verifications required by this paragraph (c) to the appropriate District Manager and Regional Supervisor before you begin any operations in an HPHT environment with the proposed equipment.
|You must submit:||Including:|
|(1) Verification that the verification organization conducted a detailed review of the design package to ensure that all critical components and systems meet recognized engineering practices,|
|(2) Verification that the designs of individual components and the overall system have been proven in a testing process that demonstrates the performance and reliability of the equipment in a manner that is repeatable and reproducible,||(i) Identification of all reasonable potential modes of failure; and
(ii) Evaluation of the design verification tests. The design verification tests must assess the equipment for the identified potential modes of failure.
|(3) Verification that the BOP equipment will perform as designed in the temperature, pressure, and environment that will be encountered, and|
|(4) Verification that the fabrication, manufacture, and assembly of individual components and the overall system uses recognized engineering practices and quality control and assurance mechanisms.||For the quality control and assurance mechanisms, complete material and quality controls over all contractors, subcontractors, distributors, and suppliers at every stage in the fabrication, manufacture, and assembly process.|
(d) Once every 12 months, you must submit a Mechanical Integrity Assessment Report for a subsea BOP, a BOP being used in an HPHT environment as defined in § 250.807, or a surface BOP on a floating facility. This report must be completed by a BAVO. You must submit this report to the Chief, Office of Offshore Regulatory Programs; Bureau of Safety and Environmental Enforcement; 45600 Woodland Road, Sterling, VA 20166. This report must include:
(1) A determination that the BOP stack and system meets or exceeds all BSEE regulatory requirements, industry standards incorporated into this subpart, and recognized engineering practices.
(2) Verification that complete documentation of the equipment's service life exists that demonstrates that the BOP stack has not been compromised or damaged during previous service.
(3) A description of all inspection, repair and maintenance records reviewed, and verification that all repairs, replacement parts, and maintenance meet regulatory requirements, recognized engineering practices, and OEM specifications.
(4) A description of records reviewed related to any modifications to the equipment and verification that any such changes do not adversely affect the equipment's capability to perform as designed or invalidate test results.
(5) A description of the Safety and Environmental Management Systems (SEMS) plans reviewed related to assurance of quality and mechanical integrity of critical equipment and verification that the plans are comprehensive and fully implemented.
(6) Verification that the qualification and training of inspection, repair, and maintenance personnel for the BOP systems meet recognized engineering practices and any applicable OEM requirements.
(7) A description of all records reviewed covering OEM safety alerts, all failure reports, and verification that any design or maintenance issues have been completely identified and corrected.
(8) A comprehensive assessment of the overall system and verification that all components (including mechanical, hydraulic, electrical, and software) are compatible.
(9) Verification that documentation exists concerning the traceability of the fabrication, repair, and maintenance of all critical components.
(10) Verification of use of a formal maintenance tracking system to ensure that corrective maintenance and scheduled maintenance is implemented in a timely manner.
(11) Identification of gaps or deficiencies related to inspection and maintenance procedures and documentation, documentation of any deferred maintenance, and verification of the completion of corrective action plans.
(12) Verification that any inspection, maintenance, or repair work meets the manufacturer's design and material specifications.
(13) Verification of written procedures for operating the BOP stack and Lower Marine Riser Package (LMRP) (including proper techniques to prevent accidental disconnection of these components) and minimum knowledge requirements for personnel authorized to operate and maintain BOP components.
(14) Recommendations, if any, for how to improve the fabrication, installation, operation, maintenance, inspection, and repair of the equipment.
(e)You must make all documentation that supports the requirements of this section available to BSEE upon request.