Notice to Lessees and Operators (NTL) of Federal Oil, Gas,
and Sulphur Leases in the Outer Continental Shelf

Blowout Preventer (BOP) Requirements for Drilling

MMS is in the process of revising a part of the testing requirements for BOP systems and equipment. The revised requirement will now allow a lessee up to 14 days between BOP pressure tests. MMS makes this revision based on a recently completed study of BOP performance. This study concluded that no statistical difference exists in failure rates for BOP's tested between 0- to 7-day intervals and between 8- to 14-day intervals. MMS will begin the rulemaking process to promulgate this revision into the regulations. The following paragraphs discuss how MMS will administer this revision in the interim.

Fourteen-day testing time frame. This revision changes the testing interval requirements in §250.57(e)(3) and §250.86(b)(2) to allow up to 14 days between pressure tests. You must continue to test BOP systems according to the other testing requirements found in §250.57 and §250.86. You may not exceed 14 days between pressure tests. This means that you must begin testing your BOP system within 14 days after the last pressure test. The operator must ensure that BOP tests are initiated prior to midnight on the 14th day subsequent to the conclusion of the previous test.

District Supervisors will not grant extensions to the 14-day time frame except when you are conducting pressure-control operations or remedial operations for stuck pipe. However, you must test as soon as the situation is remedied (e.g., stuck pipe is retrieved from the well bore). Furthermore, MMS reserves the right to specify a shorter testing time frame when warranted.

New wells and current drilling activities. The revised testing time frame applies to all drilling operations after January 31, 1997. You do not need to obtain any additional approval from the District Supervisor to test on a 14-day time frame.

Sidetrack and completion activities. The 14-day testing time frame applies to sidetrack and completion activities if you use the same or similarly-rated rig and BOP equipment as used to originally drill the well. This becomes effective on January 31, 1997. You must state in your Sundry Notice (Form MMS-124) that you will use the same or similarly-rated rig and BOP equipment.

Workover activities. The 14-day time frame for testing a BOP system does not apply to any workover activities. You must continue to test your system weekly, not to exceed 7 days.

BOP pressure testing after setting casing. You must continue to pressure test your BOP system before drilling out each string of casing or before continuing operations in cases where you do not drill out the cement.

Inspection, maintenance, and performance requirements. The current regulations require a lessee to inspect and maintain all BOP equipment to ensure that the equipment will function properly. MMS will continue to examine whether specific inspection and maintenance requirements are necessary to ensure high reliability of BOP equipment. MMS will also examine the need for performance requirements.

[signed] Carolita U. Kallaur
Associate Director for Offshore Minerals Management

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Last Updated: 02/02/2006, 07:22 AM