Reporting Verification of BOP Shear Ram Capability: Requirements and Good Practices on Reporting Blowout Preventer (BOP) Shear Ram Capability for Outer Continental Shelf (OCS) Oil and Gas Operations

Abstract

The Bureau of Safety and Environmental Enforcement (BSEE) Well Control Rule (Subpart G)1 became effective on July 28, 2016. This rule is part of the BSEE regulations pertaining to well control equipment used for oil and gas operations on the U.S. Outer Continental Shelf (OCS). More recently BSEE issue a proposed rule to amend portions of the 2016 well control rule. This proposed rule (now implemented) appeared in the Federal Register on May 18, 2018. This report was prepared late in the public comment period for the current rule and intended is a sample of desirable documentation of blind shear ram shear testing and associated regulatory requirements either in place or anticipated at the time of preparation. In accordance with this original rule and the proposed revisions, BSEE requests specific information regarding the capabilities of blind shear rams (BSR) in the Blowout Preventer (BOP). This information is required prior to beginning any operation involving the use of any BOP. More specifically, Title 30 CFR 250.732(b) of these regulations requires documentation of shear testing demonstrating the shearing and sealing capabilities of the BOP BSR. Such documentation is consistent with and complementary to other documentation verifying the designs of individual well control components and the overall BOP system. Verification demonstrates performance and reliability of the equipment based on a testing process that is repeatable and reproducible.2 This document, an annotated outline of verification documentation, arises from the combination of regulations and good practices concerning how to report BOP shear ram tests and third-party verification of BSR capability to support BSEE’s regulatory role.