American Oil and Gas Reporter - June 2019 - 33

ing-Current regulations require shear ram
positioning mechanisms to center pipes
within the shearing blade area. Many newer
shear ram designs ensure pipe positioning,
and commenters suggested removing the
centering requirements, but BSEE's final
rule retained it. However, the agency points
out, it will not require this to be achieved
using a separate mechanism, but will allow
the shear ram itself to accomplish this.
· Shearing combinations-BSEE also
will retain language requiring both shear
rams to be capable of shearing the specified
equipment, basing the decision on comments regarding the importance of shearing
redundancy and recognition that the proposed change's wording for relying on a
combination of shear rams potentially may
inject ambiguity regarding the number of
rams subject to this shearing requirement.
· Subsea accumulator capacity-BSEE
had proposed removing references to the
subsea location of the accumulator capacity,
determining it was unnecessary to specifically identify only subsea requirements
when API Standard 53 covers the entire
system. Multiple comments supported the
proposed revisions, but other commenters
asserted the agency failed to explain how
the reference's removal would ensure that
the accumulator system could function
adequately if there was a loss of power
fluid connection to the surface. Based on
those comments, to avoid confusion about
how the autoshear and deadman systems
use accumulator capacity, BSEE will retain
the clarification that certain accumulator
capacity must be located subsea.
· 21-day BOP testing frequency-In
the proposed rule, BSEE requested comments on whether the BOP testing interval
should be seven, 14 or 21 days, with
current regulations requiring pressure and
function testing of specific BOP components every 14 days. Multiple comments
support a 21-day BOP testing frequency,
and BSEE has agreed to accept that schedule, if an operator meets certain criteria.
"BSEE utilized the best available data
to analyze the economic impacts of the
final changes," the agency notes. "That
analysis indicates that the estimated overall
economic impact will benefit the industry
over the next 10 years because of the reduction in compliance costs, in addition
to increased regulatory certainty. As this
rule maintains safety and environmental
protection, the entities realizing savings
from these changes can deploy them for
other, more productive purposes, e.g.,
additional capital investment."

sociation applauding BSEE's acknowledgement that the 2016 rule, while well
intentioned, was flawed because of technical problems that detracted from the
goal of safe operations.
"BSEE's final revisions, which leave
the original rule largely intact, further
manage risks and better protect workers
and the environment, making drilling
safer," asserts Randall Luthi, NOIA's
president. "Crafted to focus on ways to
improve safety and allow companies to
meet requirements in a safe, verifiable
and practical manner, the new rule will
result in a stronger regulatory process."

Erik Milito, vice president of upstream
and industry operations at the American
Petroleum Institute, notes the revised
rules offer a framework that promotes
updated, modern and safe technologies,
industry best practices and operations.
"Offshore production delivers billions
of dollars to the federal treasury and has
created thousands on thousands of jobs
throughout the Gulf Coast as well as in
states far removed from production areas,
where American families and state budgets
depend on reliable and abundant energy
sources to meet consumer demand and
to drive the economy," Milito says. ❒

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American Oil and Gas Reporter - June 2019

Table of Contents for the Digital Edition of American Oil and Gas Reporter - June 2019
