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calculated the maximum anticipated wellhead pressure (“MAWP”) at the
417
mudline (or BOP) was 8,404 psi.

2. Required Systems and Equipment

If an operator opted to use a subsea BOP stack, it had to fulfill the MMS
requirements set forth in 30 CFR § 250.442. The requirements were:

 The operator had to install the BOP system before drilling below
surface casing.
 The subsea stack had to include at least four remote‐controlled,
hydraulically operated BOPs consisting of an annular BOP, two BOPs
equipped with pipe rams, and one BOP equipped with blind shear
rams.
 The operator had to install an accumulator closing system to provide
fast closure of the BOP components and to operate all critical functions
in case of a loss of the power fluid connection to the surface. The
accumulator system had to meet or exceed the provisions of Section
13.3 in API RP 53, Recommended Practices for Blowout Prevention
Equipment Systems for Drilling Wells.
 The BOP system had to include an operable dual‐pod control system to
ensure proper and independent operation of the BOP system.
 Before removing the marine riser, the operator had to displace the riser
with sea‐water. The operator had to maintain sufficient hydrostatic
pressure or take other suitable precautions to compensate for the
reduction in pressure and to maintain a safe and controlled well
condition.

Additionally, all subsea BOP systems were required to meet the
conditions set forth in 30 CFR § 250.443. This regulation required all systems to
include:

 An automatic backup to the primary accumulator‐charging system;
 At least two BOP control stations (one station on the drill floor and the
other in a readily accessible location away from the drill floor);
 Side outlets on the BOP stack for separate kill and choke lines;
 A choke and kill line on the BOP stack (each to have two full opening
valves, and both to be remote‐controlled if it is subsea). The choke line

417 BP’s April 15, 2010 APD.

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