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had to be installed above the bottom ram, the kill line could be
installed below the bottom ram;
 A fill‐up line above the uppermost BOP;
 Locking devices installed on the ram‐type BOPs; and
 A wellhead assembly with a rated working pressure that exceeds the
maximum anticipated surface pressure (MASP).
418

3. Required Maintenance and Inspections

30 CFR § 250.446 identified BOP stack maintenance and inspection
requirements. This provision required maintenance of BOP systems to ensure
that the equipment functioned properly. It also required to visual inspections of
the subsea BOP system and riser at least once every three days if weather and sea
conditions permitted. Subsea BOP stack maintenance was required to meet or
exceed API RP 53 Sections 18.10, 18.11 and 18.12.

a. API RP 53 Section 18.10

Section 18.10 of API RP 53 generally prescribed recommended practices
for well inspections and maintenance and required that all leaks and
malfunctions were corrected before BOP equipment was placed into service. API
RP 53 Section 18.10.3 recommended a “major inspection” of the BOP stack after
every three to five years of service. During the major inspection, the BOP stack,
choke manifold, and diverter components were recommended to be
disassembled and inspected in accordance with the manufacturer’s guidelines.
419

b. API RP 53 Section 18.11

Section 18.11.3 of API RP 53 addressed BOP maintenance. Of particular
relevance here, Section 18.11.3 required that spare parts be designed for intended
use. The operator was required to consult the original equipment manufacturer
regarding replacement parts, and if parts were acquired from a non‐original
equipment manufacturer, “the parts shall be equivalent to or superior to the
original equipment and be fully tested, design verified, and supported by
420
traceable documentation.”

418 The JIT concluded that the current 30 CFR § 250.443 contains an error; it believes that this
provision should refer to maximum allowable working pressure (MAWP), not MASP.
419 API RP 53, Section 18.10.3.
420 API RP 53, Section 18.11.3.

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