Minimum Blowout Prevention (BOP) System Requirements for Well-Workover Operations Performed Using Coiled Tubing with the Production Tree in Place
Published on April 26, 2007

MMS Lake Charles District has requested that operators be aware of a change in the regulations concerning minimum blowout prevention (BOP) system requirements for well-workover operations performed using coiled tubing with the production tree in place.

On March 7, 2006, the MMS published a final rule in the Federal Register (06-2113) affecting the following regulations:
  • 30 CFR 250.601 – Definitions
  • 30 CFR 250.615 – Blowout prevention equipment
  • 30 CFR 250.616 – Blowout preventer system testing, records and drills
The new regulations were effective on April 6, 2006.

MMS is especially concerned about compliance with the change to 30 CFR 615(e)(7) that states:
    (e) For coiled tubing operations with the production tree in place…(7) All connections used in the surface BOP system from the tree to the uppermost required ram must be flanged, including the connections between the well control stack and the first full-opening valve on the choke line and the kill line.

MMS Lake Charles District has indicated that if the BOP stack does not have flanged valves the operator will have to obtain a waiver from the MMS District Engineer.

For more information on this final rule, contact William McCarson at 281-578-3388, or e-mail at william.mccarson@jccteam.com.
This Regulatory Alert was prepared by J. Connor Consulting, Inc. to advise our clients of impending deadlines and applicable regulatory requirements. No official agency policy is implied.