If you choose to install a subsea pump system, your system must comply with your approved DWOP, which must meet the following minimum requirements:
(a) Include the installation of an isolation valve at the inlet of your subsea pump module.
(b) Include a PSHL sensor upstream of the BSDV, if the maximum possible discharge pressure of the subsea pump operating in a dead head condition (that is the maximum shut-in tubing pressure at the pump inlet and a closed BSDV) is less than the MAOP of the associated pipeline.
(c) If the maximum possible discharge pressure of the subsea pump operating in a dead head situation could be greater than the MAOP of the pipeline:
(1) Include, at minimum, 2 independent functioning PSHL sensors upstream of the subsea pump and 2 independent functioning PSHL sensors downstream of the pump, that:
(i) Are operational when the subsea pump is in service; and
(ii) Will, when activated, shut down the subsea pump, the subsea inlet isolation valve, and either the designated USV1, the USV2, or the alternate isolation valve.
(iii) If more than 2 PSHL sensors are installed both upstream and downstream of the subsea pump for operational flexibility, then 2 out of 3 voting logic may be implemented in which the subsea pump remains operational provided a minimum of 2 independent PSHL sensors are functional both upstream and downstream of the pump.
(2) Interlock the subsea pump motor with the BSDV to ensure that the pump cannot start or operate when the BSDV is closed, incorporate at a minimum the following permissive signals into the control system for your subsea pump, and ensure that the subsea pump is not able to be started or re-started unless:
(i) The BSDV is open;
(ii) All automated valves downstream of the subsea pump are open;
(iii) The upstream subsea pump isolation valve is open; and
(iv) All parameters associated with the subsea pump operation (e.g., pump temperature high, pump vibration high, pump suction pressure high, pump discharge pressure high, pump suction flow low) must be cleared (i.e., within operational limits) or continuously monitored by personnel who observe visual indicators displayed at a designated control station and have the capability to initiate shut-in action in the event of an abnormal condition.
(3) Monitor the separator for seawater.
(4) Ensure that the subsea pump systems are controlled by an electro-hydraulic control system.
(d) Follow the valve closure times and hydraulic bleed requirements according to your approved DWOP for the following:
(1) Electro-hydraulic control system with a subsea pump;
(2) A loss of communication with the subsea well(s) and not a loss of communication with the subsea pump control system without an ESD or sensor activation;
(3) A loss of communication with the subsea pump control system, and not a loss of communication with the subsea well(s);
(4) A loss of communication with the subsea well(s) and the subsea pump control system.
(e) For subsea pump testing:
(1) Perform a complete subsea pump function test, including full shutdown, after any intervention or changes to the software and equipment affecting the subsea pump; and
(2) Test the subsea pump shutdown, including PSHL sensors both upstream and downstream of the pump, each quarter (not to exceed 120 days between tests). This testing may be performed concurrently with the ESD function test required by §250.880(c)(4)(v).