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| US CHEMICAL SAFETY AND HAZARD INVESTIGATION BOARD | |
| INVESTIGATION REPORT | |
| VOLUME 1 | |
| EXPLOSION AND FIRE AT THE MACONDO WELL | |
| (11 Fatalities, 17 Injured, and Serious Environmental Damage) | |
| DEEPWATER HORIZON RIG | |
| MISSISSIPPI CANYON BLOCK #252, GULF OF MEXICO | |
| APRIL 20, 2010 | |
| KEY ISSUES IN VOLUME 1 | |
| • | |
| MACONDO INCIDENT BACKGROUND AND GENERAL DESCRIPTION | |
| • | |
| DEEPWATER DRILLING AND TEMPORARY ABANDONMENT OF THE MACONDO WELL | |
| REPORT NO. 2010-10-I-OS | |
| 6/5/2014 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| [This page left intentionally blank.] | |
| 2 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| Volume 1 | |
| Macondo-specific incident | |
| events: Relevant background | |
| on deepwater drilling and | |
| temporary abandonment | |
| 3 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| [This page left intentionally blank.] | |
| 4 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| Contents | |
| VOLUME 1 .................................................................................................................................................. 3 | |
| ACRONYMS AND ABBREVIATIONS ..................................................................................................... 7 | |
| 1.0 | |
| MACONDO BACKGROUND AND INCIDENT SUMMARY ..................................................... 8 | |
| 1.1 | |
| Involved Parties ............................................................................................................................... 8 | |
| 1.2 | |
| The US Offshore Regulator ........................................................................................................... 10 | |
| 1.3 | |
| The Well, the Rig, and the Crew .................................................................................................... 12 | |
| 1.3.1 | |
| The Deepwater Horizon Rig ............................................................................................. 14 | |
| 1.3.2 | |
| The Crew........................................................................................................................... 14 | |
| 1.4 | |
| Planning the Well ........................................................................................................................... 15 | |
| 1.5 | |
| Incident Description ....................................................................................................................... 16 | |
| 2.0 | |
| DEEPWATER DRILLING AND TEMPORARY ABANDONMENT OF THE MACONDO | |
| WELL ............................................................................................................................................ 18 | |
| 2.1 | |
| Controlling Pore Pressures with Drilling Fluids ............................................................................ 19 | |
| 2.2 | |
| Controlling Pore Pressures with Casing and Cement .................................................................... 23 | |
| 2.2.1 | |
| Cement Integrity Testing and Final Displacement ........................................................... 26 | |
| 2.3 | |
| Controlling Pore Pressures with a Blowout Preventer ................................................................... 28 | |
| 2.4 | |
| Consequences of Explosion and Fire ............................................................................................. 31 | |
| REFERENCES ........................................................................................................................................... 32 | |
| 5 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| Figures and Tables | |
| Figures | |
| Figure 1-1. Relationship between key companies associated with the Deepwater Horizon accident. .......... 9 | |
| Figure 1-2. Location of the Macondo well. ................................................................................................ 12 | |
| Figure 1-3. Timeline from when BP acquired the Macondo well lease until the Deepwater Horizon took | |
| over drilling the well. .............................................................................................................. 13 | |
| Figure 2-1. During drilling, mud travels down the drillpipe, through the drill bit, and then back up the | |
| annulus (yellow), carrying crushed rock back to the rig. ........................................................ 20 | |
| Figure 2-2. A simplified drilling margin plot. The planned mud weight (red dashed line) is formulated to | |
| remain less than the fracture gradient (green line) and greater than the pore pressure (black | |
| line). New casing transitions (green diamonds) are installed when the fracture gradient is | |
| approached............................................................................................................................... 22 | |
| Figure 2-3. Cementing casing in place involves filling the annulus with cement above any hydrocarbon | |
| bearing zones if they are present as well as a small length (30ˈ-90ˈ) in the shoe track........... 24 | |
| Figure 2-4. The final Temporary Abandonment configuration intended to remove drilling mud down to | |
| 8,367 feet to install a cement plug in seawater. ....................................................................... 26 | |
| Figure 2-5. The Deepwater Horizon BOP .................................................................................................. 29 | |
| Tables | |
| Table 1-1. Total number of employees and revenue as reported by companies associated with the | |
| Deepwater Horizon ................................................................................................................... 10 | |
| Table 1-2. Personnel On Board on April 20 by Company [NEED UPDATED TABLE] .......................... 14 | |
| Table 1-3. Well Control Personnel On Board the Rig on April 20, 2010 ................................................... 15 | |
| 6 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| Acronyms and Abbreviations | |
| APD | |
| Application for Permit to Drill | |
| BOEM | |
| Bureau of Ocean Energy Management (United States) | |
| BOEMRE | |
| Bureau of Ocean Energy Management, Regulation, and Enforcement (United | |
| States); the US offshore safety regulator between June 18 and October 1, 2011a | |
| BOP | |
| Blowout Preventer | |
| BSEE | |
| Bureau of Safety and Environmental Enforcement (United States); US offshore | |
| safety regulator since October 1, 2011b | |
| CSB | |
| United States Chemical Safety & Hazard Investigation Board | |
| DWH | |
| Deepwater Horizon | |
| EDS | |
| Emergency Disconnect System | |
| IADC | |
| International Association of Drill Contractors | |
| MMS | |
| Minerals Management Service (United States); US offshore safety regulator at | |
| the time of the Macondo accident until June 18, 2011c | |
| MODU | |
| Mobile Offshore Drilling Unit | |
| OCS | |
| Outer Continental Shelf | |
| ONRR | |
| Office of Natural Resources Revenue (United States) | |
| ppg | |
| pounds per gallon | |
| SEMS | |
| Safety and Environmental Management System | |
| UK | |
| United Kingdom | |
| a Department of Interior, Order No. 3302, Change of the Name of the Minerals Management Service to the Bureau | |
| of Ocean Energy Management, Regulation, and Enforcement (June 18. 2011), | |
| http://www.doi.gov/deepwaterhorizon/loader.cfm?csModule=security/getfile&PageID=35872. Accessed | |
| February 19, 2014. | |
| b The Reorganization of the Former MMS, http://www.bsee.gov/About-BSEE/BSEE- | |
| History/Reorganization/Reorganization/..Accessed February 19, 2014. | |
| c Department of Interior, Order No. 3302, Change of the Name of the Minerals Management Service to the Bureau | |
| of Ocean Energy Management, Regulation, and Enforcement (June 18, 2011), | |
| http://www.doi.gov/deepwaterhorizon/loader.cfm?csModule=security/getfile&PageID=35872. Accessed February | |
| 19, 2014. | |
| 7 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| 1.0 Macondo Background and Incident Summary | |
| At the time of the accident, the Deepwater Horizon (DWH) crew had finished drilling and was | |
| completing temporary abandonment of the well so that a production facility could return later to extract | |
| oil and gas from the well. | |
| The Macondo well was exploratory in nature, meaning | |
| significant uncertainty remained about the geology, the | |
| petroleum resources, and the formation characteristics that | |
| make the well easy or difficult to drill. Managing such | |
| uncertainties ultimately determines a company’s success. | |
| On the day of the April 20 tragedy, no effective safeguards | |
| were in place to eliminate or minimize the consequences of | |
| a process safety incident.a The safeguards (or barriers) | |
| intended to prevent such a disaster were not properly | |
| constructed, tested, or maintained, or they had been | |
| removed. The management systems intended to ensure the | |
| required functionality, availability, and reliability of these | |
| safety critical barriers were inadequate. Ultimately, the | |
| barriers meant to prevent, mitigate, or control a blowout | |
| failed on the day of the accident. | |
| 1.1 | |
| Involved Parties | |
| BP Exploration & Production Inc. (BP)b was and is the main | |
| lease holder/operator of the block of landc that includes the | |
| Macondo well site.d BP identifies itself as the largest | |
| leaseholder in US Gulf of Mexico deepwater, owning more | |
| than 650 different blocks of land in water depths of 1,200 feet or greater.1 | |
| Offshore lease holder/operators such as BP largely conduct deepwater well drilling and completion | |
| activities through a number of contractors. Effective selection, oversight, and coordination among the | |
| operator and various contractors are vital to safe offshore exploration. To drill the well at Macondo, BP | |
| a A process safety incident is the unexpected releases of toxic, reactive, or flammable liquids and gases in processes | |
| involving highly hazardous chemicals—Process Safety Management, OSHA 3132, 2000 (reprinted). | |
| b BP p.l.c. is the parent company of many BP group companies, including BP Exploration & Production Inc. | |
| (BPXP). When referring to “BP,” BPXP is intended unless otherwise stated. | |
| c The Outer Continental Shelf has been divided into geographical areas referred to as blocks for identification | |
| purposes on maps and in databases, http://www.data.bsee.gov/homepg/pubinfo/freeasci/leasing/leaselistdfn.asp. | |
| dAs of February 23, 2010, U.S. Department of Interior documents indicate Anadarko E&P Company LP (22.5%), | |
| Anadarko Petroleum Corporation (2.5%), MOEX Offshore 2007 LLC (10%), and BP Exploration & Production | |
| Inc. (65%), shared leasing title interests, but as of December 5, 2011, BP retained 100%, | |
| http://www.data.bsee.gov/PI/PDFImages/ACTIVE-LEASE/130/133905.pdf. Retrieved November 12, 2013. | |
| Chapter 1.0 Overview | |
| This chapter provides general | |
| background as an introduction to the | |
| CSB’s investigation of Macondo. It is | |
| not meant to be all-encompassing. | |
| Additional relevant information | |
| including key findings appears in | |
| subsequent volumes. | |
| This chapter summarizes information | |
| on the companies and entities | |
| involved in the drilling and temporary | |
| abandonment of the Macondo well, | |
| the well itself, the Deepwater Horizon | |
| rig, and the drilling crew aboard the | |
| rig on the day of the incident. It | |
| concludes with an incident | |
| description summary that identifies | |
| the failures in the hours leading up to | |
| the explosions and fires aboard the | |
| DWH. | |
| 8 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| contracted Transocean, the drilling contractor, and other well service providers, including Halliburton and | |
| Sperry-Sun Drilling Services, a subsidiary of Halliburton (Figure 1-1). | |
| As of November 2013, Transocean operated a worldwide fleet comprising 80 different drilling rigs.2 In | |
| the US Gulf of Mexico, the fleet included 13 ultra-deepwater drilling rigs, which have the same water | |
| depth capability as the Deepwater Horizon’s, 7,500 feet and greater. Transocean has stated that BP was | |
| one of its most significant customers in 2012, accounting for approximately 11 percent of operating | |
| revenues.3 | |
| As indicated in Figure 1-1, Cameron was not directly contracted to BP, but the original contract between | |
| Transocean and BP specified the configuration of the blowout preventer and made specific references to | |
| “Cameron or equivalent” components throughout the contract.4 Cameron provided updated parts, testing, | |
| technical assistance, and repair services for the Deepwater Horizon BOP throughout its service period.a | |
| Figure 1-1. Relationship between key companies associated with the Deepwater Horizon accident. | |
| Transocean owned and operated both the Marianas and the DWH drilling rigs that were used at Macondo. | |
| It also employed most of the onboard crew of both rigs. As the contracted driller, Transocean was in | |
| charge of furnishing and maintaining materials, supplies, equipment, and services required for the drilling | |
| and completion activities that occurred at Macondo.5 These services included maintaining well control | |
| equipment, which the contract between BP and Transocean stipulated would be done according to good | |
| oilfield practices and by “all reasonable means to prevent fire and blowouts.”6 BP retained control of how | |
| various aspects of the drilling program would progress by specifying the completion activities (Section | |
| 1.5), the mud program (Section 2.1), and the casing program (Section 2.2).7 | |
| Halliburton Energy Services (Halliburton) and its subsidiary Sperry-Sun Drilling Services provided | |
| cementing and well monitoring services to BP during drilling, completion, and temporary abandonment | |
| activities at Macondo.8 | |
| BP, its contractors, and the BOP manufacturer operate worldwide and earn between $8 and $375 billion | |
| dollars annually (Table 1-1). | |
| a Cameron provided the CSB with numerous engineering report sheets, signed factory acceptance tests, repair sales | |
| orders, and purchase orders. | |
| 9 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| Table 1-1. Total number of employees and revenue as reported by companies associated with the | |
| Deepwater Horizon9 | |
| 1.2 | |
| The US Offshore Regulator | |
| At the time of the Macondo incident, Minerals Management Service (MMS), a division within the | |
| Department of the Interior, was the primary offshore regulator responsible for overseeing offshore energy | |
| operations to ensure compliance with relevant laws and regulations, predominantly the Outer Continental | |
| Shelf Lands Act and 30 CFR Part 250.a MMS managed the nation’s natural gas, oil, and other mineral | |
| resources on the Outer Continental Shelf (OCS). Its jurisdiction incorporated developing and | |
| implementing plans for leasing conventional and renewable energy resources, safety and environmental | |
| protection in all offshore energy activities, and revenue management. MMS minerals revenue amounted | |
| to approximately $13 billion annually, approximately 95% of the total revenue collected by the | |
| Department of the Interior.b,10 | |
| On May 19, 2010, four weeks following the Deepwater Horizon incident, then-Secretary of the Interior | |
| Ken Salazar signed a Secretarial Order to separate and reassign the responsibilities of the Minerals | |
| Management Service 11 into three independent entities: | |
| a In addition to the Department of the Interior, several other federal agencies regulate safety and environmental | |
| activities on the OCS. For instance, the US Coast Guard regulates marine safety, particularly the “safety of life | |
| and property on Outer Continental Shelf (OCS) facilities, vessels, and other units engaged in OCS activities.” 33 | |
| C.F.R §140.1. The Environmental Protection Agency regulates air pollution from OCS sources (40 C.F.R. § 55.1) | |
| and manages oil spill response in inland waters (40 C.F.R. Pt. 110 and 112). The Outer Continental Shelf Lands | |
| Act grants the Occupational Safety and Health Administration the authority to enforce its regulations on the OCS. | |
| However, if the working conditions are already regulated by another agency, the Department of the Interior and | |
| the US Coast Guard, 4(b)(1) of the Occupational Safety and Health Act and 21(d) of OCSLA prevent OSHA from | |
| duplicating their efforts. | |
| b The Department also manages other natural and cultural resources, including Bureau of Indian Affairs, Bureau of | |
| Land Management, Bureau of Reclamation, National Park Service, Office of Surface Mining, Reclamation and | |
| Enforcement, U.S. Fish and Wildlife Service, and U.S. Geological Survey, | |
| http://interior.gov/whoweare/index.cfm. Retrieved October 28, 2013. | |
| 10 | |
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| • | |
| The Office of Natural Resources Revenue (ONRR), responsible for the royalty and revenue | |
| management function, including the collection and distribution of revenue, auditing and | |
| compliance, and asset management. On October 1, 2010, the office began its duties.12 | |
| • | |
| The Bureau of Ocean Energy Management (BOEM), responsible for the sustainable | |
| development of the Outer Continental Shelf’s conventional and renewable energy resources, | |
| including resource evaluation, planning, and leasing-related activities. | |
| • | |
| The Bureau of Safety and Environmental Enforcement (BSEE), responsible for the | |
| comprehensive oversight, safety, and environmental protection of all offshore energy | |
| activities. | |
| The changes could not immediately take effect, so in the interim Salazar renamed MMS to Bureau of | |
| Ocean Energy Management, Regulation and Enforcement (BOEMRE), to identify the agency’s role more | |
| accurately.13 On October 1, 2011, BOEMRE ceased to exist after transferring its remaining | |
| responsibilities to BOEM and BSEE.14 | |
| In the aftermath of the incident, BOEMRE and then BSEE took significant proactive steps to promulgate | |
| new safety regulations, including the Interim15,a and Final [Drilling] Rules,16,b the Safety and | |
| Environmental Management Systems (SEMS) Rule [30 CFR Part 250 Subpart S],17 and subsequent | |
| amendments (SEMS II).18 | |
| While these are the principal entities of the Macondo case, additional companies, government agencies, | |
| and stakeholder organizations are associated with the incident aftermath and general offshore operations. | |
| Background information on relevant entities appears throughout the CSB Macondo Investigation Report | |
| volumes. | |
| a Requirements included a one-time recertification of BOPs, ROV capabilities and testing, autoshear and deadman | |
| on dynamically positioned rigs, stump test of autoshear and deadman, deadman initial seafloor test, | |
| documentation of BOP inspections and maintenance according to API RP 53, and, if shear rams activated on pipe | |
| during well control, retrival and inspection of the BOP. | |
| b Requirements included third-party verification of subsea BOP “compatibility” and up-to-date engineering, subsea | |
| secondary BOP intervention capability and testing, BOP drillpipe shearing capacity at the maximum anticipated | |
| surface pressure (MASP), third-party verification of shear calculations, and a BOP surface test between each well. | |
| 11 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| 1.3 | |
| The Well, the Rig, and the Crew | |
| The Macondo well is in the Central Gulf of Mexico, in Mississippi Canyon Block #252, approximately 50 | |
| miles from Louisiana, the nearest shoreline (Figure 1-2). | |
| Figure 1-2. Location of the Macondo well. | |
| BP acquired the lease for the Macondo well in March 200819 and began drilling there in October 200920 | |
| after the offshore regulator approved BP’s exploration plan and issued BP a permit to drill.21 Two rigs, | |
| first the Marianas and then the DWH, were used to drill the Macondo well (Figure 1-3). The Marianas | |
| drilled the Macondo well from October 6 to October 29,22 but the Marianas had to be moved to a shipyard | |
| for repairs after being significantly damaged by a hurricane;23 the Deepwater Horizon replaced it, arriving | |
| on site with a crew on January 31, 2010,24 and began setup and testing. Drilling resumed in February.25 | |
| 12 | |
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| Figure 1-3. Timeline from when BP acquired the Macondo well lease until the Deepwater Horizon took | |
| over drilling the well. | |
| BP planned to drill two exploration wells—Macondo being the first—and follow with a production | |
| facility if the oil and gas-bearing region revealed commercial potential.26 The plan was to drill beyond the | |
| primary target of approximately 18,400 feet to a total depth 20,200 feet to also assess the sections below | |
| the target.27 The water depth of the Gulf at the location was just short of 5,000 feet. | |
| BP designed Macondo for use as a producing well if successful, but the well was, in fact, exploratory | |
| because of the uncertainty about both the type and quantity of the oil and gas (hydrocarbons) present at | |
| the site and the effort necessary to actually extract the oil and gas. If the well proved commercially viable, | |
| data concerning the well’s geology and hydrocarbon properties would be collected and used to create a | |
| production plan; alternatively, if the well was not viable, the data would be gathered to determine why the | |
| commercial predictions failed.28 | |
| Ultimately, as BP hoped, the Macondo well was appropriate for conversion to a producing well. | |
| 13 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| 1.3.1 | |
| The Deepwater Horizon Rig | |
| The DWH was a mobile offshore drilling unit (MODU) measuring 396 by 256 feet29,a with housing | |
| capacity for 146 people.30 The DWH was a dynamically positioned rig that used global satellite | |
| technology and thrusters to maintain position over the well rather than cables and anchors to hold it in | |
| place.31 By their very nature, offshore rigs like the Deepwater Horizon MODU face unique hazards | |
| compared to their onshore counterparts. For example, on a rig a substantial number of workers occupy a | |
| small living and working area, where escape and rescue from a catastrophic event, such as a hazardous | |
| chemical release, fire, or explosion, are inherently more difficult due to the offshore location. | |
| 1.3.2 | |
| The Crew | |
| At the time of the blowout, 126 people employed by 13 different companies were onboard the DWH | |
| (Table 1-2). | |
| Table 1-2. Personnel On Board on April 20 by Company32 | |
| Eighteen of these individuals are typically identified as the crew intimately involved in the drilling and | |
| temporary abandonment activities or having direct oversight responsibilities for those activities. (Table | |
| a For comparison purposes, the dimensions of a National Football League football field are 360 by 160 feet. | |
| 14 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| 1-3 provides additional details relevant in subsequent volumes of the CSB Macondo Investigation | |
| Report.) | |
| Table 1-3. Well Control Personnel On Board the Rig on April 20, 201033 | |
| 1.4 | |
| Planning the Well | |
| The goal of drilling a deepwater well is to create a pathway between oil and gas reservoirs trapped | |
| beneath the seafloor and the surface. a To reach the reservoirs, a hole (the wellbore) is drilled through | |
| a The general references describing drilling used in this chapter include Van Dyke, K. Fundamentals of Petroleum, | |
| 4th ed. Austin: University of Texas, 1997; Offshore Well Construction, 1st ed. Austin: University of Texas, 2005; | |
| and A Primer of Oilwell Drilling, 7th ed. Austin: University of Texas, 2008. Readers may also review the Chief | |
| Counsel’s report by the National Commission, which offers more detail than this report, but still at an introductory | |
| level. See the National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling, Chief | |
| Counsel’s Report: The Gulf Oil Disaster, | |
| http://www.oilspillcommission.gov/sites/default/files/documents/C21462-408_CCR_for_web_0.pdf (February | |
| 14, 2011). Accessed August 14, 2013. | |
| 15 | |
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| Investigation Report Volume 1 | |
| June 5, 2014 | |
| various layers (formations) of rocks and/or unconsolidated sediments such as sand, shale,a gravel or silt.b | |
| The formations, such as the target reservoir, are porousc and permeable, and they contain water, oil, | |
| and/or gas which are under pressure. An unplanned flow of these fluids into the wellbore is called a | |
| “kick,” which, if not managed, can progress to a “blowout,” the uncontrolled release of oil and gas | |
| (hydrocarbons) from the well. This is most dangerous for people and property when the hydrocarbons | |
| release onto the drilling facility, where ignition sources are present. | |
| Thus, the flammable and potential explosive nature of oil and gas contained in the reservoir(s) of a | |
| potential well is one of the most significant major hazards that must be managed throughout the lifecycle | |
| of a drilling and production operation, beginning with the planning stages of the well. Part of the planning | |
| process is a well-specific hazard analysis of the operation to determine the appropriate safeguards for | |
| mitigating the hazard and control of the risks. (Volume 2, Chapters 4 and 5, of the CSB Macondo Incident | |
| Investigation Report addresses the hazard analysis issue further). | |
| 1.5 | |
| Incident Description | |
| On April 20, 2010, the drilling activities were completed after several productive oil and gas zones had | |
| been discovered at Macondo, and the crew was performing a series of steps to temporarily abandon the | |
| well. Abandonment activities would essentially plug the well so that the rig could move on to a new | |
| drilling site and a production installation could return to the Macondo site at a later date to extract the | |
| hydrocarbons. | |
| BP’s temporary abandonment pland called for removal of most of drilling fluid column in the well before | |
| installation of a surface cement plug.e Earlier, a critical cement barrier intended to keep the hydrocarbons | |
| below the seafloor had not been effectively installed at the bottom of the well, and the cement integrity | |
| was not not conducted in a way that provided a clear “pass” or “fail” result to the workers. Both BP and | |
| Transocean personnel on the DWH rig misinterpreted the test results concerning the cement integrity, | |
| leading them to erroneously believe that the hydrocarbon bearing zone at the bottom of the well had been | |
| sealed when in fact it was not. When the drilling fluid column was removed, pressure gradually reduced | |
| above the hydrocarbon reservoir at the bottom of the well. Eventually, this action allowed hydrocarbons | |
| to flow past the failed cement barrier and up toward the DWH. Meanwhile, because of a failure to | |
| recognize the increase in fluids from the well, the crew continued to remove more of the drilling fluid | |
| column, causing both the hydrocarbon influx rate into the well and movement of hydrocarbons toward the | |
| rig to increase. The hydrocarbons continued to flow from the reservoir for almost an hour without human | |
| intervention or the activation of automated controls. | |
| a Shale is a common deepwater rock. | |
| b Silt is loose sedimentary material of a size between sand and clay. | |
| c Porous formations constitute rock or other material that contains small spaces or holes that can hold liquids. | |
| d A well may be temporarily sealed with cement or mechanical plugs to allow removal of the blowout preventer and | |
| departure of the drilling rig. | |
| e Cement plugs are portions of cement put into a wellbore to seal it. “Surface” is typically used to refer to the most | |
| shallow cement plug used in a well. | |
| 16 | |
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| The force of the hydrocarbons accelerating up the mile-long drilling risera resulted in well fluids gushing | |
| onto the drilling rig floor—a blowout. At this point, the crew took action to activate the blowout preventer | |
| (BOP). This safety critical element,b located at the sea floor, temporarily sealed the well but could not | |
| stop the hydrocarbons that had already traveled above the BOP from releasing onto the rig. | |
| Once oil and gas had risen above the BOP, the only action the crew could take was to divert it to a safer | |
| location than onto the rig floor. However, the flow from the diverter had been preset to route well fluids | |
| to the mud-gas separator rather than over the side of the Deepwater Horizon. The mud-gas separator was | |
| rapidly overwhelmed, as it was not designed to safely handle a flow of the magnitude of the Macondo | |
| blowout. As a result, drilling mud and hydrocarbons rained down onto the rig floor. The hydrocarbons | |
| found an ignition source, and explosions and fire ensued. | |
| As discussed in detail in Volume 2, both manual and automated emergency systems within the blowout | |
| preventer were activated in an attempt to shear the drillpipe and seal the well. However, pressures in the | |
| well had caused the drillpipe to buckle, which inhibited the BOP from sealing the well. | |
| The explosion and fire resulted in 11 crew members suffering fatal injuries and 17 others being critically | |
| injured.34 The Deepwater Horizon rig sank on April 22, 2010, about 36 hours after the initial explosions.35 | |
| Approximately 5 million barrels of oil spilled into the Gulf of Mexico.c | |
| Ultimately, in the hours leading up to the incident, no effective barriers were in place to prevent or | |
| mitigate a blowout. The physical barriers intended to prevent such a disaster were not properly designed | |
| for the well conditions, constructed, tested, or maintained, or they had been removed. The management | |
| systems intended to ensure the required functionality, availability, and reliability of these barriers were | |
| inadequate. An examination of the treatment of safety critical equipment and tasks at Macondo, such as | |
| the BOP and cement barrier testing, reveals opportunities for further improvements in effective barrier | |
| safety management. Furthermore, a comparison of the US regulatory requirements for these safety critical | |
| elements to other international offshore regimes illustrates gaps in the US model and offers support for | |
| further post-Macondo changes to the US offshore safety regulations. | |
| a A drilling riser is a large diameter pipe that connects a drilling rig to the BOP attached to the wellhead. | |
| b As defined by the UK Health and Safety Executive, safety critical elements are controls (hardware, people | |
| systems, or software) or tasks whose failure could cause or contribute to a major accident or which the purpose is | |
| to prevent or limit the effects of a major accident; UK Offshore Installations (Safety Case) Regulations 2005, 2 | |
| Interpretation , http://www.legislation.gov.uk/uksi/2005/3117/pdfs/uksi_20053117_en.pdf. | |
| c The total volume of oil spilled has yet to be determined by the U.S. District Court in the multidistrict litigation, but | |
| estimates range from approximately 3.2 million to 5 million barrels. In Re: Oil Spill by the Oil Rig “Deepwater | |
| Horizon” in the Gulf of Mexico, on April 20, 2010, U.S. Br. 1, January 27, 2014, ECF No. 12237; BP Br. 29, | |
| January 24, 2014, ECF. No. 12227. | |
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| 2.0 Deepwater Drilling and Temporary Abandonment of the | |
| Macondo Wella | |
| Drilling a well requires controlling the pressure exerted by | |
| oil and gas trapped within the reservoirs that drillers are | |
| trying to reach. The pressure, known as pore pressure or | |
| formation pressure, is created in part by the weight of the | |
| water and rock pushing down from above. | |
| Pore pressure needs to be controlled throughout the subsea | |
| drilling and well completion operations to minimize the | |
| occurrence of well kicks—Macondo was a particularly | |
| challenging well in this regard. Well control actions must be | |
| initiated before a kick develops into an uncontrolled | |
| hydrocarbon release into the environment—a blowout— | |
| because gas that travels up the riser and is released onto the | |
| rig where ignition sources are present, is a serious threat to | |
| people. | |
| To control pore pressures and prevent kicks during drilling | |
| and completion activities, drillers commonly use a variety of | |
| physical barriers, including: | |
| • | |
| the weight of a column of fluid that fills the hole being drilled (wellbore) and the riser | |
| • | |
| steel casing and the cement used to secure it for protecting the sides of the wellbore and | |
| preventing hydrocarbons from entering | |
| • | |
| cement placed at the bottom of a well to seal the hydrocarbon bearing zone | |
| • | |
| a “surface” cement plug—cement placed in a shallow location in the well close to the surface at | |
| the seafloor—to seal the wellbore | |
| • | |
| drilling equipment known as a blowout preventer (BOP). | |
| Each of these barriers is discussed briefly throughout this chapter, but the BOP receives additional in- | |
| depth discussion in Volume 2 of the CSB Macondo Investigation Report. An introductory discussion of | |
| these barriers is necessary for a broader examination of the systemic, human, organizational, and | |
| regulatory issues that contributed to the incident. This chapter provides a basic description of some | |
| a This section focuses on deepwater drilling and temporary abandonment operations from a floating vessel, such as | |
| the Deepwater Horizon rig. General references describing drilling include Van Dyke, K. Fundamentals of | |
| Petroleum, 4th ed. Austin: University of Texas, 1997; Offshore Well Construction, 1st ed. Austin: University of | |
| Texas, 2005; and A Primer of Oilwell Drilling, 7th ed. Austin: University of Texas, 2008. The Chief Counsel’s | |
| report by the National Commission offers more detail than this report, but still at an introductory level. See the | |
| National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling Chief Counsel’s Report: The | |
| Gulf Oil Disaster, http://www.oilspillcommission.gov/sites/default/files/documents/C21462- | |
| 408_CCR_for_web_0.pdf (February 14, 2011). Accessed August 14, 2013. | |
| Chapter 2.0 Overview | |
| This chapter focuses on the issue of | |
| controlling formation pressures of the | |
| well during the deepwater drilling | |
| and temporary abandonment | |
| operations at Macondo. Basic drilling | |
| and completion activities are | |
| described, integrated with facts | |
| pertaining to the events of April 20, | |
| 2010. This information provides the | |
| foundation for the CSB’s technical, | |
| systemic, organizational, and | |
| regulatory analyses in subsequent | |
| report volumes. | |
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| underlying premises to offshore drilling and completion operations and the essential concepts that support | |
| the CSB’s investigative analysis in subsequent volumes. | |
| 2.1 | |
| Controlling Pore Pressures with Drilling Fluids | |
| The primary barrier used to control pore pressures while drilling is a column of fluid that fills the | |
| wellbore and the riser. Various drilling fluids, such as water or water-based and oil-based drilling muds,a | |
| are circulated down from the rig through the pipe used to drill the wellbore (drillpipe) and the drill bit | |
| used to cut through the formations to create the wellbore. Afterwards, the same fluids carry the crushed | |
| rock back around the drill bit up through the annular space between the drillpipe and wellbore (also called | |
| the annulus) to the surface via the riser, a large diameter pipe that connects a drilling rig to the BOP | |
| attached to the wellhead (Figure 2-1). The column of drilling fluid exerts hydrostatic pressure b on the | |
| walls of the wellbore. When the hydrostatic pressure in the wellbore is greater than the pore pressure, the | |
| well is said to be overbalanced. In this instance, the fluid column acts as a barrier by pushing back against | |
| the pore pressure, thus keeping the hydrocarbons from entering into the wellbore. Keeping a well in this | |
| overbalanced state is typically the primary means for controlling pore pressures and the basis of well | |
| control. If for some reason the hydrostatic pressure drops below the pore pressure, the well becomes | |
| underbalanced and a kick can occur. | |
| Alternatively, if the pressure exerted by the drilling fluids is too high, it can exceed the “fracture | |
| gradient,” or the pressure at which the walls of the exposed wellbore break down and drilling mud is lost | |
| into the formation.c These “lost returns” or “lost circulation” events are costly due to expenses related to | |
| the lost drilling mud, and they are also dangerous due to the resulting drop in the height of the drilling | |
| fluid column, which may result in an underbalanced state if a sufficient volume of the fluid column is lost | |
| to the formation and not replaced at the surface fast enough. This, too, can potentially result in a kick or, | |
| even worse, a blowout.d | |
| a Drilling muds are liquids and mixtures of liquids and solids circulated through the wellbore during drilling | |
| operations. | |
| b Hydrostatic pressure is exerted by liquid at a given point as a result of the weight of the column of fluid above it. | |
| c The total pressure exerted by the drilling fluids will be a combination of the hydrostatic pressure and additional | |
| pressure generated when the drilling fluids are circulated through the annulus. This can be expressed as | |
| “equivalent circulating density” (ECD). | |
| d Closing the BOP on a combined lost circulation event and well kick can lead to an underground blowout. In some | |
| cases, an underground blowout can cause pressures to exceed either casing failure pressures or the burst pressure | |
| of pressure relief valves known as rupture disks, which are designed to fail before the casing. (See Section 2.2 for | |
| casing description). An underground blowout was a serious concern at Macondo because if the installed rupture | |
| disks had burst due to the high blowout or kill pressures, a well flow up the annulus ultimately could have resulted | |
| in a surface blowout. See National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling, | |
| Chief Counsel’s Report: The Gulf Oil Disaster, Chapter 4.2, | |
| http://www.oilspillcommission.gov/sites/default/files/documents/C21462-408_CCR_for_web_0.pdf (February | |
| 14, 2011), Accessed August 14, 2013. | |
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| Figure 2-1. During drilling, mud travels down the drillpipe, through the drill bit, and then back up the | |
| annulus (yellow), carrying crushed rock back to the rig. | |
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| Drilling fluid is formulated as a barrier to keep the pressure at the bottom of the well within the drilling | |
| window or margin, which the International Association of Drill Contractors (IADC) defines as “the | |
| difference between the maximum pore pressure and the minimum effective fracture pressure.”36 In its | |
| well control manual in effect at the time of the Macondo incident, Transocean stated well planning is | |
| highly influenced by the drilling margin, as it dictates how drilling is conducted to achieve an efficient | |
| and safe operation.37 | |
| Applications to drill in the Gulf of Mexico must include the planned drilling margin,38 which is usually | |
| submitted in graphic form. Figure 2-2 represents a simplified drilling margin plot and demonstrates that | |
| the fracture gradient and the pore pressure typically increase as well depth increases, but not necessarily | |
| uniformly or constant relative to one another. The planned drilling margin is given in terms of equivalent | |
| mud density, reported in pounds per gallon (ppg), so that pressure can easily be related to the density of | |
| the drilling mud column. Mud weight is formulated to remain within the drilling margin to keep well | |
| fluids contained and to avoid fracturing the walls of the wellbore, risking a lost circulation event and | |
| potentially a subsequent kick. Offshore US drilling regulations state: “[w]hile drilling, you must maintain | |
| the safe drilling margin identified in the approved APD [Application for Permit to Drill]. When you | |
| cannot maintain this safe margin, you must suspend drilling operations and remedy the situation.”39 The | |
| regulations do not specify what the minimum drilling margin should be, but keeping the mud weight at | |
| least 0.5 ppg under the fracture gradient is typically accepted practice.40 | |
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| Figure 2-2. A simplified drilling margin plot. The planned mud weight (red dashed line) is formulated to | |
| remain less than the fracture gradient (green line) and greater than the pore pressure (black line). New | |
| casing transitions (green diamonds) are installed when the fracture gradient is approached. | |
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| 2.2 | |
| Controlling Pore Pressures with Casing and Cement | |
| To avoid exceeding the fracture gradient, the crew drills a well until the total pressure exerted by the | |
| drilling fluids approaches the fracture gradient, at which point steel casing lines the wellbore to cover the | |
| weaker formations.a Among other purposes,41 casing serves to strengthen the wellbore so that it does not | |
| fracture or collapse during drilling. Casing is secured in a well by pumping cement into the annular space | |
| between the casing and the formation, where it sets and hardens (Figure 2-3). The cement in the annulus | |
| and at the bottom of the casing, referred to as the shoe track, should keep drilling fluids from flowing up | |
| around the outside of the casing, thus protecting the wellbore, and it should prevent any hydrocarbons in | |
| the surrounding formation from flowing into the well. Cement is a crucial physical barrier to secure the | |
| integrity of the well, preventing ingress of hydrocarbons into the well and loss of well control. Yet, an | |
| MMS study of offshore blowouts published in 2007 noted the most common contributing factor for | |
| blowouts between 1992 and 2006 was cementing operations.42 Accordingly, cementing operations need to | |
| be designed and managed in a manner that does not assume a successful cement job. | |
| a “Casing” is a generic term for steel pipe. Formally, casing also refers to pipe if it extends up to the wellhead. A | |
| section of pipe also can be hung from the bottom of a previous casing. In this case, it is called a “liner.” Liners can | |
| hang from casing or from another liner. The intended effect on control of drilling margin is the same. | |
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| Figure 2-3. Cementing casing in place involves filling the annulus with cement above any hydrocarbon | |
| bearing zones if they are present as well as a small length (30ˈ-90ˈ) in the shoe track. | |
| After casing has been installed, heavier mud can then be introduced into the wellbore, and operations | |
| continue by drilling past the cement at the bottom of casing. The steps observed in the red line of Figure | |
| 2-2 are points in the well where the intention is to install casing to protect the weaker formations higher | |
| up in the well. Installing new casing can be exercised only a limited number of times because each new | |
| installation has to fit down through the casings installed immediately before, so the new casing must be | |
| smaller in diameter than the last. Few transitions can be made before the wellbore simply gets too narrow | |
| for additional drilling. Current drilling mechanics and the size of well logging instrumentation limit the | |
| minimum practical hole size to be a 6-inch diameter except in extraordinary circumstances.43 | |
| During the planning of the Macondo well, BP calculated how many times and at what depth to install a | |
| casing or liner transitions.44 When drilling the Macondo well, the crew encountered differences in the | |
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| predicted geology, which resulted in shallower-than-anticipated transitions and ultimately a shallower- | |
| than-planned final depth. BP has acknowledged that the final section of the well was difficult to drill due | |
| to a narrowing of the drilling margin as a result of an unusual reduction in the fracture gradient at the | |
| bottom of the wellbore,45 but the already small diameter casing prohibited installation of additional casing | |
| large enough to drill further. | |
| Thus, drilling stopped on April 9, 2010, at 18,360 feet below sea level, short of the original well planned | |
| depth of 19,650. Despite this change, the well had already encountered a good productive hydrocarbon | |
| region for later production. Once the hydrocarbon zone was reached, BP decided to plug and abandon the | |
| well for later hydrocarbon extraction. | |
| The process of preparing the well so that the drilling rig can depart until another rig or production facility | |
| returns is called temporary abandonment. For temporary abandonment to occur, the well needs to be | |
| sealed; until it is, the hazards of a well kick and blowout are still very real. US regulations require cement | |
| to be placed at the bottom of the well and the installation of a surface “retrievable or a permanent-type | |
| bridge plug or a cement plug at least 100 feet long in the inner-most casing” with the top of the plug | |
| required to be “no more than 1,000 feet below the mud line [sea floor]”46 unless the company seeks | |
| approval for an alternative plan from the regulator.47 At Macondo, BP gained approval to set a surface | |
| plug at approximately 3,000 feet below the seafloor. a,48 In its request, BP acknowledged this was a deep | |
| surface plug and stated it planned to extend the surface plug length to 300 feet rather than the minimum | |
| requirement of 100 feet “to compensate for the added setting depth.”49 In addition to choosing the deep | |
| placement of the surface plug, BP also decided to set the surface plug in seawater rather than drilling | |
| mud.b (Figure 2-4). | |
| BP did not have a company standard for developing a temporary abandonment plan. For Macondo, BP | |
| considered numerous temporary abandonment plan options in the week or so leading up to | |
| implementation. These changes included the location of the surface plug, which ultimately affected the | |
| negative pressure test conditions used to assess the bottom hole cement integrity (Section 2.3.1) and | |
| displacement of the well.50 Many variations are possible for cement integrity testing, each with | |
| advantages and disadvantages based on the particular circumstances of the well. (See Appendix 2-A, | |
| Deepwater Horizon Blowout Preventer Failure Analysis, for details.) While the various temporary | |
| a This depth was three times the regulatory maximum listed in MMS regulations (30 C.F.R. § 250.1721(d), 2010). | |
| The Application for Permit to Modify cites concerns with a piece of equipment called a lockdown sleeve (LDS) | |
| for the deviation. Post incident, BP stated in its investigation report that the depth of the surface cement plug was | |
| governed by the procedure for installing the LDS. The crew would hang 3,000 feet of pipe in the well to generate | |
| the 100,000 lbs. of weight necessary for installing the lockdown sleeve (BP, Deepwater Horizon Accident | |
| Investigation Report, September 8, 2010, p. 72). The Chief Counsel’s Report generated by the National | |
| Commission has challenged this assertion, stating other means were available to generate the necessary weight | |
| that would not have allowed the surface cement plug to be set more shallow (National Commission on the BP | |
| Deepwater Horizon Oil Spill and Offshore Drilling, Chief Counsel’s Report: The Gulf Oil Disaster, February 14, | |
| 2011, p. 141). | |
| b See the panel discussion that BP, Transocean, and Halliburton participated in concerning setting cement plugs in | |
| mud versus seawater, National Oil Spill Commission Meeting, November 8, 2010, pp. 209-216. | |
| http://www.oilspillcommission.gov/sites/default/files/documents/Transcript-%20Meeting%205.pdf. Last accessed | |
| July 25, 2013. | |
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| abandonment options BP explored improved the procedure, the CSB found no explicit risk assessment for | |
| the final procedure used at Macondo. | |
| Figure 2-4. The final Temporary Abandonment configuration intended to remove drilling mud down to | |
| 8,367 feet to install a cement plug in seawater. | |
| 2.2.1 | |
| Cement Integrity Testing and Final Displacement | |
| US regulations require conducting a positive pressure test to verify that no leaks are in the well.a On the | |
| day of the incident, the Deepwater Horizon drilling crew conducted a positive pressure test and | |
| a During a positive pressure test, a well is pressured up and then held in this condition to see if the pressure is | |
| maintained, indicating no leaks in the casing. If a decrease in pressure is observed, regulations require that either | |
| the well be re-cemented, the casing repaired, or additional casing installed to ensure the well is sealed. 30 CFR | |
| §250.423 (2010 and 2012). | |
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| determined the Macondo well passed the test.51 A major limitation of a positive pressure test is that it | |
| does not check the cement sealing off the hydrocarbon bearing zones at the very bottom of the well for | |
| inward leakage.a Even though regulations at the time of the incident did not require a negative pressure | |
| test, BP’s final temporary abandonment plan also called for one.b | |
| A negative pressure test can assess the integrity of the bottom-hole cement. It simulates an underbalanced | |
| well by displacing some of the heavy drilling mud from the well and closing the BOP to isolate the | |
| bottom of the well from the hydrostatic pressure exerted by fluids above the BOP. Various methods are | |
| available to accomplish the test, and the specific procedure was left to those planning the process.c Yet, | |
| neither BP nor Transocean management provided the Deepwater Horizon crew with a negative pressure | |
| test procedure that included acceptance criteria to confirm test success or actions to take if any deviations | |
| occurred during the test,d and the risks associated with conducting the negative pressure test were not | |
| formally assessed. | |
| To prepare for the negative pressure test at Macondo, a drillpipe was lowered to the depth identified for | |
| the bottom of the cement plug (Figure 2-4). A viscous and dense water-based Loss Circulation Material | |
| (LCM) followed by seawater was pumped down the drillpipe to displace the mud by pushing it above the | |
| BOP toward the rig.e After stopping displacement and closing the BOP,f the crew observed the pressures | |
| and/or flow from the well four times over three hours.g Each time, they observed unexpected results, so | |
| a A positive pressure test ensures no outflow from the well into its surroundings. One way to conduct the test entails | |
| closing the blind shear ram in the BOP (with no drillpipe present) and then pumping drilling mud down a pipe that | |
| connects to the BOP below the closed ram to pressure up the well. Cement at the bottom of a well is usually | |
| blocked from this pressure by a device known as a “wiper plug,” which is installed as part of the casing cement | |
| job and which seals against outflow from the well. | |
| b Regulations have changed post incident to require the negative pressure test, 30 CFR §250.423(c) (2012). | |
| c Current regulations, 30 CFR §250.423(c), require the operator to submit a procedure and acceptance criteria for | |
| approval. | |
| d For example, instructions from the Ops Note included a single sentence, “With seawater in the kill close annular | |
| and do a negative test ... 2350 psi differential,” Email communication, “Ops Note,” April 20, 2010, BP-HZN- | |
| BLY00071107, http://www.mdl2179trialdocs.com/releases/release201302281700004/Trocquet_David- | |
| Depo_Bundle.zip, Exhibit 1992. Accessed December 10, 2013. | |
| e The Chief Counsel Report noted that BP chose to put the LCM into the well to avoid disposing the material as a | |
| hazardous waste pursuant to the Resource Conservation and Recovery Act (National Commission on the BP | |
| Deepwater Horizon Oil Spill and Offshore Drilling, Chief Counsel’s Report: The Gulf Oil Disaster, February 14, | |
| 2011, p. 151) . The LCM material had never been tested for this application, there was no operational reason to use | |
| it, and the lost circulation material spacer was pumped into the well to avoid disposal of the material as a | |
| hazardous waste pursuant to the Resource Conservation and Recovery Act. The viscous, gelling nature of the | |
| LCM could have plugged a line the crew used to conduct the negative pressure test, greatly contributing to the | |
| false positive interpretation of the test. See Appendix 2-A for more details. | |
| f Most likely the lower annular preventer was closed. Witnesses at the hearings before the Deepwater Horizon Joint | |
| Investigation Team gave contradictory recollections: May 27, 2010, p. 36; May 28, 2010, p. 120; August 25, | |
| 2010, p. 272. | |
| g When displacement of the well was stopped to conduct the negative pressure test, as expected some trapped | |
| pressure was in the drillpipe. The crew bled the pressure from the drillpipe, which should have resulted in a zero | |
| pressure reading on the drillpipe. If the hydrocarbon bearing zone at the bottom of the well had been sealed, no | |
| subsequent increase in pressure would have resulted. Pressure did increase and was bled two more times before | |
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| they made adjustments before deeming the well passed the final test. The crew’s actions suggest they did | |
| not realize that the unexpected readings were indications of a failed negative pressure test and that | |
| integrity of the cement had not been secured. (See Appendix 2-A for details.) | |
| After the final negative pressure test was erroneously accepted as a “pass,” the Deepwater Horizon crew | |
| continued the process of displacement, replacing the drilling mud in the wellbore and riser with seawater | |
| in preparation to set the surface plug. Replacing dense drilling mud with seawater had the effect of | |
| lowering the hydrostatic pressure on the bottom of the well. With the fluid column removed and no | |
| surface plug yet set, the only means left for preventing the hydrocarbons from entering the riser and | |
| eventually making their way up the well to the rig was detection of the kick by the crew and manual | |
| activation of blowout prevention equipment to seal the well.a | |
| 2.3 | |
| Controlling Pore Pressures with a Blowout Preventer | |
| If the drilling column fluid (mud weight) barrier and the cement barrier both fail, and the well is still open | |
| (no plug installed), drilling crews depend on a blowout preventer (BOP) to control pore pressures. The | |
| BOP has two primary roles during drilling and completion operations. First, it is a tool the drill crew | |
| manually operates to control or regain control of the well during an initial kick by closing one or more | |
| sealing elements. Second, it is an emergency response mitigation device with both manual and automatic | |
| functions meant to shear drillpipe, seal the wellbore, and disconnect the rig from the well. A subsea BOP | |
| (Figure 2-5) can be massive; the Deepwater Horizon BOP was nearly 57 feet tall and weighed | |
| approximately 400 tons.52 The BOP is anchored to the top of the well casing at the seabedb and is | |
| connected to a drilling rig by a riser. Drilling equipment, drillpipe, tubulars,c and other tools used in the | |
| drilling process are lowered from the rig, through the riser, through the blowout preventer, and into the | |
| well. | |
| While subsea BOPs share general physical characteristics, the actual configuration, the control system, | |
| and the performance requirements are specific to each BOP. The Deepwater Horizon’s BOP was built by | |
| Cameron and had been used on the DWH since the rig began its service in 2001.53 | |
| The BOP components vary in their capabilities. Some seal the well around drillpipe, some seal open holes | |
| (when no drillpipe is present), and others shear the drillpipe and seal the well. The arrangement of these | |
| components within a BOP is based on the characteristics of the offshore operation and the anticipated | |
| the crew used a lack of flow from the well as an indicator of a passed test despite a pressure increase that was | |
| detected in the well. | |
| a Technically, mechanical float valves also are located at the bottom of the well installed as part of the production | |
| casing. These valves (also called check valves) allow cement used to install casing to flow one way out the bottom | |
| of the casing, but not back up into the casing once cement pumping stops. BSEE does not consider float valves by | |
| themselves a mechanical barrier, but they can and often do hold pressure. Float valves cannot be tested | |
| independently. Thus, they cannot be considered a reliable device, but they have to fail for the well to flow. | |
| b The National Commission generated a series of animations to depict not only BOP equipment placement and | |
| activation but also helpful drilling practices. See links to animations at http://www.oilspillcommission.gov/chief- | |
| counsels-report. Last accessed July 30, 2013. | |
| c As defined by Schlumberger Oil Field Glossary (http://www.glossary.oilfield.slb.com/search.cfm), a tubular is “A | |
| generic term pertaining to any type of oilfield pipe, such as drillpipe, drill collars, pup joints, casing, production | |
| tubing and pipeline.” | |
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| complexities. These components are identified in Figure 2-5, and the specific details of these components | |
| on the Deepwater Horizon BOP are discussed in more detail in Volume 2. | |
| Figure 2-5. The Deepwater Horizon BOP | |
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| When drilling mud and hydrocarbons began pouring out of the well and onto the Deepwater Horizon, the | |
| drilling crew activated a component called an annular preventer, which should have sealed the space | |
| around the drillpipe and prevented further hydrocarbons from rising above the BOP.a However, well data | |
| indicate that this component failed to seal the well.b Not only did the riser fluids—the hydrocarbons, | |
| drilling mud and seawater—that already passed above the BOP continue to travel up the riser and release | |
| onto the rig floor, but the riser was also being replenished by the flow of even more hydrocarbons through | |
| the leaking component. | |
| Immediately after activating this component, the rig crew also closed the diverter at the top of the riser.54 | |
| When the diverter shut, flow up the riser exiting onto the rig floor was redirected to the diverter piping. | |
| The two potential piping destinations were overboard into Gulf waters or to the Mud-Gas Separator | |
| (MGS). On the day of the incident, the diverter was directed to the MGS. Moments after the diverter was | |
| closed, the MGS was overwhelmed and hydrocarbons began blowing out of four different exit points onto | |
| the rig. | |
| Pressure datac indicate that the crew closed at least one additional sealing component of the BOP called a | |
| pipe ram, which successfully shut in the well but caused the pressure in the drillpipe to build substantially | |
| as evidenced by the surface drillpipe pressure building. (See Volume 2, Section 2.3 for details.) Riser | |
| fluids above the BOP continued to unload onto the rig floor, but their replenishment temporarily ceased. | |
| About two minutes later, the first explosions occurred on the rig and data transmission from the rig to | |
| shore ceased. | |
| In the minutes following the explosion, a crew member pressed the Emergency Disconnect System (EDS) | |
| button on the bridge BOP remote control panel.55 This maneuver should have activated the BOP | |
| components that would shear the drillpipe, seal the well, and disconnect the rig and riser from the BOP, | |
| thus allowing the DWH to move away from the wellhead. However, there was no indication of EDS | |
| actuation which was likely a result of the explosion damaging the rig-based BOP control systems and | |
| power and communication lines between the rig and the BOP. | |
| The explosion likely activated the AMF/deadman automatic emergency response system. This system | |
| was meant to shear the drillpipe and seal the well, but as evident from the major oil spill that ensued, the | |
| well remained unsealed. The likely activation of the AMF/deadman system and the failure of the BOP to | |
| seal the well is discussed in detail in Volume 2 (Chapter 3) of the CSB Macondo Investigation Report. | |
| a Witness statements said that the bridge remote control panel indicated that the lower annular was closed. Hearing | |
| before the Deepwater Horizon Joint Investigation, May 28, 2010, p. 145. However, upon recovery, the lower | |
| annular was found open [Bureau of Ocean Energy Management Regulation and Enforcement (BOEMRE), March | |
| 11, 2011. Forensic Examination of Deepwater Horizon Blowout Preventer, Report No. EP030842.] | |
| http://www.uscg.mil/hq/cg5/cg545/dw/exhib/DNV%20Report%20EP030842%20for%20BOEMRE%20Volume% | |
| 20I.pdf, p. 27. Accessed August 14, 2013. | |
| b If the annular preventer had sealed, the drillpipe pressure at the surface would have rapidly increased to 5,000+ | |
| psig (as when the upper pipe ram sealed at 9:47 p.m.). Rather, the drillpipe pressure fluctuated between 1,800 and | |
| 400 psig in this time period. | |
| c See Appendix 2-A and the National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling, | |
| Chief Counsel’s Report: The Gulf Oil Disaster, | |
| http://www.oilspillcommission.gov/sites/default/files/documents/C21462-408_CCR_for_web_0.pdf (February 14, | |
| 2011). Accessed August 14, 2013, p.191. | |
| 30 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| 2.4 | |
| Consequences of Explosion and Fire | |
| Of the Deepwater Horizon crew, 11 suffered fatal injuries from the explosion and fire and 17 others were | |
| critically injured.56 The Deepwater Horizon rig sank on April 22, 2010, about 36 hours after the initial | |
| explosions.57 Approximately 5 million barrels of oil were spilled into the Gulf of Mexico.a | |
| a The total volume of oil spilled has yet to be determined by the U.S. District Court in the multidistrict litigation, but | |
| estimates range from approximately 5 million barrels to 3.2 million barrels. In Re: Oil Spill by the Oil Rig | |
| “Deepwater Horizon” in the Gulf of Mexico, on April 20, 2010, U.S. Br. 1, Jan. 27, 2014, ECF No. 12237; BP Br. | |
| 29, Jan. 24, 2014, ECF. No. 12227. | |
| 31 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| References | |
| 1 BP, “Exploration and Production,” http://www.bp.com/en/global/corporate/about-bp/bp-worldwide/bp-in- | |
| america/our-us-operations/exploration-and-production.html. Retrieved November 12, 2013. | |
| 2 Transocean, http://www.deepwater.com/fw/main/Contract-Drilling-276.html. Retrieved November 12, 2013. | |
| (Website link no longer active.) | |
| 3 Proxy Statement and 2012 Annual Report, Transocean, p. AR-9, http://phx.corporate- | |
| ir.net/External.File?item=UGFyZW50SUQ9MTc4NzQ5fENoaWxkSUQ9LTF8VHlwZT0z&t=1.Retrieved | |
| November 1, 2013. | |
| 4 Transocean Drilling Contract for the Deepwater Horizon, 1998, | |
| http://www.mdl2179trialdocs.com/releases/release201305171200030/TREX-004271.pdf. Retrieved December 5, | |
| 2013. | |
| 5 Transocean Drilling Contract for the Deepwater Horizon, 1998, | |
| http://www.mdl2179trialdocs.com/releases/release201305171200030/TREX-004271.pdf. Retrieved December 5, | |
| 2013. | |
| 6 Transocean Drilling Contract for the Deepwater Horizon, 1998, BP-HZN-M8100021478, | |
| http://www.mdl2179trialdocs.com/releases/release201305171200030/TREX-004271.pdf. Retrieved December 5, | |
| 2013. | |
| 7 Transocean Drilling Contract for the Deepwater Horizon, 1998, BP-HZN-M8100021480, | |
| http://www.mdl2179trialdocs.com/releases/release201305171200030/TREX-004271.pdf. Retrieved December 5, | |
| 2013. | |
| 8 Contract for Gulf of Mexico Strategic Performances Unit Offshore Well Services between BP Exploration and | |
| Production, Inc. and Halliburton Energy Services, Inc., BP-HZN-CSB00175428 - BP-HZN-CSB00175972. | |
| 9 BP Annual Report and Form 20-F 2012, p. 55. | |
| http://www.bp.com/content/dam/bp/pdf/investors/BP_Annual_Report_and_Form_20F_2012.pdf. Retrieved | |
| November 12, 2013; http://www.bp.com/en/global/corporate/about-bp/bp-worldwide/bp-in-america/our-us- | |
| operations/refining.html. Retrieved November 12, 2013; “BP at a Glance,” | |
| http://www.bp.com/sectiongenericarticle.do?categoryId=3&contentId=2006926. Retrieved November 12, 2013; | |
| Proxy Statement and 2012 Annual Report, Transocean, pp. AR-7 & AR-9, http://phx.corporate- | |
| ir.net/External.File?item=UGFyZW50SUQ9MTc4NzQ5fENoaWxkSUQ9LTF8VHlwZT0z&t=1. Retrieved | |
| November 12, 2013; 2012 Annual Report, Halliburton, p. 38, http://phx.corporate- | |
| ir.net/External.File?item=UGFyZW50SUQ9MTc2OTU5fENoaWxkSUQ9LTF8VHlwZT0z&t=1, Retrieved | |
| November 12, 2013; http://www.halliburton.com/en-US/about-us/history-of-halliburton-of-halliburton.page?node- | |
| id=hgeyxt5y; 2012 Annual Report, Cameron, pp 29, http://investors.c-a- | |
| m.com/file.php/88/2012+Annual+Report_1fc62ad8-a436-4016-bd33-82432de12d66.pdf. Retrieved November 12, | |
| 2013. | |
| 10 U.S. Department of Interior, “Salazar Divides MMS’s Three Conflicting Missions,” | |
| http://www.doi.gov/news/pressreleases/Salazar-Divides-MMSs-Three-Conflicting-Missions.cfm. Retrieved | |
| December 12, 2012. | |
| 11 The Secretary of the Interior, Order No. 3299, Establishment of the Bureau of Ocean Energy Management, the | |
| Bureau of Safety and Environmental Enforcement, and the Office of Natural Resources Revenue, May 19, 2010, | |
| http://www.doi.gov/deepwaterhorizon/loader.cfm?csModule=security/getfile&PageID=32475. Retrieved December | |
| 5, 2013. | |
| 12 Bureau of Safety and Environmental Engineering, “BSEE History,” http://www.bsee.gov/About-BSEE/BSEE- | |
| History/Reorganization/Reorganization.aspx. Retrieved December 12, 2012. | |
| 32 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| 13 Secretary of the Interior, Order No. 3302, Change of the Name of the Minerals Management Service to the Bureau | |
| of Ocean Energy Management, Regulation and Enforcement, June 18, 2010, | |
| http://www.doi.gov/deepwaterhorizon/loader.cfm?csModule=security/getfile&PageID=32475. Retrieved December | |
| 5. 2013. | |
| 14 Bureau of Safety and Environmental Engineering, “BSEE History,” http://www.bsee.gov/About-BSEE/BSEE- | |
| History/index.aspx. Retrieved 12 December 2012. | |
| 15 Oil and Gas Sulphur Operations in the Outer Continental Shelf—Increased Safety Measures for Energy | |
| Development on the Outer Continental Shelf; Final Rule, Docket ID BOEM–2010–0034, 75 Federal Register 198 | |
| (October 15, 2010), pp. 63,345-63,377. | |
| 16 Oil and Gas and Sulphur Operations in the Outer Continental Shelf—Increased Safety Measures for Energy | |
| Development on the Outer Continental Shelf; Final Rule, Docket ID BOEM–2012–0002, 77 Federal Register 163 | |
| (August 22, 2012), pp. 50,856-50,901. | |
| 17 Final Rule, Oil and Gas and Sulphur Operations in the Outer Continental Shelf—Safety and Environmental | |
| Management Systems, 75 Federal Register (October 15, 2010), p. 63,610. | |
| 18 Final Rule, Oil and Gas and Sulphur Operations in the Outer Continental Shelf—Revisions to Safety and | |
| Environmental Management Systems, Docket ID: BSEE-2012-0011, 78 Federal Register 66 (April 5, 2013), pp. | |
| 20,423-20,443. | |
| 19 Minerals Management Service, High Bids Ranked by Bid Amount, Mar.19, 2008; (OCS Number G32306), | |
| http://www.boem.gov/uploadedFiles/BOEM/Oil_and_Gas_Energy_Program/Leasing/Regional_Leasing/Gulf_of_M | |
| exico_Region/lsesale/206/rpt4_206.pdf. Lease ownership was shared with two other companies, Anadarko | |
| Petroleum (25%) and MOEX Offshore (10%); Macondo Prospect Well Participation Agreement Deepwater Gulf of | |
| Mexico (Exhibit 2852), http://www.mdl2179trialdocs.com/releases/release201302281700004/Strife_Stuart- | |
| Depo_Bundle.zip. | |
| 20 Application for Permit to Drill a New Well Approval, Lease G32306, Area/Block MC 252. Publically accessed at | |
| http://www.mdl2179trialdocs.com/releases/release201302281700004/TREX-04021.pdf. | |
| 21 MMS Control Number N-09349 (BP-HZN-CSB00093568), April 6, 2009. | |
| http://www.defenders.org/sites/default/files/publications/gulf_oil_disaster_complaint_exhibit_3_plan.pdf.; | |
| Application for Permit to Drill a New Well Approval, Lease G32306, Area/Block MC 252. Publically accessed at | |
| http://www.mdl2179trialdocs.com/releases/release201302281700004/TREX-04021.pdf. | |
| 22 Transocean, IADC Daily Drilling Report, Marianas, Report No.7 (October 6, 2009); Transocean, IADC Daily | |
| Drilling Report, Marianas, Report No.30 (October 29, 2009). | |
| 23 Transocean, IADC Daily Drilling Report, Marianas, Report No.40 (November 8, 2009). BP-HZN-CSB00180108; | |
| Transocean, IADC Daily Drilling Report, Signal Shipyard, Report No.1 (November 27, 2009). TRN-USCG_MMS- | |
| 00011799 | |
| 24 Transocean, IADC Daily Drilling Report, Deepwater Horizon, Report No. 1 (January 31, 2010). TRN-USCG | |
| MMS-00011510- TRN-USCG MMS-00011513 | |
| 25 Transocean, IADC Daily Drilling Report, Deepwater Horizon, Report No.12 (February 11, 2010). BP-HZN- | |
| CSB00055037- BP-HZN-CSB00055041 | |
| 26 Initial Exploration Plan, Mississippi Canyon Block 252, OCS-G 32306 (Exhibit 6181). Publicly accessed at | |
| http://www.mdl2179trialdocs.com/releases/release201302281700004/Tooms_Paul-Depo_Bundle.zip. | |
| 27 Application for Permit to Drill a New Well Approval, Lease G32306, Area/Block MC 252. Publicly accessed at | |
| http://www.mdl2179trialdocs.com/releases/release201302281700004/TREX-04021.pdf , confirmed with CSB | |
| interview. | |
| 28 Internal BP document, Gulf of Mexico SPU Well Planning Process Macondo, Wells Decision Support Package, | |
| Stage Gate 1, 4/14/2009. (BP-HZN-CSB00182207) | |
| 33 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| 29 Transocean Website, Fleet Specifications, Retrieved June 9, 2010. (Internet link no longer active.) | |
| 30 Deepwater Horizon Equipment List, April 27, 2009 (BP-HZN-CSB00020850). | |
| 31 Transocean Drilling Contract for the Deepwater Horizon, 1998. Publicly accessed at | |
| http://www.mdl2179trialdocs.com/releases/release201305171200030/TREX-004271.pdf. Retrieved December 5, | |
| 2013. | |
| 32 Transocean Personnel-on-Board as of 20 Apr 2010 17:09:15 (TRN-USCG_MMS-00030435 – 00030441); | |
| confirmed accurate with Weatherford September 1, 2010 response to the CSB interrogatory subpoena request for | |
| information concerning personnel on board. | |
| 33 Transocean Personnel-on-Board as of 20 Apr 2010 17:09:15 (TRN-USCG_MMS-00030435 – 00030441); | |
| [Persons on Board (POB); Well Control Handbook, Issue 3, rev.1, March 31, 2009 [TREX 1454]; Macondo Well | |
| Incident – Transocean Investigation Report, Volume 1, p.17; Deepwater Horizon Operations Integrity Case, Section | |
| 2,Transocean Management System—HSE Management, Issue 1 (March 1, 2008) [TRN-MDL-02865361]; Contract | |
| for Gulf of Mexico Strategic Performance Unit Offshore Well Services between BP Exploration and Production, | |
| Inc., and Halliburton Energy Services, Inc., Section 3, Appendix 5, p.121 [BP-HZN-2179MDL00335470]. | |
| 34 BP plc (BP), Deepwater Horizon Accident Investigation Report, September 8, 2010, | |
| http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cts=1331666404195&ved=0CCkQFjAA | |
| &url=http%3A%2F%2Fwww.bp.com%2Fliveassets%2Fbp_internet%2Fglobalbp%2Fglobalbp_uk_english%2Finci | |
| dent_response%2FSTAGING%2Flocal_assets%2Fdownloads_pdfs%2FDeepwater_Horizon_Accident_Investigatio | |
| n_Report.pdf&ei=x55fT7qYJunIsQKFqPSMCA&usg=AFQjCNE4cEa7fTYS0DYjDfGY60zekb6cqw. Accessed | |
| March 12, 2012, and p. 9. Accessed August 14, 2013. | |
| 35 National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling, Chief Counsel’s Report: The | |
| Gulf Oil Disaster, February 17, 2011, p. 18, | |
| http://www.oilspillcommission.gov/sites/default/files/documents/C21462-408_CCR_for_web_0.pdf. Accessed | |
| August 14, 2013. | |
| 36 IADC, http://www.iadclexicon.org/drilling-margin/. Accessed May 28, 2014. | |
| 37 Transocean, Well Control Handbook - Level: L1B, Issue #3, Revision #1 - HQS-OPS-HP-01, pp BP-HZN- | |
| 2179MDL00330790. Publicly accessed at | |
| http://www.mdl2179trialdocs.com/releases/release201303071500008/TREX-00596.pdf. | |
| 38 §250.414 (c) (2010 and 2012). | |
| 39 §250.427(b) (2010 and 2012). | |
| 40 Department of the Interior, Report Regarding the Causes of the April 20, 2010 Macondo Well Blowout, September | |
| 14, 2011, http://docs.lib.noaa.gov/noaa_documents/DWH_IR/reports/dwhfinal.pdf. Accessed December 9, 2013. | |
| 41 Offshore Well Construction, 1st ed. Austin: University of Texas, 2005: p. 3.1; R. Mitchell and S.Miska, | |
| Fundamentals of Drilling Engineering, Society of Petroleum Engineers, 2011: p. 385. | |
| 42 D. Izon, E.P. Danenberger, and M. Mayes, “Absence of Fatalities in Blowouts Encouraging in MMS Study of | |
| OCS Incidents, 1992 – 2006,” Drilling Contractor, July/August 2007, pp.84-90. | |
| 43 S. Christman, Email and telephone communications (2013). | |
| 44 BP p.l.c., Deepwater Horizon Accident Investigation Report, September 8, 2010, p. 16, | |
| http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cts=1331666404195&ved=0CCkQFjAA | |
| &url=http%3A%2F%2Fwww.bp.com%2Fliveassets%2Fbp_internet%2Fglobalbp%2Fglobalbp_uk_english%2Finci | |
| dent_response%2FSTAGING%2Flocal_assets%2Fdownloads_pdfs%2FDeepwater_Horizon_Accident_Investigatio | |
| n_Report.pdf&ei=x55fT7qYJunIsQKFqPSMCA&usg=AFQjCNE4cEa7fTYS0DYjDfGY60zekb6cqw. Accessed | |
| March 12, 2012. | |
| 34 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| 45 BP p.l.c., Deepwater Horizon Accident Investigation Report, September 8, 2010, p. 33, | |
| http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cts=1331666404195&ved=0CCkQFjAA | |
| &url=http%3A%2F%2Fwww.bp.com%2Fliveassets%2Fbp_internet%2Fglobalbp%2Fglobalbp_uk_english%2Finci | |
| dent_response%2FSTAGING%2Flocal_assets%2Fdownloads_pdfs%2FDeepwater_Horizon_Accident_Investigatio | |
| n_Report.pdf&ei=x55fT7qYJunIsQKFqPSMCA&usg=AFQjCNE4cEa7fTYS0DYjDfGY60zekb6cqw. Accessed | |
| March 12, 2012. | |
| 46 30 C.F.R. § 250.1721(d) (2012). | |
| 47 30 C.F.R. § 250.1721(d) (2012). | |
| 48 Application for Permit to Modify, Lease G32306, Area/Block MC 252, | |
| http://www.mdl2179trialdocs.com/releases/release201305171200030/TREX-004032.pdf. Accessed August 8, 2010. | |
| 49 Application for Permit to Modify, Lease G32306, Area/Block MC 252, | |
| http://www.mdl2179trialdocs.com/releases/release201305171200030/TREX-004032.pdf. Accessed August 8, 2010. | |
| 50 Internal BP email, http://www.mdl2179trialdocs.com/releases/release201303141200012/TREX-00537.pdf. | |
| Accessed August 8, 2010; Internal BP email, | |
| http://www.mdl2179trialdocs.com/releases/release201303141200012/TREX-00097.pdf. Accessed August 8, 2010; | |
| Application for Permit to Modify, Lease G32306, Area/Block MC 252, | |
| http://www.mdl2179trialdocs.com/releases/release201305171200030/TREX-004032.pdf. Accessed August 8, 2010; | |
| Macondo Drilling Production lnterval BP01 rev1, | |
| http://www.mdl2179trialdocs.com/releases/release201303141200012/TREX-00836.pdf. Accessed August 8, 2010; | |
| Macondo Drilling Production lnterval BP01 rev2, | |
| http://www.mdl2179trialdocs.com/releases/release201303141200012/TREX-00545.pdf. Accessed August 8, 2010; | |
| Transocean report, pp. 80-86, MC 252 #1 STOOBP01 - Macondo Prospect; 7" x 9-7/8" Interval; Version H.1, April | |
| 12; p. 10; BP-HZN-CSB00022750; Emails, February 28. Fowler to Stoltz, et. al., and replies; BP-HZN- | |
| BLY00062447; Email, April 14, 2:07 p.m.: Morel to Wilson and Sepulvado; BP-HZN-CSB00160178; MC 252 #1 | |
| STOOBP01 - Macondo Prospect; 7" x 9-7/8" Interval, Version H.2, April 15; p. 8; BP-HZN-C S B00027980; MMS | |
| Form 124 APM; MC 252 #1; Temporary Abandonment Procedure _RevA.doc 4/16; BP-HZN-CSB00163048; | |
| Email, April 18, 10:37 a.m.: Morel to Guide, and reply; BP-HZN-BLY00070087; Email Ops note, April 20, 10:43 | |
| a.m.: Morel to Vidrine, et. al.; BP-HZN-CSB00056581. | |
| 51 Transocean, IADC Daily Drilling Report, Deepwater Horizon, Report No.34, April 20, 2010, 10:30 am – 12:00 | |
| p.m. TRN-USCG_MMS-00011644 - TRN-USCG_MMS-00011648. | |
| 52 Bureau of Ocean Energy Management Regulation and Enforcement (BOEMRE), March 11, 2011. Forensic | |
| Examination of Deepwater Horizon Blowout Preventer, Report No. EP030842, p. 15. | |
| http://www.uscg.mil/hq/cg5/cg545/dw/exhib/DNV%20Report%20EP030842%20for%20BOEMRE%20Volume%2 | |
| 0I.pdf. Accessed March 12, 2012. | |
| 53 Transocean, Macondo Well Incident: Transocean Investigation Report Volume II, June 2011, | |
| https://www.deepwater.com/_filelib/FileCabinet/pdfs/12_TRANSOCEAN_Vol_2.pdf, Appendix H. Accessed | |
| December 9, 2013. | |
| 54 Hearing before the Deepwater Horizon Joint Investigation, May 29, 2010, p. 10. | |
| (http://www.mdl2179trialdocs.com/releases/release201304110900026/TREX-37031.pdf, pp. BP-HZN- | |
| BLY00377488 – 489. Accessed August 9, 2013. The interview notes state “gas buster,” which is another name used | |
| for the MGS. | |
| 55 Hearing before the Deepwater Horizon Joint Investigation, May 28, 2010, p. 145; Hearing before the Deepwater | |
| Horizon Joint Investigation, May 27, 2010, pp. 11 and 190. | |
| 56 BP plc (BP), Deepwater Horizon accident investigation report, September 8, 2010, | |
| http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cts=1331666404195&ved=0CCkQFjAA | |
| &url=http%3A%2F%2Fwww.bp.com%2Fliveassets%2Fbp_internet%2Fglobalbp%2Fglobalbp_uk_english%2Finci | |
| dent_response%2FSTAGING%2Flocal_assets%2Fdownloads_pdfs%2FDeepwater_Horizon_Accident_Investigatio | |
| 35 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| n_Report.pdf&ei=x55fT7qYJunIsQKFqPSMCA&usg=AFQjCNE4cEa7fTYS0DYjDfGY60zekb6cqw. Accessed | |
| March 12, 2012, and p. 9, accessed August 14, 2013. | |
| 57 National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling, Chief Counsel’s Report: The | |
| Gulf Oil Disaster, February 17, 2011, p. 18, | |
| http://www.oilspillcommission.gov/sites/default/files/documents/C21462-408_CCR_for_web_0.pdf. Accessed | |
| August 14, 2013. | |
| 36 | |
| Macondo | |
| Investigation Report Volume 1 | |
| June 5, 2014 | |
| 37 |