We have completed all 26 recommendations made by BP’s investigation into the Deepwater Horizon accident, the Bly Report
The 26 recommendations look at internal practices and systems as well as our contractor and service provider oversight, with some of them dependent on the co-operation of entities outside BP.
BP’s drilling operating practices and management systems
1. Update and clarify cementing guidelines
Update and clarify current practices to ensure that a clear and comprehensive set of cementing guidelines and associated Engineering Technical Practices (ETPs) are available as controlled standards. The practices should include, as a minimum:
- Clearly defined mandatory practices.
- Recommended practices and operational guidance.
- Definitions of critical cement jobs.
- Description of the technical authority’s (TA’s) role in oversight and decision making.
Deepwater Horizon Accident Investigation Report (the Bly Report)
2. Update requirements for subsea BOP configuration
Review and update ETP GP 10-10 Well Control, clarifying requirements for subsea blowout preventer (BOP) configuration:
- Establish minimum requirements for ram types, numbers and capability.
- Establish minimum requirements for emergency well control activation systems.
- Conduct a gap assessment of the BP-operated and BP-contracted rig fleet and put corrective actions in place to assure conformance.
3. Update requirements for negative pressure tests and lock-down rings
Update the relevant technical practices to incorporate the following design requirements: BPA-D-003Tubular Design Manual: Consider load conditions for negative-pressure tests in the casing design assessment for subsea wells DWOP: Standardize the installation of the locking mechanism of the casing hanger seal assembly to the high-pressure housing for subsea wellheads.
4. Update practice on pressure, including contingency and testing procedures
Review and update ETP GP 10-45 Working with Pressure to include negative-pressure testing; this practice should provide as a minimum:
- The purpose of the test.
- A definition of the barriers to be tested.
- Identification and evaluation of the consequences of failure.
- A contingency plan of action in the event that failures occur.
- A requirement for detailed procedures which should include as an example.
- The configuration of test lines and correct valve positions.
- All operational steps and decision points.
- A description of the roles and accountabilities for the personnel involved.
- Clearly defined success/failure criteria for the test.
- Authorization instructions if results are outside the defined success criteria.
- Assurance that contractor procedures are consistent with ETP GP 10-45.Section 6. Investigation Recommendations.
5. Strengthen incident reporting standards for well control and well integrity
Clarify and strengthen standards for well control and well integrity incident reporting and investigation. Ensure that all incidents are rigorously investigated and that close out of corrective actions are completed effectively.
6. Propose recommended practice for foam cement testing to API
Propose to the American Petroleum Institute the development of a recommended practice for design and testing of foam cement slurries in high-pressure, high-temperature applications.
7. Assess risk management and MOC processes for lifecycle of D&C activities
Review and assess the consistency, rigour and effectiveness of the current risk management and management of change (MOC) processes practiced by Drilling and Completions (D&C) by:
- Implementing an action plan to address areas that should be strengthened to conform with OMS expectations.
- Defining minimum requirements of D&C functional teams to deliver consistent and effective application of MOC and risk mitigation from planning through execution.
- Assessing high-consequence drilling activities as a priority, starting with the Gulf of Mexico Exploration and Appraisal drilling team.
8. Strengthen the technical authority's role in cementing and zonal isolation
Reassess and strengthen the current TA’s role in the areas of cementing and zonal isolation. Ensure adequate TA coverage to support all the D&C global operations. As a minimum, a TA should:
- Review and approve all critical zonal isolation engineering plans and procedures.
- Provide assurance of contractors for all services related to zonal isolation engineering and technical services, including engineering competency, service quality and adherence to relevant standards.
9. Enhance drilling and completions competency programs for key operational and leadership positions
Enhance D&C competency programs to deepen the capabilities of personnel in key operational and leadership positions and augment existing knowledge and proficiency in managing deepwater drilling and wells operations by:
- Defining the key roles to be included in the enhanced competency programmes.
- Defining critical leadership and technical competencies.
- Creating a ‘Deepwater Drilling Leadership Development Programme.’ The programme would build proficiency and deepen capabilities through advanced training and the practical application of skills.
- Developing a certification process to assure and maintain proficiency. Conduct periodic assessments of competency that include testing of knowledge and demonstrations of the practical application of skills.
10. Develop advanced deepwater well control training
Develop an advanced deepwater well control training programme that supplements current industry and regulatory training. Training outcomes would be the development of greater response capability and a deeper understanding of the unique well control conditions that exist in deepwater drilling. This programme should:
- Embed lessons learned from Deepwater Horizon accident.
- Require mandatory attendance and successful completion of the programme for all BP and drilling contractor staff who are directly involved in deepwater operations, specifically supervisory and engineering staff, both onshore and offshore.
- Where appropriate, seek opportunities to engage the broader drilling industry to widen and share learning.
11. Establish BP in-house expertise for subsea BOP & BOP control systems
Establish BP’s in-house expertise in the areas of subsea BOPs and BOP control systems through the creation of a central expert team, including a defined segment engineering technical authority (SETA) role to provide independent assurance of the integrity of drilling contractors’ BOPs and BOP control systems. A formalized set of authorities and accountabilities for the SETA role should be defined.
12. Request IADC to develop subsea engineering certification
Request that the International Association of Drilling Contractors review and consider the need to develop a programme for formal subsea engineering certification of personnel who are responsible for the maintenance and modification of deepwater BOPs and control systems.
13. Strengthen BP's rig audit process to improve closure and verification of audit findings and actions across BP-owned and BP-contracted drilling rigs
14. Establish key performance indicators for well integrity, well control, and rig safety-critical equipment
Establish D&C leading and lagging indicators for well integrity, well control and rig safety critical equipment, to include but not be limited to:
- Dispensations from DWOP.
- Loss of containment (e.g., activation of BOP in response to a well control incident).
- Overdue scheduled critical maintenance on BOP systems.
15. Require drilling contractors to implement auditable integrity monitoring system
Require drilling contractors to implement an auditable integrity monitoring system to continuously assess and improve the integrity performance of well control equipment against a set of established leading and lagging indicators.
Contractor and service provider oversight and assurance
16. Assess cementing service provider capabilities
Conduct an immediate review of the quality of the services provided by all cementing service providers. Confirm that adequate oversight and controls are in place within the service provider’s organization and BP regarding:
- Compliance with applicable service provider, BP and industry standards.
- Competency of engineering and supervisory personnel.
- Effective identification, communication and mitigation of risk associated with providers’ services.
17. Confirm well control and monitoring practices are defined and applied
Assess and confirm that essential well control and well monitoring practices, such as well monitoring and shut-in procedures, are clearly defined and rigorously applied on all BP-owned and BP-contracted offshore rigs (consider extending to selected onshore rigs such as those for high-pressure, high-temperature, extended reach drilling [ERD] and sour service applications). These practices should be:
- Defined and codified as BP minimum standards for demonstrated practice and proficiency.
- Formally bridged into contractor rig site well control policies and procedures, with a self-verification and reporting process.
- Reinforced by regular audit by BP well site leaders.
18. Require hazard and operability reviews for surface gas/drilling fluid systems
Require hazard and operability (HAZOP) reviews of the surface gas and drilling fluid systems for all BP-owned and BP-contracted drilling rigs. Include a HAZOP review as an explicit check for rig acceptance and rig audit. Phase 1 should address offshore rigs. Phase 2 should address selected onshore rigs such as those for high-pressure, high-temperature, ERD and sour services applications.
19. Include study of all surface system hydrocarbon vents in all HAZOPs
Include in the HAZOP reviews a study of all surface system hydrocarbon vents, reviewing suitability of location and design.
20. Establish minimum levels of redundancy and reliability for BOP systems
Establish minimum levels of redundancy and reliability for BP’s BOP systems. Require drilling contractors to implement an auditable risk management process to ensure that their BOP systems are operated above these minimum levels.
21. Strengthen BP's requirements for BOP testing by drilling contractors, including emergency systems
Strengthen BP’s minimum requirements for drilling contractors’ BOP testing, including emergency systems. Require drilling contractors to:
- Demonstrate that their testing protocols meet or exceed BP’s minimum requirements.
- Perform self-audits and report conformance with their own protocols.
22. Strengthen BP's requirements for BOP maintenance management systems by drilling contractors
Strengthen BP’s minimum requirements for drilling contractors’ BOP maintenance management systems. Require drilling contractors to:
- Demonstrate that their maintenance management systems meet or exceed BP’s minimum requirements.
- Perform self-audits and report results to confirm conformance with their own management systems.
23. Set minimum requirements for drilling contractors' MOC for subsea BOPs
Define BP’s minimum requirements for drilling contractors’ MOCs for subsea BOPs. Require drilling contractors to:
- Demonstrate that their MOC systems meet or exceed BP’s minimum requirements.
- Perform self-audits and report results to confirm conformance with their own MOC processes.
24. Develop a clear plan for remotely operated vehicle (ROV) intervention for each subsea BOP
Develop a clear plan for ROV intervention (independent of the rig-based ROV) as part of the emergency BOP operations in each of BP’s operating regions, including all emergency options for shearing pipe and sealing the wellbore.
25. Require contractors to verify blind shear ram performance capability
Require drilling contractors to implement a qualification process to verify that shearing performance capability of BSRs is compatible with the inherent variations in wall thickness, material strength and toughness of the rig drill pipe inventory.
26. Include testing and verification of revised BOP standards in rig audit
Include testing and verification of conformance with Recommendations 20 through 25 (entitled 8.1 through 8.6 in the full report) in the rig audit process.