The Bureau of Ocean Energy Management, Regulation and Enforcement (BOEMRE)Atlantis Report (PDF) that Lorinda Pike covered in her Gulf Watchers Sunday - It Was Dangerous Paperwork - BP Catastrophe AUV #483 diary has been released. The report states that there is no regulatory requirement that deepwater rig operators must have correctly labeled, accessible engineering documents available.
Whistle blower Ken Abbott, a former safety consultant, filed a lawsuit against BP under the federal False Claims Act alleging that they did not have drawings that accurately showed how subsea parts of the Atlantis platform were built. "As-built" documents can differ dramatically from original design documents.
Food and Water Watch later joined Abbot in his suit.
After reviewing the actual report any rational person would fully agree with the plaintiff's comments cited in Lorinda's diary.
BP Atlantis platform cleared on safety issue
Abbott said in a statement that he was "disappointed but not really surprised." He took a jab at the ocean energy bureau, previously known as the Minerals Management Service, which he said aims first "to protect themselves and then the oil companies."
"They may have changed their name, but not their way of operating," Abbott said. Abbott vowed to continue pressing his case, which has been joined by Food and Water Watch, an environmental advocacy organization.
The group's executive director, Wenonah Hauter, said the bureau's report was "seriously flawed" and showed the agency was "protecting the interests of its industry cronies, rather than the public."
"The federal government dragged its feet on this investigation, and its findings are appalling - like a doctor's note for a truant student," Hauter said. "They are a weak attempt to cover BP's foul play. After all this time, the public deserves better."
BOEMRE concludes that the engineering documents on the Atlantis are a disorganized mess but seems to take the word of people still collecting BP paychecks that everything is perfectly safe. Despite claims that they reviewed 3,400 engineering drawings and related documents I could not find any evidence in the report itself that the BOEMRE even knows what documents should be on the rig, let alone whether or not they are actually there and readily available to the people who need them.
This bizarre quote is from the Atlantis Documents Investigation BOEMRE Press Release.
Based on a thorough review of the evidence, the investigation found the majority of the allegations to be unfounded, but did find that there were a number of problems with the way that BP organized, stored, and labeled engineering drawings and documents. BOEMRE found no evidence that these documentation deficiencies created specific unsafe conditions on the Atlantis production platform.
BOEMRE seems to think that BP's Guidance on Certification and Systems Handover Packages provide an adequate and safe substitute for having engineering documents properly organized, labeled and readily available. However, there is no mention in these procedures stating that people on the rig should have ready access to properly labeled original design documents, all subsequent changes and "as-built" documents.
According to the BOEMRE report, they have not worried their pointy little heads in requiring deepwater drillers to have properly labeled and organized engineering documents. Only in BOEMRE's and big oil's universe would any sane human consider tolerating this sorry state of affairs to be safe.
From the BOEMRE report:
BP’s efforts to organize and track Atlantis drawings and documents were further complicated by BP’s practice of not labeling certain drawings “as built,” even when those drawings depicted a structure or system as it was installed. BP decided that it was unnecessary to update drawings with an “as built” stamp or label if the drawing had not been revised from earlier versions (e.g., Issued for Design, Issued for Construction, etc.).
We found that BP’s engineering drawings relating to the Atlantis facility, which were prepared by a number of different contactors, were inconsistently labeled. BP acknowledged these labeling problems in a letter accompanying its submission of documents to BOEMRE. The letter, dated August 9, 2010, stated:
Because the enclosed drawings were prepared by several different engineering firms, the nomenclature used to indicate the revision status of drawings differs among the numerous drawings contained in the enclosed books. For example, drawings by DSME used “Rev. 60” to denote an “as built” drawing, while “as built” drawings by FMC Technologies were typically labeled “design” because FMC builds equipment and structures to design.
Our review of the Atlantis engineering drawings also found that some drawings had inconsistent, undated, or missing engineer stamps. Other drawings had missing drawing numbers. We found that at least one of the subsea field architecture drawings was inconsistent with a subsea start‐up chronology provided by BP.
These problems arose because BP did not require its Atlantis subsea contractors to conform engineering drawings and documents to a single, uniform set of standards established by the company. BP instead allowed its contractors to develop drawings and documents under their own respective documentation systems. Because there were a significant number of contractors involved in the Atlantis project, this led to a proliferation of inconsistent labeling conventions and the other document identification problems that we observed.
These labeling and documentation problems alone do not constitute a violation of BOEMRE’s regulations. Current BOEMRE regulations do not address how engineering drawings are to be stamped, organized and labeled.
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