THE BUREAU OF OCEAN ENERGY MANAGEMENT,  

REGULATION AND ENFORCEMENT

Investigations and Review Unit

BP’S ATLANTIS OIL AND GAS PRODUCTION PLATFORM:

AN INVESTIGATION OF ALLEGATIONS THAT OPERATIONS

PERSONNEL DID NOT HAVE ACCESS TO ENGINEER‐APPROVED

DRAWINGS

March 4, 2011
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BP’s Atlantis Oil and Gas Production Platform:  An Investigation of

Allegations That BP Did Not Have Access to Engineer‐Approved Drawings

TABLE OF CONTENTS

  

EXECUTIVE SUMMARY.................................................................. 1  

I. Background

A. BP and the Atlantis Production Facility....................................   3

1. BP’s Deepwater Production Operations.................................   3

2. The Atlantis Field..............................................................   3

3. Design, Fabrication and Installation of the Atlantis Production

Platform...........................................................................   3

4. The Atlantis Facility’s Subsea System....................................   4

5. Refurbishment and Reinstallation of the Atlantis  

Subsea Equipment........................................................   5

6. The Atlantis Handover Process............................................   6

7. Atlantis Operations ...........................................................  7

8. Problems with the Atlantis Facility’s Subsea Documentation .....   8

B. Applicable BOEMRE Regulations

1. Production Safety Systems.................................................. 11

2. Platforms and Structures.................................................... 13

3. Pipelines......................................................................... 14

4. Other Relevant Regulatory Provisions................................... 14

II. Inspection and Review of the Atlantis Facility.................................. 16

A. BOEMRE’s Regulatory Review.................................................. 16

B. U.S. Coast Guard Regulatory Review.........................................17

C. Review by the Certified Verification Agent...................................17

III. Abbott Litigation and Related Inquiries...........................................18

A. Kenneth Abbott’s Lawsuits...................................................... 18

B. Congressional Inquiries.......................................................... 19

C. BP’s Ombudsman..................................................................20

IV. BOEMRE’s Investigation..............................................................23

A. Overview of the Investigation.................................................. 23

B. The Scope and Timing of the Investigation................................. 23
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V. Allegations, Evidence, and Findings.............................................. 25

A. Production Safety Systems....................................................... 25

B. Violation of 30 C.F.R. § 250.802..................................................25

C. ROV Inspection of Subsea Structures........................................... 25

D. Documentation Problems in the BP Atlantis Project Files...............26

1. Electronic Database Problems..............................................26

2. Engineering Drawings—Labeling and Related Problems........... 27

E. Engineering Drawings—Allegedly Unapproved or  

Not “As Built”............................................................... 28

1. Allegations........................................................................ 28

2. Evidence cited by Mr. Abbott......... ...........................................29

a. The Duff Spreadsheet.......................................................... 29

b. E‐mails....................................................................... 29

c. Conversations with BP Employees....................................30

3. Findings.............................................................................30

a. The Duff Spreadsheet.................................................... 31

b. E‐mails....................................................................... 32

c. Conversations with BP Employees................................... 33

F. Alleged False or Incomplete Submissions to BOEMRE—

Submission of Structural Drawings..................................... 36

1. Allegations......................................................................  36

2. Evidence Cited by Mr. Abbott............................................... 37

3. Findings......................................................................... 37

G. Alleged False or Incomplete Submissions to BOEMRE—

Verification by Certified Verification Agent (CVA)................ 38

1. Allegations...................................................................... 38

2. Evidence Cited by Mr. Abbott................................ ............... 38

3. Findings..........................................................................38

H. Alleged False or Incomplete Submissions to BOEMRE—

Statements About “As Built” Documents............................... 39

1. Allegations....................................................................... 39

2. Evidence Cited by Mr. Abbott.............................................. 39

3. Findings..........................................................................39

I. Alleged False or Incomplete Submissions to BOEMRE—

Deep Water Operations Plan (DWOP) and Safety Hazard  

Analysis (HAZOP).............................................................40

1. Allegations....................................................................... 40

2. Evidence Cited by Mr. Abbott.............................................. 40

3. Findings..........................................................................40
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J. Alleged Unsafe Operating Conditions....................................... 41

1. Allegations....................................................................... 41

2. Evidence Cited by Mr. Abbott.............................................. 41

3. Findings..........................................................................41

RECOMMENDATIONS.................................................................... 43

CONCLUSION.............................................................................. 44
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EXECUTIVE SUMMARY

BP Exploration and Oil, Inc. (BP) operates the Atlantis oil and gas

production facility in the Gulf of Mexico.  In April 2009, Kenneth A. Abbott, a

former BP contractor, filed a lawsuit against BP under the False Claims Act,

alleging that BP did not maintain copies of engineer‐approved drawings for the

Atlantis facility, as required under regulations promulgated by the Bureau of

Ocean Energy Management, Regulation and Enforcement (BOEMRE).  Mr.

Abbott alleges that this lack of documentation has created imminent and

significant safety risks on the Atlantis facility.    

BOEMRE conducted an extensive investigation of the engineering

drawings and documents depicting the relevant components of the Atlantis

facility.  BOEMRE also evaluated safety concerns raised first by Mr. Abbott and

then by certain members of Congress.     

Our investigation found that the electronic document database that BP

used to store documents developed during the design, construction, and

installation of the Atlantis production facility was disorganized and inadequate

to handle the large volume of documents generated by BP and its third‐party

contractors.   In addition, BP used a confusing labeling system for engineering

drawings contained in the project files.  Those drawings also had other defects

and deficiencies, including undated and missing stamps and signatures, and

inconsistent titles for types of drawings.

Although many of the documents and drawings contained in the

electronic database had these deficiencies, the documents in the electronic

database were not the materials relied upon by Atlantis operations personnel.   

We found that BP’s process for transferring the drawings and documents used

by operations personnel on the Atlantis facility involved the use of “systems

handover packages.”  The systems handover packages, which included

engineering documents and drawings, were compiled by a team of BP personnel

that included engineers with knowledge of each type of component being

handed over and then transferred to the Atlantis facility prior to the start of

production.   

Our investigation found that Mr. Abbott’s allegations that Atlantis

operations personnel lacked access to critical, engineer‐approved drawings are

without merit.  Mr. Abbott and a colleague were working on a document‐update

project during Mr. Abbott’s time working for BP.  We found no evidence that the
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document control deficiencies, which were being addressed in 2008 and 2009 by

Mr. Abbott and his team, created specific unsafe conditions on the Atlantis

production platform.  Nor did we find any evidence suggesting that, at the time

he and his team were working to correct documentation issues, Mr. Abbott was

in a position to evaluate whether these documentation deficiencies affected the

safety of operations on the Atlantis facility.  Our investigation further concluded

that Mr. Abbott’s allegations about false submissions by BP to BOEMRE are

unfounded.     

Although Mr. Abbott’s core allegations are unsupported by the evidence,

our investigation determined that BP failed to file with BOEMRE certain

drawings depicting changes to a number of production safety system

components, in violation of 30 C.F.R. § 250.802.   BOEMRE has issued an incident

of non‐compliance (INC) to BP as a result of this finding.   

Based upon our investigation, prior inspections, and review of documents

submitted by BP during the permitting process, we concluded that there is no

evidence to suggest that documents and drawings submitted by BP fail to

accurately reflect the production safety systems installed on the Atlantis facility.   

Based on all evidence developed during our investigation, as well as prior

inspections and a thorough review by BOEMRE of documents and drawings

produced by BP, we found no grounds for suspending the operations of the

Atlantis pursuant to 30 C.F.R. § 250.168 or revoking BP’s designation as an

operator under 30 C.F.R. § 250.135.  
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I. Background

A. BP and the Atlantis Production Facility

1. BP’s Deepwater Production Operations

BP has invested over $14 billion in deepwater projects in the Gulf of

Mexico since 1994, and is one the most significant industry participants in the

Gulf.  Over the past 15 years, the company has significantly increased its

deepwater production in the Gulf of Mexico.  Deepwater production presents a

host of challenges, including high pressures, high reservoir temperatures, low

water temperatures, long distances between wells and production facilities, and

heavy crudes.  These challenges increase the complexities associated with subsea

production and have demanded sophisticated technological solutions.  In the

Gulf of Mexico, BP produces from more than twenty deepwater fields, including

Pompano, Marlin, Horn Mountain, Na Kika, Holstein, Mad Dog, Atlantis and

Thunder Horse.    

2. The Atlantis Field

The Atlantis field (also known as the Green Canyon 743 field) includes

Green Canyon blocks 699, 700, 742, 743, and 744 and is located the Central Gulf

of Mexico about 190 miles south of New Orleans, Louisiana.  BP and BHP Billiton

jointly acquired leases on these blocks under OCS Sale 152 (held on May 10,

1995).  BHP retains a 44% working interest in the project, and BP is the

designated operator.     

BP has estimated that the Atlantis field contains recoverable reserves of

approximately 635 million barrels of oil equivalents in sixteen different

production wells.  The Atlantis field also contains four water injection wells.   

3. Design, Fabrication and Installation of the Atlantis

Production Platform

BP contracted with GVA Consulting, a division of KBR, to design a 58,700

metric ton semi‐submersible platform to produce in the deepwater Atlantis field.   

Mustang Engineering was retained as the structural engineering design firm for

the Atlantis field, and their services included providing engineering support

during shipyard construction.   
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The fabrication and integration of the components of the Atlantis platform

occurred in several steps, and those components were completed in 2005.  

Daewoo Shipbuilding and Marine Engineering Co., Ltd. (DSME) fabricated the

hull of the Atlantis platform in Pusan, Korea.1  The three topside modules were

fabricated by McDermott International, Inc. in Morgan City, Louisiana.  KBR

performed the integration work at a yard near Ingleside, Texas.   

ABS was the independent Certified Verification Agent (CVA) responsible

for assessing the design, fabrication, and installation of the Atlantis production

platform.   

4. The Atlantis Facility’s Subsea System

The Atlantis platform’s subsea system is comprised of subsea trees,

pipeline end terminations (PLETs), manifolds, flowlines, risers, umbilicals,

jumpers, and other components.   In the Atlantis subsea system, there are sixteen

production wells that are (or are planned to be) connected to four production

manifolds.  Each production manifold is designed to serve four wells.    

The configuration of the Atlantis subsea system is depicted in Exhibit 2

attached to this Report.  Each subsea tree is connected to a riser and the Atlantis

platform by a series of flowlines, manifolds, and jumpers.  The production trees

are equipped with remotely actuated, adjustable chokes to provide flow and

pressure control.  The subsea trees are operated by an electro‐hydraulic

multiplexed control system.  Flying leads provide electrical power, control

signals, hydraulic power, and chemical supplies to the subsea trees.  A subsea

control module (SCM) decodes electrical signals and directs hydraulic power to

various subsea tree functions.  The umbilicals and leads function as a distribution

network for the subsea control system.  All control functions are managed from a

control station located on the production platform.   

The Atlantis subsea components were manufactured by a number of

different contractors that BP selected for its major deepwater projects in the Gulf

of Mexico – including Thunder Horse, Mad Dog, and Holstein.  Technip USA,

Inc. was the primary engineering consulting firm for subsea pipeline

development.  FMC Corporation provided detailed design of the subsea

equipment, including wellhead equipment, tree systems, manifold systems,

 

1   Exhibit 1 provides a list of acronyms used in this Report.   
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PLET assemblies, flowline jumper assemblies, subsea control system, topside

control equipment, and ROV docking.2  

5. Refurbishment and Reinstallation of the Atlantis

Subsea Equipment

In April 2006, BP discovered a metallurgical anomaly in the manifold

systems that were part of the Thunder Horse subsea system.  This discovery

caused BP to become concerned about potential corrosion in the Thunder Horse

manifold systems.  As a result, BP decided to replace the Thunder Horse

manifold systems to prevent the inadvertent discharge of hydrocarbons into the

Gulf of Mexico.  After diagnosing the problem with the Thunder Horse manifold

systems, BP decided to reconstruct the Atlantis manifold systems to avoid

similar potential problems with the Atlantis facility.   

BP evaluated a number of options to address the potential problems with

the Atlantis subsea equipment.  BP developed a plan to reconstruct the Atlantis

manifolds and PLETs and to build new PLEMs.  These changes to the Atlantis

subsea system were designed to eliminate the problematic metallurgy

combination that had been identified in the subsea system installed in the

Thunder Horse facility.  BP concluded that these changes would significantly

reduce the risk of internal corrosion in Atlantis’s subsea components.

BP retrieved the four Atlantis manifolds that had already been installed

on the sea floor.  These manifolds, which were designed to include multi‐

function valves, were modified to be “valveless.”  The modified manifolds

offered less flexibility in well production operations, but were generally easier to

operate than the originally installed manifolds.     

The switch‐out of the Atlantis manifolds, PLETs, and PLEMs created a

number of design and plan document control challenges.  BP attempted to avoid

confusion in its document control system (at times referred to as the “Atlantis

Documentum”) by referring to the original set of manifolds, PLETs, and PLEMs

 

2   Other contractors for the Atlantis subsea system included:  Nexans Norway AS

(umbilical engineering and fabrication); Subsea 7 (installation of umbilicals); Stress Engineering

Services, Inc. (engineering and technical services and verification services); Acute Technical

Services, Inc. (welding technical services); Omega Natchiq Inc. (fabrication of PLEMs); Cameron

Flow Control (subsea chokes); Honeywell, Inc. (control system software); the Bayou Companies

(pipe fabrication for flow lines and risers) and Heerema Marine Contractors (flowline and riser

installation).   
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as “SS‐0” and to the first generation of refurbished subsea equipment as “SS‐1.”  

The equipment included in SS‐1 is anticipated to have a useful life through 2012.  

BP plans to install “SS‐2” subsea equipment, which BP believes will have an

extended useful life, during 2012.   

BP has estimated that the refurbishment and installation of the subsea

equipment (through SS‐2) will cost in excess of $115 million.  The company

concluded that the changes were necessary to prevent a possible manifold failure

that could have resulted in hydrocarbons leaking into the Gulf of Mexico.  See

Exhibit 3 (MOC request dated 9/7/07).      

6. The Atlantis Handover Process

BP developed a set of detailed procedures called “Guidance on

Certification.”  These procedures are intended to ensure that, prior to the start of

the production of oil (often referred to as “first oil”), personnel with

responsibility for operations of a production platform are provided with access

to the documentation and drawings that BP believes are necessary to ensure safe

operation of the platform and the associated subsea system.  The following is a

description of the applicable procedures (for both topside and subsea

equipment):

 Certificate of Compliance.  This procedure requires that the company

that fabricates a piece of equipment, part, or component has inspected

the item to ensure that it meets all contract requirements.

 Inspection Release Certificate.  This procedure requires BP personnel

to inspect and sign off on a piece of equipment, part, or component

after personnel conclude that the item is ready for service.   

 Well Handover Certificate.  This procedure requires that the well

completions supervisor and the offshore subsea supervisor certify that

certain documents – including well schematics, well fluid summaries,

datasheets, ROV surveys, and safety valve certifications – are

complete.  After the well site leader authorizes a certificate stating that

all documents are complete, the subsea team lead reviews the

certification.  Finally, the offshore installation manager (OIM) signs the

certification, which states that the well is ready for initial production.
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 Mechanical Completion.  This procedure requires BP personnel to

function test all equipment and systems to verify that they were

constructed, installed, and maintained in accordance with design

drawings and maintenance schedules.  After this verification, the pre‐

commissioning manager signs the document accepting that the

systems have been properly handed over for pre‐commissioning.

 System Handover.  This procedure requires the pre‐commissioning

manager to state that all systems have been commissioned and that

they are ready for operations.  The subsea team leader and the OIM

then sign a document accepting the handover.  After this step, the

transfer of documents to the platform is complete and production

operations can begin.   

For the Atlantis project, BP followed each of the above procedures prior to

the start of production.  In addition, with respect to the subsea handover process,

the Atlantis subsea team designed a more detailed process to specifically

determine how the subsea systems would be handed over to operations

personnel.  This included work on how the Mechanical Completion packages

and the System Handover Packages would be structured, and Atlantis

operations personnel provided input on how the subsea handover process

should work.   

The subsea Systems Handover Packages for the Atlantis facility included

drawings that had been reviewed by the subsea team leader to ensure that the

drawings depicted the systems and equipment as they were installed.  Drawings

that had been revised or needed to be revised were identified on an “incomplete

work list.”  BP had a procedure in place designed to ensure that updated

drawings from the incomplete work list were provided to operations personnel.  

See Exhibit 4 (Atlantis Systems Handover Procedure).  

All system handover packages were transferred to the Atlantis operations

team before first oil and signed by the OIM.  The system handover packages

included drawings depicting both topside and subsea structures.    

  

7. Atlantis Operations

The Atlantis platform operates in more than 7,000 feet of water, deeper

than any other moored semi‐submersible platform in the world.  The Atlantis

facility is also one of the largest moored semi‐submersible platforms in the
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world.  The Atlantis field size, water depth and reservoir structure have made it

a technologically challenging deepwater oil production project.   

The Atlantis platform began production from two wells in October 2007.  

By 2010, there were twelve production wells in operation in the Atlantis field.  

The Atlantis facility’s current production capacity is estimated at 200,000 barrels

of oil and 180 million cubic feet of gas per day.  Oil and gas is transported to

existing Outer Continental Shelf (OCS) and onshore interconnections via the

Mardi Gras Transportation System.  Exhibit 5 shows the Atlantis production flow

process.   

8. Problems with the Atlantis Facility’s Subsea

Documentation

The design, fabrication, installation, testing, commissioning, start‐up, and

operation of the subsea system for the Atlantis facility has, to date, generated

over 13,000 documents and drawings.  These documents and drawings have

been generated by BP as well as its third‐party contractors.  In the early stages of

the project, Mustang Engineering had the responsibility for organizing the

Atlantis project subsea documents.  Most of these documents had been provided

to Mustang by Technip.  By all accounts, the Atlantis project documents were not

organized well.  These documents, which included drawings of various sectors

of the Atlantis production and subsea systems, were stored in an electronic

database that lacked adequate organizational structure.   

In 2007, BP’s Gulf of Mexico operations began implementing a document

control standards system called “Documentum.”  The Documentum system was

a database in which all project documents could be stored, including all

documents that had been included in the System Handover Packages.  Both

Atlantis and Thunder Horse project documents were stored in Documentum.   

The complete universe of subsea project documents related to the Atlantis

facility is much more expansive than the handover packages that were delivered

to BP Atlantis operations personnel.  For example, project documents include

early drafts and notes, as well as superseded or obsolete items.  All of these

project documents were maintained in Documentum.

The changes to the Atlantis subsea manifolds, PLETs, and PLEMs, as well

as the plan to add additional wells to the subsea system after first oil, further

complicated the process of organizing the Atlantis subsea documents.  Typically,
13

project files do not need to be updated following the beginning of production

and all relevant drawings and documents are transferred to operations before

first oil.  However, with the Atlantis facility, there were a number of “project

phases” that were initiated long after first oil, resulting in the continued addition

of documents and drawings to the Atlantis Documentum.   

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.).   

In 2008, Barry Duff, project services lead for the Atlantis facility, and

Tinikka Curtis, a document management clerk, began work on organizing the

Atlantis project documents contained in Documentum.  Mr. Duff and Ms. Curtis

used a Technip‐generated register of documents to build a spreadsheet listing

documents and drawings by “sector” or type of equipment (e.g., risers, controls,

jumpers, trees, etc.).   

In August 2008, Mr. Duff began transitioning to a new position, and BP

retained Kenneth Abbott, a third‐party contractor, to replace Mr. Duff as a

project controls lead for the Atlantis project.  On August 15, 2008, Mr. Duff sent

an e‐mail to his supervisors expressing concern about transferring any Atlantis

project documents to operations personnel prior to the re‐organization of the

Documentum.  Mr. Duff stated that transfer of documents to operations

personnel prior to re‐organization of Documentum “could lead to catastrophic

Operator errors.”  See Exhibit 6.

Mr. Duff’s e‐mail was prompted by a request by BP operations employee

Nita Oza for the transfer of the remaining Atlantis project documents.  Ms. Oza

was working with 2H, a third‐party contractor, on a Gulf of Mexico‐wide

maintenance and inspection plan for installed subsea equipment.  The contractor

requested access to all Atlantis project documents, regardless of whether they

had already been formally handed over to operations personnel.   

Mr. Duff wanted to re‐organize the project documents before sending

them to operations, and he informed Mr. Abbott of this when he transferred his

responsibilities to Mr. Abbott.   
14

When Mr. Abbott began his work on the Atlantis project, he focused on

project scheduling and budgeting, which were his main responsibilities as project

controls lead.  Ms. Curtis continued to work on re‐organizing the Documentum

database.  In November 2008, Bill Broman, Atlantis subsea delivery manager,

sent an e‐mail to the BP Atlantis project engineering team leads attaching

spreadsheets organized by “sector” of the overall Atlantis system.  In this e‐mail,

Mr. Broman encouraged each of the leads to work with Ms. Curtis to update

Documentum.  See Exhibit 7.   

Mr. Abbott’s contract with BP ended before Ms. Curtis completed work

updating and organizing the BP Atlantis documents in Documentum.  In 2009, a

team led by Bob Peloubet, Engineering Manager, and John McDougal, Subsea

Document Control Manager, took over this work and oversaw the reorganization

of the Atlantis subsea documents in Documentum.  This team instituted new

folder structures and document naming conventions within Documentum.  By

2010, the Atlantis subsea document control process had improved significantly.3   

See Exhibit 8 for an overview of the improvements made to the Atlantis

document control process.   

B. Applicable BOEMRE Regulations

BOEMRE regulates companies engaged in offshore production of oil and

gas on the OCS and is responsible for ensuring compliance with federal

regulations that govern the design, fabrication, installation, and operation of

production facilities, as well as certain documentation requirements.  Applicable

documentation regulations require that:  (1) BOEMRE be provided with

complete, accurate, and detailed information about each production platform on

the OCS; and (2) operators have access to the documents and drawings necessary

to ensure safe operations and documents necessary for contingency planning.  

These requirements are important to ensuring safe production operations on the

OCS.   

Because not all components of complex oil and gas production facilities –

particularly those on the seafloor – can be physically inspected, it is important

that operators maintain engineering drawing sets representing those components

 

3   Atlantis operations personnel can access Atlantis project documents from the platform,

or in Houston, by logging onto the Documentum system.  The documents and drawings housed

in Documentum currently are better labeled than they were in during the 2008 to 2009 and are

now contained in a better organized folder structure.    
15

and that those drawings are complete and accurate, and can be readily located.  

Failure to maintain such drawings for platform structures that are weight‐

bearing is a violation of BOEMRE regulations.  These regulations are intended to

ensure the structural integrity of platforms and associated facilities operating on

the OCS.  

BOEMRE regulations governing offshore oil and gas operations on the

OCS are contained in part 250 of title 30 of the Code of Federal Regulations (30

C.F.R. part 250).  Specific regulatory requirements apply to particular

components of an offshore oil and gas production facility.  For example, certain

requirements apply only to the floating platform itself and associated structures,

while other requirements apply to pipelines that transport oil or gas between

structures or to shore.  The regulations are divided into subparts applicable to

the specific components:

• Subpart H applies to Oil and Gas Production Safety Systems, 30 C.F.R.

§§ 250.800‐808 (Exhibit 9);

• Subpart I applies to Platforms and Structures, 30 C.F.R. §§ 250.900‐.921

(Exhibit 10); and

• Subpart J applies to Pipelines and Pipeline Rights‐of‐Way, 30 C.F.R. §§

250.1000‐1019 (Exhibit 11).

Below is a summary of the current BOEMRE regulations applicable to

production safety systems, platforms and structures, pipelines and pipeline

rights‐of‐way.   

1. Production Safety Systems

BOEMRE requires that production safety equipment be designed,

installed, used, maintained, and tested in a manner to assure the safety and

protection of the human, marine, and coastal environments.  There are no

specific “as‐built” documentation requirements for production safety systems in

the BOEMRE regulations.  Subpart B, 30 C.F.R. § 250.293, requires the submission

and approval of a Deepwater Operations Plan (DWOP) before production from a

deepwater oil and gas platform may begin.  Subpart H, 30 C.F.R. § 250.800,

requires BOEMRE approval of the production safety systems.
16

BOEMRE regulations also require that lessees comply with certain

American Petroleum Institute (API) recommended practices (RPs).  See 30 C.F.R.

§ 250.198.  Particularly relevant to production safety systems are two API RPs

that address hazard analyses:  API RP 14C, Recommended Practice for Analysis,

Design, Installation, and Testing of Basic Surface Safety Systems for Offshore

Production Platforms; and API RP 14J, Recommended Practice for Design and

Hazards Analysis for Offshore Production Facilities.  The entirety of API RP 14C

is incorporated into 30 C.F.R. § 250.802(b), which states that operators must

protect all platform production facilities with a basic and ancillary surface safety

system designed, analyzed, installed, tested, and maintained in operating

condition in accordance with API RP 14C.  Specific figures and subsections from

API RP 14C are incorporated into other sections of the regulations governing

production and safety systems:

 30 C.F.R. § 250.292(j):  The DWOP must contain “Flow schematics and

Safety Analysis Function Evaluation (SAFE) Charts (API RP 14C,

subsection 4.3c, incorporated by reference in § 250.198) of the

production system from the Surface Controlled Subsurface Safety

Valve (SCSSV) downstream to the first item of separation equipment.”

 30 C.F.R. § 250.802(e)(2):  An operator must receive BOEMRE approval

of safety‐systems design and installation features, including “[a]

schematic piping flow diagram (API RP 14C, Figure E, incorporated by

reference as specified in § 250.198) and the related Safety [A]nalysis

Function Evaluation Chart (API RP 14C, subsection 4.3c, incorporated

by reference as specified in § 250.198).”  

The other relevant incorporated recommended practices, API RP 14J,

contain procedures and guidelines for planning, designing and arranging

offshore production facilities and performing a hazards analysis.  API RP 14J is

specifically incorporated into 30 C.F.R. § 250.800(b)(1) as a general requirement

for new floating production systems.  API RP 14J defines a hazard analysis as “a

systematic procedure for identifying, evaluating, and controlling potential

hazards on a facility.”  API RP 14J (Exhibit 12).  Hazard analyses can be

accomplished by using any of the methodologies identified in Section 7 of API

RP 14J.4  One such methodology is called a “Hazard and Operability Study”

(HAZOP).  

 

4   API RP 14J was not incorporated into Minerals Management Service (MMS) regulations

until 2005, which was after the initial design of the Atlantis facility had already begun.  Therefore,
17

With respect to Mr. Abbott’s specific allegations that are the subject of this

investigation, it is important to note that neither API RP 14C nor API RP 14J, as

incorporated into BOEMRE’s regulations, requires “as built,” “approved for

design,” or “approved for construction” engineering documents before

production may begin.  Generally speaking, a hazard analysis does not require

engineering documents.  A hazard analysis is ʺa systematic procedure for

identifying, evaluating and controlling potential hazards in a facility.ʺ  API RP

14J at 35.  The purpose of this analysis is ʺto identify undesirable events that

might pose a threat to safety, and define reliable protective measures that will

prevent such events or minimize their effects if they occur.ʺ  API RP 14C at 7.  A

hazard analysis is an on‐going process that might culminate in the preparation of

an ʺas‐builtʺ document, but that document is not specifically required as an

element of the analysis.  API RP 14J explains that “[h]azards analysis is

applicable to all phases in the life cycle of a facility: from project inception

through design, construction, operation and abandonment.”  API 14C at 36.  In

other words, hazard analyses may properly be done before anything associated

with a facility is “as built.”  API RP 14C and API RP 14J do not specifically

mention the terms ʺas built,ʺ ʺapproved for design,ʺ or ʺapproved for

constructionʺ anywhere in their text.

2. Platforms and Structures

BOEMRE requires that lessees design, fabricate, install, use, maintain,

inspect, and assess all platform and related structures on the OCS so as to ensure

their structural integrity for the safe conduct of drilling, workover, and

production operations.  30 C.F.R. § 250.900.   

The provision titled “What records must I keep?,” at 30 C.F.R. §

250.903(a)(1),  requires that “as‐built” documents be maintained at a location

 

BP was not required to comply with API RP 14J.  Nevertheless, BPʹs  compliance with API RP 14C

also is sufficient to demonstrate compliance with API RP 14J.  According to API RP 14J, ʺThere

are two fundamental steps associated with a hazards analysis of any process. The first step is

hazard control through compliance with standard practice.  The second step is predictive hazard

evaluation, which is required for processes without sufficient previous experience or that present

an unusually high risk.”  API RP 14J at 36 (emphasis in original).  API RP 14J then identifies API

RP 14C as “[a] good example of safety through standard practice,” the first step identified in API

RP 14J.  Id. At 37.  The second step, the predictive hazard evaluation, is only required when new

or unconventional materials, equipment, processes or procedures are involved.  Id.   

  
18

provided in the certification required by § 250.905(k).  BOEMRE has historically

interpreted this requirement to apply to structures that are weight‐bearing on the

platform, including the following:

(1) Drilling, production, and pipeline risers, and riser tensioning systems;

(2) Turrets and turret‐and‐hull interfaces;

(3) Foundations, foundation pilings and templates, and anchoring systems;

and

(4) Mooring or tethering systems.

See 30 C.F.R. § 250.910(b)(1).  Subsea production equipment, such as manifolds,

pipeline end terminations (PLETs) and pipeline end manifolds (PLEMs), are not

specifically covered by the scope of the BOEMRE regulations requiring the

maintenance of “as built” documents.  

3. Pipelines

With respect to pipelines, 30 C.F.R. § 250.1008(b) requires an operator to

provide as‐built location plats showing the location of the pipeline after

construction.  This section also requires that a registered engineer or land

surveyor certify the pipeline right‐of‐way “as‐built” location plats.  This

requirement refers to the physical location of a pipeline after installation, not to

the pipeline’s design or construction.   

4. Other Relevant Regulatory Provisions

BOEMRE regulations also require that a CVA review the design,

fabrication, and installation of a production platform.  See 30 C.F.R. § 250.916 ‐ 

.918.  The CVA is required to use “good engineering judgment” to ensure that

the production platform has been built according to the approved design and

fabrication plans.  30 C.F.R. § 250.917(a).

BOEMRE has the authority, under 30 C.F.R. § 250.172(b), to suspend

operations or production at a facility if the operator’s activities pose a threat of

serious, irreparable or immediate harm or damage.  Pursuant to 30 C.F.R. §

250.135, BOEMRE can revoke a company’s designation as an operator if its

operating performance is determined to be unacceptable.  BOEMRE considers

the following factors in evaluating whether an operator’s performance is

unacceptable:  accidents and their nature; pollution events and environmental

damage and their nature; incidents of noncompliance; civil penalties; failure to
19

adhere to OCS lease obligations; or any other relevant factors.  See 30 C.F.R. §

250.136.   
20

II. Inspection and Review of the Atlantis Facility

A. BOEMRE’s Regulatory Review  

To verify BP’s compliance with the requirements of 30 C.F.R. subparts B

and H, BOEMRE reviewed the DWOP and production safety system applications

submitted by BP for the Atlantis facility.  In its production safety system

application, BP submitted all of the information required for a complete analysis

under API RP 14C.  See 30 C.F.R. § 250.802(e)(1)‐(3).  BP also certified that the

design for the Atlantis facility’s mechanical and electrical systems was approved

by registered professional engineers, as required by 30 C.F.R. § 250.802(e)(5)

(regarding approval of safety‐system design and installation features).

As noted previously, “as‐built” P&IDs for subsea equipment are not

required as part of the BOEMRE approval process, but BOEMRE does require a

complete analysis of safety flow diagrams and SAFE charts.  See 30 C.F.R. §

250.802(e)(1)‐(3).  BOEMRE reviewed the safety flow diagrams and SAFE charts

for the Atlantis facility in conjunction with completed P&IDs from BP before

granting the required approvals.  Before the first production of oil by the Atlantis

platform, BOEMRE conducted four inspections of the Atlantis facility’s

production safety systems.  These inspections included a review of the surface

and subsea safety system function logic.  During the course of these pre‐

production inspections, BOEMRE engineers and inspectors documented areas of

concern and required BP to take corrective actions prior to first oil.

The BOEMRE safety system review included verification of the

installation of certified subsurface safety valves, underwater safety valves, and

boarding shutdown valves, along with a review of the closure times and build‐

up leakage tests associated with these valves.  These valves comprise the critical

components of the production safety system.  Since commencement of

production by the Atlantis facility, BOEMRE Houma District personnel have

conducted three inspections onboard the facility – on February 12‐14, 2008; April

1‐3, 2009; and May 5‐7, 2010.  No incidents of non‐compliance were issued

during the first two inspections.  BOEMRE issued one incident of non‐

compliance during the most recent inspection because a leaking boarding shut‐

down valve failed to form a bubble‐tight internal seal.  BP isolated the incoming

flow line associated with this valve.  The valve was greased immediately and

retested.  BOEMRE allowed BP to return the valve to service after BP showed

that the leak had been fixed and the valve had passed a leakage test.   
21

As required by 30 C.F.R. § 250.802(e)(5), which governs approval of safety‐

system design and installation features, BP certified that the Atlantis facility’s

mechanical and electrical systems were installed consistent with the approved

design.  BOEMRE inspections, conducted in 2008, 2009, and 2010, verified that

the production safety systems were installed correctly, as approved, and that

these systems functioned properly.

B. U.S. Coast Guard Regulatory Review

The U.S. Coast Guard (USCG) also has an important role in reviewing and

approving floating production systems.  The USCG typically inspects, among

other things, general vessel specifications, all structures other than conventional

hull vessels, operating manuals and environmental conditions for Mobile

Offshore Drilling Units (MODUs), and a number of operating certificates.  The

USCG is also responsible for lifesaving and fire protection system equipment,

electrical machinery and miscellaneous system and equipment, cargo systems

and equipment, and boilers and pressure vessels.  See 33 C.F.R. Subchapter N.

The USCG conducted the required reviews of the Atlantis floating

production system and reviewed reports of inspections done by the American

Bureau of Shipping (see below).  After its review, the USCG granted a series of

approvals to BP to operate the Atlantis facility.

C. Review by the Certified Verification Agent

The American Bureau of Shipping (ABS) acted as the Certified Verification

Agent for the Atlantis facility.  ABS approved the design and fabrication of the

pile foundation system, the mooring system, the hull, and the topsides of the

Atlantis platform.  ABS also witnessed and approved the installation of the

Atlantis platform at Green Canyon block 787.  Part of ABS’s review included

analysis of engineering documents and drawings that are the subject of this

investigation.   
22

III. Abbott Litigation and Related Inquiries

A. Kenneth Abbott’s Lawsuits

In April 2009, Kenneth W. Abbott, a former BP contractor, brought a

lawsuit as a relator on behalf of the United States against BP under the False

Claims Act.  United States of America ex rel. Kenneth W. Abbott v. BP Exploration and

Production et al. (S.D. Tex.).  Claims under the False Claims Act must be brought

in the name of the government and filed under seal to allow the government

time to investigate the allegations and to determine whether to intervene and

take over the action.  31 U.S.C. § 3760(b).  In his lawsuit, Mr. Abbott alleged that

BP submitted false certifications that induced MMS (now BOEMRE) to approve

production from the Atlantis facility.  

In his complaint, Mr. Abbott asserted that BP failed to maintain

documents depicting the ʺas builtʺ condition of the Atlantis facility’s subsea

system.  Mr. Abbott’s complaint also focused on the alleged absence of

documents marked ʺapproved for designʺ and ʺapproved for construction,ʺ 

which he claimed would show the configuration of the equipment as it was

designed or intended to be constructed.  Mr. Abbott’s complaint claimed that

many critical documents and drawings were missing from a BP Atlantis

document database and that there was no record that certain engineering work

on the Atlantis platform was actually performed.  Mr. Abbott alleged that,

without these safety documents, oil and gas cannot be safely produced by the

Atlantis facility.   

In January 2010, Mr. Abbott voluntarily dismissed his lawsuit, but it

remained under seal.  On May 17, 2010, Mr. Abbott and a non‐profit

organization, Food and Water Watch, filed a second lawsuit against the

Department of the Interior and MMS seeking to obtain an injunction compelling

MMS to shut‐in the Atlantis facility due to the alleged absence of engineering

documents relating to the Atlantis platformʹs subsea system.

On May 20, 2010, on Mr. Abbott’s motion, the court lifted the seal on his

False Claims Act lawsuit and reopened that case.  On June 18, 2010, the

injunctive suit was voluntarily dismissed without prejudice.  On September 10,

2010, Mr. Abbott and Food and Water Watch filed an amended complaint against

BP that again alleged that BP was operating the Atlantis facility without

engineer‐approved documents.  Neither BOEMRE nor the U.S. Department of
23

the Interior is a defendant in this case.  Mr. Abbott’s amended complaint seeks

both injunctive relief and damages under the False Claims Act.  On December 13,

2010, the United States filed an amicus brief in this case regarding the proper

scope of the False Claims Act.  BP has filed a motion to dismiss, which is

currently pending.

B. Congressional Inquiries

In 2009, several members of Congress asked MMS to provide information

regarding the Atlantis production facility.  At that same time, MMS was

reviewing Mr. Abbott’s allegations regarding the Atlantis facility.  However,

because Mr. Abbott’s lawsuit was under seal, MMS was barred from sharing

with Congress the details of its inquiry into Mr. Abbott’s allegations.   

On February 24, 2010, United States Representative Raul M. Grijalva and

eighteen other members of Congress wrote to then‐MMS Director S. Elizabeth

Birnbaum urging her to direct “a full investigation of whether British Petroleum

[sic] had a complete and accurate set of required engineering drawings for the BP

Atlantis platform and its associated subsea components prior to the start of

production from that platform, and to report back to Congress on the results of

that investigation as soon as possible” (a copy of the letter is attached as Exhibit

13).

On June 17, 2010, Mr. Abbott testified before the House Subcommittee on

Energy and Mineral Resources.  In his testimony, Mr. Abbott alleged the

following deficiencies relative to the Atlantis facility:

 The oil and gas products under high pressure are managed, contained

and transported to the floating surface vessel by the wellhead, the tree,

the manifolds, pipelines and flowlines, controls and risers.  According

to Mr. Abbott, less than 10% of these systems were certified as

approved by engineers.

 The wellhead is the equipment that controls pressures inside the well

at the upper end of the casing and below the tree – none of the

documents for this equipment ever had any engineering approval,

according to Mr. Abbott.

 The tree is a series of valves immediately above the well which have

the same function as the BOP stack during drilling; they control

pressures and can be used to shut down the well if needed; they are a
24

critical part of the Safety Shutdown System.  On Atlantis, they also

include values to control flows related to the manifolds.  Of these

critical components, 98% never received any engineering approval,

according to Mr. Abbott.

 The software logic for the safety shutoff system does not have

engineering approval.

 Welding procedures for such critical items as manifolds do not have

engineering approval.

See Exhibit 14.   Mr. Abbott’s allegations appeared to be based upon his review –

and a review conducted by an engineer, Michael Sawyer, hired to assist in Mr.

Abbott’s litigation – of a spreadsheet reflecting the Atlantis subsea project

drawings.   

Mr. Abbott testified that the above problems were similar to the problems

that led to the Deepwater Horizon tragedy.  He further testified that he believed

that the Atlantis facility could be a “ticking time bomb” and that BP Atlantis

operations personnel might be “flying blind” because they lack critical, engineer‐

approved documents.  

C. BP’s Ombudsman  

BP has an Office of the Ombudsman (the Ombudsman) that is charged

with investigating allegations of misconduct by company personnel.  In early

2009, Mr. Abbott contacted the Ombudsman and alleged that BP had:  (1)

breached its contract with him; and (2) illegally terminated him in retaliation for

his defense of a female employee who had allegedly been harassed.  Mr. Abbott

did not raise concerns about missing engineering documents or lack of engineer

approval of documents in his initial complaint.  In March 2009, after he was no

longer working as a third‐party contractor for BP, Mr. Abbott e‐mailed the

Ombudsman regarding his allegations that the Atlantis facility was operating

without certain “as built” engineering drawings.   

The Ombudsman’s two‐page response to Mr. Abbott, dated April 13, 2010,

rejected Mr. Abbott’s allegations that he had been wrongfully terminated.  The

response also addressed Mr. Abbott’s allegations regarding the Atlantis

engineering documents.  Mr. Abbott has claimed that the Ombudsman’s

response contains statements that support his allegations.  The response states:
25

Your concerns about the project not following the terms of its own

Project Execution Plan were substantiated, and addressed by a BP

Management of Change document.  The Project Execution Plan is a

BP internal document, and not a regulatory requirement.  We did

not do a comprehensive document audit regarding the

documentation issues on the Atlantis.  As you know, you did not

raise that issue until after the initial investigation of your concerns

was completed, and only reviewed the issue you raised to us;

The concerns that you expressed about the status of the drawings

upgrade project were not unique to you.  It was a challenge to the

Project and of concern to others who raised the concern before you

worked there, while you were there, and after you left.  You did not

“blow the whistle” on the problem until, apparently, after you left

employment at BP.  Your raising the issue did not result in any

change to the schedule of BP addressing the issue.   

See Exhibit 15.   

The BP Management of Change document referred to by the Ombudsman

(“MOC document”), dated April 24, 2009, stated:

Due to the extended time frame for Atlantis Subsea Project

operations at DC1 from the Manifold changeout and ongoing

development, the completion and final handover of a complete set

of Subsea project documentation to Operations has been delayed as

a result of continual updates on many documents.  Currently the

documentation files are maintained in the Operations and Project

document storage systems depending upon the stage of completion

while at all times still available to any interested party within

Atlantis. This is a deviation from the intent of the project to have

had a complete set of documentation handed over after start‐up of

Atlantis.  There is an ongoing program to complete and move

documents to Operations as they are available.    

See Exhibit 16.  The MOC document describes the steps that BP planned to take

to address the Atlantis project document problems:
26

It is proposed to formalize the existing process of only transferring

to Operations the Subsea Project documentation that has been

completed and will not need to be updated in the next couple of

years of the ongoing Subsea Project as a result of currently

identified project scope.  At all times the documentation will be

available, in updated form, in either the Project or Operations

document storage systems.  The intent of this proposal is to

eliminate the need for repeated document handovers between the

Project and Operations.  This proposal will have no impact on

access to documents by the Atlantis project and will not impact

access to documentation required for any regulatory purposes.  As

previously mentioned, this proposal is to maintain the current

process being used by Operations and the Subsea project for Subsea

Project documentation handover.   

See Exhibit 16.   The MOC document detailed the changes BP planned to

implement to “eliminate the need for repeated document handovers between

Project and Operations” (after first oil).   The MOC document did not address the

systems handover process that BP follows (detailed on pages 6‐7 of this Report)

to transfer documents to operations prior to first oil.   
27

IV. BOEMRE’s Investigation

A. Overview of the Investigation

Our investigation focused on whether BP maintained a complete and

accurate set of engineering drawings for the Atlantis platform (and associated

subsea components), as required by BOEMRE regulations.  We also investigated

Mr. Abbott’s allegations regarding (1) missing or unapproved engineering

drawings; (2) false or incomplete BP submissions to BOEMRE; and (3) unsafe

operating conditions on the Atlantis facility.  

The investigation was conducted by a team of eight BOEMRE engineers,

and, beginning in September 2010, was led by BOEMRE’s Investigations and

Review Unit.  The investigative team also received input and assistance from the

Department of the Interior Solicitor’s Office regarding the interpretation and

application of BOEMRE regulations.  The investigation team reviewed more than

3,400 engineering drawings and related documents concerning the Atlantis

facility.  The team’s review of the drawings submitted by BP included an in‐

depth analysis of drawings depicting the Atlantis platform’s production safety

systems and its structural systems.   

To assist in our review and interpretation of these drawings and

documents, we interviewed a number of people with in‐depth knowledge of the

operations of the Atlantis facility and the engineering drawings depicting those

operations.  BOEMRE interviewed 29 individuals who were either employees of,

or contractors for, BP.  We interviewed personnel from contractors including

KBR, Technip, ABS and Mustang Engineering.  We also interviewed Mr. Abbott

and Michael Sawyer, an engineer retained by Mr. Abbott to analyze material

related to his allegations.   

We also reviewed ROV footage of the Atlantis subsea system (filmed in

2010) and witnessed a real‐time demonstration of current capabilities of the BP

Atlantis Documentum database, which is accessible to BP Atlantis operations

personnel.   

B. The Scope and Timing of the Investigation

MMS (now BOEMRE) first began reviewing BP’s compliance with

regulatory requirements for as‐built engineering documents in May 2009,
28

following the filing of Mr. Abbott’s lawsuit.  As part of this investigation,

BOEMRE reviewed regulations, certifications, and engineering documents.   

By July 2009, MMS had received inquiries about the Atlantis from

members of Congress, the press, and advocacy groups.  The fact that the False

Claims Act lawsuit had been filed under seal limited MMS’s ability to

communicate with Congress and the public about the allegations regarding BP’s

compliance with regulatory requirements for as‐built documents.   

On March 26, 2010, MMS Director Birnbaum responded to the February

24, 2010 Congressional letter, stating that MMS ʺwill conduct a full investigation

of this situationʺ and will complete its report by the end of May 2010.   During

the first week of April, MMS investigators interviewed BP employees regarding

BP’s document control process for the BP Atlantis project.  After the interviews,

MMS investigators traveled to Houston to review Atlantis facility documents

and drawings.

On April 19, 2010, three MMS investigators arrived at BP’s office in

Houston, Texas, to review documents and drawings associated with the Atlantis

platform and its subsea system.  The following day, on April 20, 2010, the

explosions occurred on the Deepwater Horizon drilling rig on another BP lease in

the Gulf of Mexico.  MMS directed the personnel involved in the investigation to

assist in the Deepwater Horizon response and temporarily suspended the Atlantis

investigation.   

In mid‐May 2010, MMS resumed its Atlantis investigation, with a focus on

(1) whether there were immediate safety concerns that would necessitate the

shut‐in of the Atlantis platform; and (2) the status of the Atlantis engineering

drawings.  After analysis of the documents, data, and other information

regarding the operation of the Atlantis facility identified no safety issues

requiring an immediate shut‐in of the platform, the investigation focused on

issues related to BP’s maintenance of required engineering drawings.  To that

end, on July 21, 2010, BOEMRE sent a letter to BP requesting production of the

engineering documents that BOEMRE regulations required BP to maintain.   In

August 2010, BP produced over 3,400 documents and drawings depicting the

Atlantis’s production safety systems and its structural systems.   
29

V. Allegations, Evidence, and Findings

A. Production Safety Systems

As discussed above, BOEMRE regulations do not require the submission

of “as‐built” documentation for production safety systems.  However, based on

our investigation and several inspections of the Atlantis facility’s production

safety systems, we concluded that the flow schematics and SAFE charts

maintained by BP accurately reflect the equipment and systems that are installed

on the facility.5   

B. Violation of 30 C.F.R. § 250.802  

Our investigation found that certain operations related to the Atlantis

facility were not being conducted pursuant to BOEMRE‐approved plans and

drawings.  We concluded that BP failed to submit drawing revisions, in violation

of 30 C.F.R. § 250.802.  On October 4, 2010, BOEMRE issued a Notice of Incidents

of Non‐Compliance to BP listing the plans and drawings that BP had failed to

submit for approval.6  BP responded to this Notice on October 20, 2010 and

submitted the required drawings (see Exhibit 17 for a copy of the Notice and BP’s

response).  BOEMRE has since reviewed and approved these drawings.  

C. ROV Inspection of Subsea Structures

To investigate the allegations that the lack of critical engineering drawings

depicting subsea structures created immediate safety hazards, BOEMRE

requested that BP produce materials related to a 2010 ROV inspection of the

 

5   Atlantis operations personnel rely upon a computer system called the “Human Machine

Interface” (HMI) or the System Control and Data Acquisition (SCADA).  This system functions as

a diagnostic tool and an early warning system for potentially catastrophic events.  Given the

importance of these computer systems, BOEMRE is currently evaluating whether to expand its

regulations to include specific requirements related to the functionality and performance of such

systems.

6   BOEMRE issued this Notice prior to the publication of this report because it determined

that BP’s violations needed to be corrected immediately.  To effectively regulate the production

activities in the OCS, BOEMRE must have accurate, up‐to‐date drawings of production safety

systems.      
30

Atlantis subsea structures.7  Because subsea structures cannot be inspected in‐

person, ROV inspections are the only means to review installed subsea

components.   

The inspection report on the 2010 ROV footage was prepared by 2H

Offshore Inc. in January 2011.  The actual ROV inspection was conducted by

Wood Group Integrity Management and Oceaneering International.  The report

concluded that the Atlantis subsea equipment is in good condition, with the

exception of jumper insulation, which was shown to have a number of cracks.  

The report suggested that BP further test the thermal integrity of the well and

flowline jumpers where the insulation cracks are located.  2H did not

recommend replacement of the jumpers or other remedial actions because the

jumpers are scheduled to be removed in 2012 when BP plans to install the SS‐2

subsea components.  See Exhibit 18 (copy of the 2H report).8

D. Documentation Problems in the BP Atlantis Project Files

1. Electronic Database Problems

As described above, the BP Atlantis project files are stored in an electronic

database called the Documentum.  The Documentum database contains

documents and drawings generated by BP and its third‐party contractors.  Until

BP reorganized Documentum in 2009 and 2010, documents related to the Atlantis

project were not well organized.  All of the BP witnesses we interviewed

admitted that the documentation related to the Atlantis project’s subsea

components required significant “clean up,” updating, and reorganization.  

Among other things, a significant problem was that the project documents

should have been better organized before being transferred to Atlantis

operations personnel before production began.9  

 

7   BP contracts with third‐party firms to conduct ROV inspections on an annual basis and to

provide a report analyzing the condition of the subsea components.   

8   Performance of a full audit of the present condition of all subsea components was not

within the scope of this investigation.  BOEMRE is continuing its regulatory review of the

performance and integrity of the Atlantis facility’s subsea components, including wellheads,

jumpers, and other components, and will take any appropriate action necessary to ensure the safe

operation of the Atlantis facility and its subsea systems and components.

   

9   As described in this report, this was a document management problem that was separate

from the system handover process, which involves a set of procedures BP followed to transfer
31

By June 2010, the Atlantis subsea document control process had improved

significantly.  BP upgraded Documentum to include a more organized file

structure and generally to allow searches for relevant materials by BP operations

personnel or others at BP to be conducted more efficiently.   

2. Engineering Drawings – Labeling and Related

Problems

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.   

See Exhibit 19.   Thus, the “as built” drawings depicting the Atlantis facility’s

topside and subsea structures were inconsistently labeled and did not always

carry the label “as built.”   

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

 

key documents and drawings (including subsea documents and drawings) to operations

personnel.   
32

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.10  

We find that BP complied with the requirements of 30 C.F.R. § 250.903(a)(1) and

30 C.F.R. § 250.905(d).  We note, however, that BP’s use of a multitude of labels

and the failure of BP to coordinate the drawing labeling systems used by its

contractors has made it difficult to evaluate whether BP, in fact, complied with

BOEMRE regulators.  Where operators such as BP rely on contactors to design,

fabricate, and install critical structures, they should implement and oversee a

document labeling system that allows BOEMRE – and the operator ‐‐ to more

readily determine whether the materials reflect the “as built” systems on the

facility.   

E. Engineering Drawings – Allegedly Unapproved or Not “As

Built”

1. Allegations

In his lawsuit, and in our interview of him during this investigation, Mr.

Abbott alleges that various materials – including engineering designs,

components for construction, and “as built” engineering documents – related to

critical Atlantis subsea systems “such as risers, P&IDs, and installation

engineering documents” never received the necessary approvals.  Mr. Abbott

further alleges that the deficiencies in the Atlantis document database (e.g.,

missing drawings and documents) demonstrate that:  (1) necessary engineering

work was not completed; (2) production equipment was not constructed

according to approved construction documentation; and (3) requisite testing

could not be confirmed.   

 

10   As discussed in Section I.B.2 above, there is a requirement that operators maintain copies

of certain “as built” drawings, but there is no requirement that such drawings carry the label “as

built” or that they be maintained in a specified manner.   
33

2. Evidence Cited by Mr. Abbott

a.  The Duff Spreadsheet

A central piece of evidence upon which Mr. Abbott’s allegations are based

is an Excel spreadsheet that depicts the different types of subsea structures

associated with the Atlantis production platform.  The spreadsheet was created

by Mr. Abbott’s predecessor, Barry Duff, and Tinikka Curtis, who reported to

Mr. Duff (and then later to Mr. Abbott).  Mr. Abbott claims that one can tell that

critical engineering drawings and documents were not approved by engineers by

looking at the labels used for the drawings and documents in this Excel

spreadsheet.   

Mr. Abbott does not claim to have reviewed all of the underlying

drawings referred to in the spreadsheet to assess whether the drawings, in fact,

accurately depict the Atlantis facility’s subsea system.   He claims to have “spot

checked” between 300 and 400 documents and that his spot‐check supported the

conclusions that he drew based upon his review of the spreadsheet.   

b. E‐mails

Mr. Abbott claims that a number of BP e‐mails support his allegations that

BP Atlantis operations personnel lacked certain subsea engineering documents

that they needed to safely operate the facility.

First, Mr. Abbott claims that an August 15, 2008 e‐mail from Mr. Duff to

Mr. Broman and Mr. Naseman regarding “P&IDs For Operation” is evidence

that BP Atlantis operations personnel did not have access to critical, engineer‐

approved, “as built” drawings.   

In the August 15, 2008 e‐mail, Mr. Duff expressed concern about turning

over the Atlantis project documents to BP operations personnel without prior

review by the document control team.  In the e‐mail, Mr. Duff states that “[t]he

Operator will assume the drawings are accurate and up to date.  This could lead

to catastrophic Operator errors due to their assuming the drawing is correct.”  

See Exhibit 6.   

Second, Mr. Abbott claims that an August 14, 2008 e‐mail from Andrew

Gregg (BP contractor) to Mr. Duff and Mike Garland shows that BP operations

personnel did not have access to Atlantis SS‐1 drawings and that BP was
34

unwilling to spend $2 million to transfer critical engineering drawings to BP

operations personnel.   

Third, Mr. Abbott claims that a November 28, 2008 e‐mail from Bill

Broman to a number of BP Atlantis project engineers entitled “Atlantis

Document Control – Path Forward” shows that BP engineers had not approved,

and BP operations personnel did not have access to, critical subsea engineering

documents and drawings.   This e‐mail attached a number of Excel files that

referred to Atlantis documents and drawings by “sector” (i.e., type of subsea

system).   

c. Conversations with BP Employees

Mr. Abbott claims that he raised his concerns about the lack of critical

documentation regarding the Atlantis facility with a number of BP employees

and that a number of these employees agreed that there was a problem.  He

claims – in Congressional testimony, interviews with BOEMRE personnel, and in

a letter to the Inspector General for the Department of the Interior – that he

discussed the missing engineering drawings and documents with Ron Berger, a

systems engineer on the subsea delivery team, and that Mr. Berger

acknowledged that Atlantis operations personnel did not have critical “as built”

drawings.  Specifically, during an interview with BOEMRE investigators, Mr.

Abbott asserted that Mr. Berger said “I’ve got no [as‐built drawings].”  When

asked whether Mr. Berger mentioned anything about a system handover

package, Mr. Abbott stated that Mr. Berger said “where is my system handover

package?”  See Exhibit 20 (cited portions of a transcript of BOEMRE interview of

Mr. Abbott) at 25.   

Mr. Abbott also claims that he told BP employees Ryan Malone, Bill

Naseman, Bill Broman, Tinikka Curtis, John Hughes, John Mack, David

Whitehead, Bernie Kirkham, Rick Weber and John Schweibel that BP operations

personnel lacked access to critical “as built drawings.”    

3. Findings

We find that Mr. Abbott’s allegations regarding “as built” engineering

drawings and the lack of engineering approvals are not supported by credible

evidence.  With regard to each of the above outlined categories of evidence, we

find as follows:
35

a. Spreadsheet

At most, the spreadsheet relied upon by Mr. Abbott reveals that BP had a

number of problems with both the organization of the Atlantis subsea project

documents and with the labeling of subsea drawings depicting the systems and

equipment as they were installed.   However, the spreadsheet alone is not a

reliable source for determining the engineering drawings that, in fact, were

completed and transferred to operations personnel prior to first oil.  BP used a

detailed set of procedures that governed the transfer of drawings and documents

to Atlantis operations personnel.  The spreadsheet Mr. Abbott relied upon did

not indicate whether the drawings at issue had been transferred to Atlantis

operations personnel pursuant to these procedures.   

The spreadsheet purported to list the Atlantis subsea project documents

that needed to be properly organized and labeled for proper transfer to

operations personnel.11  This spreadsheet did not, however, address whether

critical engineering documents and drawings had been transferred to Atlantis

operations personnel prior to first oil.  Numerous BP documents, and every BP

employee and contractor interviewed as part of our investigation, confirmed that

there was a transfer of systems handover packages prior to first oil and that these

packages included engineering drawings and documents depicting what had

been installed.  Moreover, the transfer of drawings and documents that was to

occur after the Documentum problems were addressed was a typical transfer of

project files that takes place some time after the initial handover process has

occurred.   

   We reviewed documents and drawings contained in the seven volumes of

system handover packages to confirm that the handover process had taken place

prior to first oil.   We also reviewed numerous drawings and documents within

the handover packages and verified that certifying documents (Certificates of

Compliance, Inspection Release Certificates, Well Handover Certificates, and

Mechanical Completion documents) were included.  However, the systems

 

11   Several BP employees explained that all project documents are ultimately transferred to

operations even though many of these same documents would already have been transferred

with the systems handover packages.   The reason is that, after the “project” phase is completed

(i.e., after first oil), project personnel typically move to the next project while the operations

personnel continue to work on production from the platform.  A complete transfer of project files

and documents eventually should be made to ensure that the documents (even the superseded

drafts that do not reflect “as built” designs) are retained during production.   
36

handover packages did not contain all of the documents and drawings that had

been saved in the Atlantis Documentum database.

We did not find any evidence that BP’s handover process was flawed.  But

even if there was some mistake or omission in the delivery of engineering

drawings in the handover packages, we found no evidence that any mistake or

omission created unsafe operating conditions.  In any event, BP has improved

the organization and searchability of the Atlantis Documentum database

substantially, and BP operations personnel have ready access to Documentum.   

b. E‐mails

We reviewed each of the e‐mails relied upon by Mr. Abbott and

interviewed a number of BP employees and contractors regarding these e‐mails.   

In particular, we focused on Mr. Duff’s e‐mail that referred to potential

“catastrophic Operator errors.”  BOEMRE investigators questioned Mr. Duff at

length about the e‐mail.  Mr. Duff stated that he never believed that BP Atlantis

operations personnel lacked access to critical engineering documents.  He

explained that his concern, at the time that he wrote the e‐mail, was that

operations personnel should not be given the entire, unorganized set of the

Atlantis project documents without some quality checks and controls around the

documents provided.

Mr. Duff told us that, notwithstanding the strong language in his e‐mail,

he never considered the unorganized state of the Atlantis project drawings and

documents to be a major problem.  He was aware that a formal handover process

had occurred and that BP had a detailed set of procedures that govern the

materials to be included in the handover packages.  When pressed to explain

why he had chosen to refer to possible “catastrophic Operator errors,” Mr. Duff

said that he was probably frustrated that his project services group was being

saddled with the Documentum database re‐organization process and that BP

operations personnel expected re‐organization to be completed very quickly.  He

said that he was appealing to his bosses (Naseman and Broman) to give his

group more time to complete the project and therefore used far more dramatic

language than the facts justified.     

Mr. Broman, who was one of two recipients of the e‐mail, said that he did

not understand Mr. Duff to be saying that BP operations personnel lacked access

to critical engineering documents.  Mr. Broman explained that Mr. Duff and Ms
37

Curtis were charged with “cleaning up the Atlantis project file cabinet.”  The e‐

mail exchange reflected Mr. Duff’s concerns about that process – not about the

prior systems handover process that had already taken place.  Mr. Naseman,

who Mr. Duff reported to and who was the other recipient of the e‐mail,

similarly said that Mr. Duff was, notwithstanding his use of alarming language,

essentially communicating that “the work is not done” on the database of

Atlantis project documents.  Mr. Naseman said he was not alarmed by Mr. Duff’s

e‐mail because he knew that a formal handover process had occurred and that he

did not believe that BP Atlantis operations personnel were missing any critical

documents.    

The e‐mail from Mr. Gregg to Mr. Broman and Mr. Naseman is, similarly,

not evidence that BP operations personnel lacked access to critical engineering

documents or that BP was unwilling to spend $2 million to ensure such access.  

Contrary to Mr. Abbott’s assertions, Mr. Turner (who was mentioned in the e‐

mail) did not have any responsibility for the Atlantis subsea systems and was not

in a position to know whether BP operations personnel had access to the Atlantis

“SS‐1” documents and drawings.    

Finally, the e‐mail from Mr. Broman to Atlantis project engineering

personnel entitled “Atlantis Document Control – Path Forward” was an e‐mail

about, not surprisingly given its title, the Atlantis subsea document control

system.  It did not purport to identify critical engineering documents that were

not accessible by BP Atlantis operations personnel.  No BP Atlantis operations

personnel were copied on or mentioned in the e‐mail.  This communication

simply did not address access to documents and drawings by operations

personnel.   

c. Conversations with BP Employees

We interviewed each of the individuals Mr. Abbott claimed to have

spoken to about his concerns that BP operations personnel lacked access to

critical engineering documents and drawings and that many of these documents

and drawings were never approved by a BP engineer.   

Each of these individuals described the documentation problems that Mr.

Abbott and Ms. Curtis were addressing as “cleaning up” and organizing the

Documentum database.  None of them said they recalled any discussions with

Mr. Abbott in which Mr. Abbott stated that he believed that BP operations

personnel lacked access to critical engineering documents and drawings or that
38

many of these documents and drawings were never approved by an BP engineer.   

Mr. Abbott’s contentions, and his responses during his interview, demonstrate

that, at a minimum, Mr. Abbott does not have a complete understanding of the

process BP used to transfer documents and drawings to Atlantis operations

personnel.12     

A central allegation that Mr. Abbott has made – to Congress, to BOEMRE

and to the Inspector General of the Department of the Interior – is that Mr.

Berger, who had responsibility for Atlantis subsea operations, admitted to him in

January 2009 (in a meeting also attended by Ms. Curtis) that BP Atlantis

operations personnel lacked access to critical subsea documents and drawings.  

See Exhibit 20 at 24.  During his interview with us, Mr. Berger strongly denied

having had such a conversation with Mr. Abbott and told us that, if he had a

concern about the lack of access to drawings by BP Atlantis operations personnel,

he would have gone straight to those operations personnel and not to Mr.

Abbott.  Mr. Berger participated in the systems handover package process that

was designed to ensure that Atlantis operations personnel had access to critical

subsea documents prior to first oil.  In light of Mr. Berger’s denials and his role

with the handover process, we find there is insufficient credible evidence to

support the claim that Mr. Berger said, “Where is my systems handover

package?” as alleged by Mr. Abbott.     

Ms. Curtis told us that she did not recall Mr. Berger saying anything

during the meeting with Mr. Abbott about Atlantis operations personnel’s access

to engineering drawings and documents.  Both Mr. Berger and Ms. Curtis stated

that they believed that the meeting was held to address the ongoing

Documentum database clean‐up project, not the handover of documentation to

Atlantis operations personnel in advance of first oil.  

We fully explored Mr. Abbott’s other specific allegations about his

conversations with other personnel.  We resolve them as follows:  

 

12   When asked about this process, Mr. Abbott said that “[t]here is a subsea handover

procedure, but that procedure originates with the document control clerk, and those drawings

are all bundled up or sent – either bundled up as hard copies or sent electronically by her to the

operators, period.  That’s the only way I know that that works.”  See Exhibit 20 at 50‐51.  Every

other individual interviewed, including those who actually worked to ensure the appropriate

drawings and documents were included in the systems handover packages, described the

process outlined on pages 6‐7 of this report.  This process was much more than review and

production of documents and drawings by a document control clerk.   
39

 Mr. Abbott claimed that Mr. Broman told him that necessary “as built”

documents were not available to personnel on the Atlantis platform.  

Mr. Abbott said that he asked Mr. Broman to put out an e‐mail to fix

this problem.  See Exhibit 20 at 32.  Mr. Broman said that his e‐mail,

entitled “Atlantis Document Control – Path Forward” was sent to

encourage project engineering leads to help with the Documentum

“file cabinet clean up” tasks being performed by Ms. Curtis under Mr.

Abbott’s direction.  Mr. Broman denies that he ever thought or said, to

Mr. Abbott or anyone else, that the problem being fixed was the lack of

access to critical, engineer‐approved documents by BP Atlantis

operations personnel.  Mr. Broman told us that if he thought that BP

Atlantis operations personnel were lacking critical, engineering‐

approved documents, he would have contacted operations directly

and worked right away on getting them the documentation they

needed.    

 Mr. Abbott claimed the Ryan Malone, project manager for the Atlantis

north flank who had an office next to Mr. Abbott’s office, expressed

“concern” and “shock” about Atlantis documentation issues and that

the documents were not in place to support installation of subsea well

equipment.   See Exhibit 20 at 42.  Mr. Malone told us that he spoke to

Mr. Abbott on a number of occasions about document control issues,

but that those conversations were “matter of fact” and were not

conversations in which Mr. Malone or Mr. Abbott expressed “concern”

or “shock.”  Mr. Malone said that he never heard Mr. Abbott say that

operations personnel did not have the documents they needed to

safely operate the Atlantis facility.  Mr. Malone said that he

understood the problem Mr. Abbott and Ms. Curtis were working on

was a document database clean‐up project.   

 Mr. Abbott claimed that Ms. Curtis confirmed to him that a large

number of engineering documents had not been transferred to BP

Atlantis operations personnel.  See Exhibit 20 at 63.  Ms. Curtis

explained to us that, at the direction of Mr. Duff, she had started the

process of organizing the Atlantis project documents.  She said that the

documents were “all in one folder” and needed to be separated and

labeled.  Ms. Curtis said that she did not recall ever telling Mr. Abbott

that personnel on the Atlantis platform did not have access to

necessary engineering drawings and documents.   
40

 Mr. Abbott claimed that while at BP he spoke to his boss, Mr.

Naseman, about the fact that BP Atlantis operations personnel lacked

access to certain engineer‐approved drawings.  Mr. Abbott said that he

– in phone calls and staff meetings – asked for support from Mr.

Naseman in getting the Atlantis project engineers to provide drawings

and documents to Ms. Curtis.  Mr. Abbott said that Mr. Naseman got

angry and said that Mr. Abbott was “putting too much pressure on the

engineers.”  See Exhibit 20 at 23.  Mr. Naseman acknowledged saying

something like this, but told us that he also stated that the engineers

needed to work on the database problem because it was their job to

provide the drawings and documents to Ms. Curtis.  Mr. Naseman,

however, told us that he never recalled Mr. Abbott characterizing the

problem as an operational issue (i.e., that BP operations personnel

lacked access to engineer‐approved documents).  Mr. Naseman

characterized the project as the “subsea document clean‐up.”   

 Mr. Abbott claimed that, in meetings with Atlantis project engineer

leads (John Hughes, John Mack, David Whitehead, Bernie Kirkham,

Rick Weber, and John Schweibel) he expressed the view that BP

operations personnel lacked access to as built, engineer‐approved

documents.  See Exhibit 20 at 38‐39.  Each of these Atlantis project

engineer leads strongly denied Mr. Abbott’s characterization and

account of the meeting.  Indeed, prior to the meeting, Mr. Broman sent

an e‐mail, which referred to the spreadsheet that forms the basis of

most of Mr. Abbott’s allegations, regarding “Atlantis Document

Control” and provided the topics to be discussed, none of which

related to operational concerns.  In short, we found no evidence

corroborating Mr. Abbott’s description of this meeting.   

F. Alleged False or Incomplete Submissions to BOEMRE –

Submission of Structural Drawings

1. Allegations

Mr. Abbott alleges that BP failed to comply with 30 C.F.R § 250.904(a) and

(b) by failing to submit a complete set of structural drawings, including drawings

of subsea systems.  Mr. Abbott claims that “the vast majority of [subsea

component] engineering drawings were not ‘approved for construction’” and

that, as such, BP’s submission of drawings constituted a false claim to the United

States government.
41

2. Evidence Cited by Mr. Abbott

As previously discussed, Mr. Abbott’s allegations regarding the status of

certain engineering drawings are based primarily on his characterization of a

spreadsheet depicting the labels of drawings contained in the Documentum

database.  Mr. Abbott claims that conversations and e‐mails with other BP

personnel are evidence supporting his view of the status of the drawings.   

3. Findings

We found no evidence that the “vast majority” of subsea component

engineering drawings were not approved for construction.  We did find,

however, that BP’s inconsistent use of labels and the failure of BP to coordinate

the drawing labeling systems used by its contractors made it difficult to

determine whether BP complied with the requirements of 30 C.F.R. §

250.903(a)(1) (requiring maintenance of as‐built drawings for the functional life

of the platform) and 30 C.F.R. § 250.905(d) (requiring submission of approved‐

for‐construction fabrication drawings for the Platform Approval Program).  

Despite these labeling and document organization problems, we found

that BP followed a clearly defined process to transfer documents and drawings to

Atlantis operations personnel prior to first oil.  We found no evidence that BP

operations personnel lacked access to critical, engineer‐approved subsea system

drawings.  

Moreover, Mr. Abbott’s claim, which is focused on the allegedly

unapproved or missing subsea drawings, misstates the current requirements of

BOEMRE regulations.  The “as built” requirements in 30 C.F.R. 250.901(a) and 30

C.F.R. 250.905(d) apply only to structures associated with the platform.  

BOEMRE defines structures “associated with the platform” as those structures

that are weight bearing on the platform.  The following structures fall within the

scope of 30 C.F.R. 250.901(a) and 30 C.F.R. 250.905(d):  drilling, production, and

pipeline risers and riser tensioning systems; turrets and turret‐and‐hull

interfaces; foundations, foundation pilings and templates, and anchoring

systems; and mooring or tethering systems.  See 30 C.F.R. 250.910(b).  BOEMRE’s
42

regulations currently do not specifically require the submission and approval of

“as built” drawings for subsea components.13    

G. Alleged False or Incomplete Submissions to BOEMRE –

Verification by Certified Verification Agent (CVA)

1. Allegations

Mr. Abbott further alleges that BP violated 30 C.F.R. § 250.918 because the

CVA final verification report must address “the adequacy of the entire

installation phase, including recordkeeping.”  Mr. Abbott contends that the CVA

could not have rendered an accurate verification report without access to the “as

built” drawings that he claims were missing.   

2. Evidence Cited by Mr. Abbott

Mr. Abbott’s claim as to the allegedly false CVA verification appears to be

dependent on and derived from his allegations regarding missing or unapproved

Atlantis subsea drawings.    

3. Findings

We interviewed the CVA for the Atlantis project, ABS, in connection with

this investigation.  Our investigation confirmed that ABS reviewed the design,

fabrication and installation of the Atlantis production platform and complied

with all of the applicable BOEMRE requirements governing certifications (see

Exhibit 13 for details on the CVA process).   BOEMRE found no evidence to

support the allegation that ABS lacked access to engineering drawings when it

conducted its verification of the design, fabrication, and installation of the

Atlantis platform.  

 

13 The Recommendations section of this Report contains proposed changes to BOEMRE regulations 

as applied to drawings depicting subsea components. 
43

H. Alleged False or Incomplete Submissions to BOEMRE –

Statements About “As Built” Documents

1. Allegations

Mr. Abbott alleges that BP falsely certified that it had maintained a

complete set of “as built” documents in violation of 30 C.F.R. 250.903(a)(1) and 30

C.F.R. 250.905(k).

   

2. Evidence Cited by Mr. Abbott

Again, these allegations appear to be premised on Mr. Abbott’s claims

regarding missing and unapproved Atlantis subsea drawings.   In addition, Mr.

Abbott alleges that at least two different BP statements to BOEMRE (or MMS)

dated August 1, 2005 and August 9, 2010, were false.  See Exhibits 21 and 19.   

3. Findings

BP’s August 1, 2005 letter accompanied a Production Platform Safety

System Application required by BOEMRE regulations.  In that letter, authored by

Dennis Sustala, Atlantis Regulatory Compliance Coordinator, BP stated that:

[T]he designs for the mechanical and electrical systems to be installed

were completed under the supervision of registered professional

engineers.  Maintenance of the system will be by qualified personnel.  

All design data shall be kept at BP’s Houston, Texas office.   

See Exhibit 21.  BP’s August 10, 2010 letter stated that:

The design of this structure has been certified by a recognized

classification society, or a registered civil or structural engineer or

equivalent, specializing in the design of offshore structures.  The

certified design and as‐built plans and specifications will be on file at

BP’s offices in Houston, Texas.  

See Exhibit 19.   
44

BP’s August 10, 2010 letter provided a list of registered engineers

associated with BP’s August 1, 2005 statement regarding the supervision of the

design of the mechanical and electrical systems on the Atlantis.  BOEMRE found

no evidence that there was false information contained in either of these letters.    

I. Alleged False or Incomplete Submissions to BOEMRE – Deep

Water Operations Plan (DWOP) and Safety Hazard Analysis

(HAZOP)

1. Allegations

Mr. Abbott alleges that the Deep Water Operations Plan (DWOP)

submitted pursuant to 30 C.F.R. 250.293 and the safety hazard analysis

(“HAZOP”) 14 submitted pursuant to 30 C.F.R. 250.292 could not have been

accurate if BP did not have certain engineer‐approved drawings.   Mr. Abbott

also alleges that, as a condition precedent to beginning production, BP had to

apply for and receive approval for its production safety system, which he claims

required the submission of an accurate HAZOP and related piping and flow

diagrams.   

2. Evidence Cited by Mr. Abbott

Mr. Abbott claims that this allegation is supported by his claims regarding

missing or unapproved Atlantis subsea drawings.  He alleges that BP could not

have submitted an accurate DWOP or HAZOP without the drawings he claims

were never approved by BP engineers.      

3. Findings

Mr. Abbott’s allegations are premised on a fundamental misreading of

BOEMRE regulations.  Neither 30 C.F.R. § 250.292, which specifies the content of

the DWOP, nor 30 C.F.R. § 250.802(e), which specifies the documents necessary

for approval of the safety system design and installation, requires a hazard

analysis.  Furthermore, neither these sections of the regulations nor the API RPs

most relevant to hazard analyses – API RP 14C and 14J – require ʺas‐built,ʺ 

 

14   Mr. Abbott uses the term ʺHAZOPʺ to refer to a hazard analysis.  A Hazard and

Operability (HAZOP) Study is one method of hazard analysis, but there are others as well. See

API RP 14J, Recommended Practice for Design and Hazards Analysis for Offshore Production

Facilities at 38 (describing HAZOP as one method of hazard analysis).  API RP 14J is discussed in

more detail in footnote 4 and accompanying text.
45

ʺapproved for construction,ʺ or ʺapproved for designʺ engineering documents or

certification of the existence of documents labeled in this manner.  See section

I.B.1 of this Report for a more detailed explanation of these regulations.  

J. Alleged Unsafe Operating Conditions

1. Allegations

In his Congressional testimony, Mr. Abbott stated that the Atlantis

production platform may be a “ticking time bomb” and that the BP Atlantis

operations personnel may be “flying blind.”  Mr. Abbott alleges that BP

operations personnel do not have access to as built, engineer approved

documents depicting the Atlantis subsea system.   He claims that this creates

immediate safety risks.  He also testified that BP’s problems with the Atlantis

facility are similar to issues that led to the Deepwater Horizon accident.   

2. Evidence Cited by Mr. Abbott

Mr. Abbott bases these allegations on his claims and evidence

summarized above.     

3. Findings

Our investigation related to the Atlantis facility began before the

Deepwater Horizon accident occurred.  Since Deepwater Horizon, BOEMRE has

conducted a thorough investigation to determine whether there was any

evidence that supported Mr. Abbott’s allegations about unsafe operations on the

Atlantis production facility.  BOEMRE found no such evidence.    

While at BP, Mr. Abbott was a project manager whose job included

overseeing document control systems.  There is no evidence that, during his

employment with BP, Mr. Abbott raised concerns about unsafe conditions on the

Atlantis facility.   Mr. Abbott had no responsibility for operations of the Atlantis

platform.  Thus, he was never in a position to directly evaluate the safety of the

Atlantis facility’s operations.  Mr. Abbott’s allegations are premised entirely on

concerns about the adequacy and availability of design and engineering

documents.  However, Mr. Abbott was unfamiliar with the handover process for

providing documentation to operational personnel prior to first oil and,

therefore, he lacked first‐hand knowledge of the documents and drawings that

were available to BP Atlantis operations personnel.  None of the witnesses we
46

interviewed recalled that any BP operations personnel had ever expressed

concern about access to engineer‐approved drawings and documents necessary

to safely operate the Atlantis facility.   

If the facts warranted doing so, BOEMRE has the authority to suspend

BP’s operations or to revoke BP’s designation as an operator.  Because we find no

basis to conclude that the document organization and labeling problems that BP

admitted experiencing with the Atlantis facility amount to a threat of serious,

irreparable or immediate harm or damage, suspension is not warranted at this

time.  Likewise, Mr. Abbott’s allegations provide no basis that would support a

finding by BOEMRE that BP’s operating performance with respect to the Atlantis

facility was unacceptable.  Thus, revocation of BP’s designation as an operator is

not warranted at this time.  
47

RECOMMENDATIONS

1. In light of the increasing complexity of production operations in

deepwater, we recommend that BOEMRE evaluate:

(a) Expanding 30 C.F.R. § 250.905(d), or otherwise revising existing

regulations, to require accurate, up‐to‐date, clearly labeled “as built”

drawings for all structures that are connected in any way to oil or gas

production platforms, including all subsea components.  Operators would

be required to maintain engineering drawings for all components and to

label and organize those drawings in a way that will allow efficient review

by platform personnel and BOEMRE.

(b) Implementing a requirement, through expansion of the scope of 30

C.F.R. § 250.916‐.918 or some other means, that a CVA review the design,

fabrication, and installation of all subsea components.       

2. In light of the inherent difficulties in evaluating the condition of

subsea components, we recommend that BOEMRE consider promulgating a rule

that would require operators to perform annual ROV inspections of all subsea

components and maintain ROV footage and inspection reports for review, as

necessary, by BOEMRE.   

  

   

   
48

CONCLUSION

To address allegations raised by Mr. Abbott and members of Congress,

BOEMRE conducted an extensive investigation of the engineering drawings and

documents depicting the relevant components of the Atlantis facility and

carefully considered allegations that engineering documentation deficiencies

created unsafe operating conditions on the Atlantis.     

Our investigation found that the electronic document database that BP

used to store documents developed during the design, construction, and

installation of the Atlantis production facility was disorganized and inadequate

to handle the large volume of documents generated by BP and its third‐party

contractors.  In addition, BP used a confusing labeling system for engineering

drawings contained in the project files.  Those drawings also had other defects

and deficiencies, including undated and missing stamps and signatures, and

inconsistent titles for types of drawings.   

Our investigation found that Mr. Abbott’s allegations that Atlantis

operations personnel lacked access to critical, engineer‐approved drawings are

without merit.  We found no evidence that the document control deficiencies

listed above created specific unsafe conditions on the Atlantis production

platform.  Our investigation further concluded that Mr. Abbott’s allegations

about false submissions by BP to BOEMRE are unfounded.     

Our investigation, which went beyond the scope of Mr. Abbott’s

allegations and assessed BP’s compliance with additional BOEMRE regulations

regarding engineering drawings, determined that BP failed to file with BOEMRE

certain drawings depicting changes to a number of production safety system

components, in violation of 30 C.F.R. § 250.802.  BOEMRE has issued an incident

of non‐compliance (INC) to BP as a result of this finding.   

Based on all the evidence developed during our investigation, as well as

prior inspections and a thorough review of documents and drawings produced

by BP, we found no grounds for suspending the operations of the Atlantis

pursuant to 30 C.F.R. § 250.168 or revoking BP’s designation as an operator

under 30 C.F.R. § 250.135.