Page 209 - test2

underway on the Deepwater Horizon prior to the blowout increased the
difficulty of monitoring the wellbore.

2. The Agency should consider researching what meter accuracy is
acceptable, as well as the placement of flow meters for the purpose of kick
detection. Flow meters are accurate within 5‐10%. Placement of these
meters is critical so that the well can be accurately monitored and the
vessel motion effect minimized.

3. The Agency should consider revising the incident reporting rule at 30 CFR
§ 250.188 to capture well kick incidents, similar to the March 8, 2010,
Macondo well control event. Under current regulations, operators are
only required to report “losses of well control” and are not required to
report “well control” events such as kicks. The reporting of these events
would allow the Agency to track them and evaluate trends that may
indicate problems with a specific operator or contractor.

4. The Agency should consider working with industry to develop a
standardized negative test procedure with interpretation guidance. As
discussed in this Report, BP considered several negative test procedures
without specific interpretation guidance. If interpretation guidance had
been provided to the rig crew, the early signals of the well flowing may
have been detected and the blowout averted.

5. The Agency should consider researching the effect of water depth on kick
detection and response times in comparison to shallow water. Prompt
kick detection is critical in deepwater operations with a subsea BOP stack.
It is imperative that the rig crew detect well flow before the hydrocarbons
rise above the BOP stack. If the kick is not detected until after the
hydrocarbons rise above the BOP stack, then well control response options
are severely limited and the risks of a blowout are significant.

6. The Agency should consider promulgating a regulation at 30 CFR §
250.416 that allows for the limited use of mud gas separator (MGS)
systems. The Agency should consider including the requirements in API
RP 96A in this regulation. MGS systems are designed to circulate out
kicks in a controlled manner but are not designed to handle a large
volume of uncontrolled flow. Operators must have procedures in place to
guide the rig crew’s use of the MGS systems, and rig crews must be

204