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trained on these procedures. In particular, rig crews need guidance on
when to divert the flow overboard.

7. The Agency should review its procedures for analyzing the well activity
reports to determine if the operator is accurately reporting significant
anomalies (e.g., ballooning, lost returns, wellbore integrity failures).
Currently, the requirements for the well activity reports include reporting
of significant well events including, for example, lost returns, kick
occurrence, and wellbore integrity failure. Under current Agency
procedures, the engineer reviews the current approved procedure and
compares it to the well activity report to ensure that the operator is
complying with the approved permit.

8. The Agency should clarify the wellbore monitoring regulations contained
in 30 CFR § 250.401(c) to address potential kick detection failures, like the
ones that occurred at the Macondo well. This provision currently states
that an operator should “[e]nsure that the toolpusher, operatorʹs
representative, or a member of the drilling crew maintain continuous
surveillance on the rig floor from the beginning of drilling operations until
the well is completed or abandoned, unless you have secured the well
with blowout preventers (“BOPs”), bridge plugs, cement plugs, or
packers.” The Agency should clarify the meaning of the term ʺmember of
the drilling crew,ʺ which is too broad and does not address specific
requirements for surveillance of the well. The Agency should also clarify
the meaning of the phrase ʺsecured the well,ʺ which does not address how
the effectiveness of different cement barriers should be evaluated and
monitored.

C. Ignition Source Recommendations

1. The Agency should consider including in the Safety Alert discussions on
design considerations of existing and planned air intake locations,
operating philosophy when conducting design hazard analyses of Mobile
Offshore Drilling Units (MODUs), inspection and testing documentation
of all safety devices for engine shutdown, and performance of site‐specific
safety analyses of safety devices to ensure that systems align with
operating philosophy.

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