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using multiple ROVs. During these attempts, it was discovered that the
ROV pump outputs were incapable of generating the volume needed to
shift shuttle valves and activate the BOP functions. In sum, the ROV’s
pumps did not have the same pressure and fluid flow as the accumulator
system that typically operates the BOP stack. Additionally, the ROVs
were not always equipped with the necessary hot stabs needed to connect
to the rig‐specific BOP stack. Further, the ram closing times are
significantly extended when using an ROV, creating the opportunity for
ram erosion due to the uncontrolled flow of wellbore fluids and solids
across the cutting and sealing surfaces of the ram blocks.

5. The Agency should consider researching the effects of a flowing well on
the ability of a subsea BOP to shear pipe.

6. The Agency should consider researching a blind shear ram design that
incorporates an improved pipe‐centering shear ram.

E. Regulatory Agency Recommendations

1. The Agency should consider revising 30 CFR § 250.443 (g) to refer to “[a]
wellhead assembly with a rated working pressure that exceeds the
maximum anticipated wellhead pressure,” rather than “surface pressure,” as
the regulation currently reads.

2. The Agency should consider revising the regulations at 30 CFR §
250.450(e) to define BOP testing ”problems or irregularities.” BP’s daily
operations reports noted that a pilot leak existed on one of the control
pods over the course of 17 days. This leak existed during a time when the
required BOP function and pressure testing occurred. Operators should
be required to report irregularities, such as this type of leak, to the
Agency.

3. The Agency should consider defining the term “properly functioning” in
30 CFR § 250.451(d), which states, in part, that if the lessee encounters a
BOP control station or pod that does not function properly, it must
“[s]uspend further drilling operations until that station or pod is
operable.” The Agency should also consider defining the term “proper
operation” under 30 CFR § 250.442(d), which states, “[t]he BOP system
must include an operable dual‐pod control system to ensure proper and
independent operations of the BOP system.” As indicated in this Report,

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