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there were BOP control system hydraulic leaks were noted in the daily
operations report; however, they did not impede the closing ability of the
annular or ram preventers. These leaks did require the placement of the
BOP controls into the “block/neutral/vent” position in order to stop or
slow the hydraulic leak. The Agency needs to determine if a pod with
hydraulic leaks of this nature is an “operable pod” and/or is
“function[ing] properly.”

4. The Agency should consider promulgating regulations that would require
designated operators to report leaks associated with BOP control systems
on the IADC daily report, in the well activity report, and to the district
drilling engineer. This would ensure that the Agency is aware of the leak
and could either require the operator to suspend operations and fix the
leak or determine that the leak will not affect the operation of the BOP
system and allow operations to continue.

5. The Agency should consider revising the definition of “well control” at 30
CFR § 250.1500 to read as follows: “Well control means drilling, well
completion, well workover, and well servicing operations. It includes
measures, practices, procedures and equipment, such as fluid flow
monitoring, to ensure safe, accident‐free, and pollution‐free drilling,
completion, and workover operations as well as the installation, repair,
maintenance, and operation of surface and subsea well control
equipment.” This revision would establish minimum expectations for
who should be trained for their roles in monitoring and maintaining well
control at all times. This new definition would encompass mudloggers as
well as subsea engineers and anyone who has the responsibility for
monitoring the well and/or maintaining the well control equipment. As
discussed in the Report, the mudlogger played a critical role in monitoring
the well along with the driller and assistant driller. BP, however, did not
identify the mudlogger as a person needing well control training or a
person responsible for monitoring the well for kick detection.

6. The Agency should consider expanding 30 CFR § 250.446 to include
documentation and record keeping requirements for major (3‐5 year)
inspections as required by BOEMRE’s adoption of API RP 53, which
identifies what major inspections and maintenance should be performed.
However, API RP 53 does not indicate the necessary records needed to
document that the major inspections were performed. This recordkeeping

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