I have just stumbled across some witness testimony. Take a look before it gets taken down!
BP is pretty much an international company these days but still they do not make me particularly proud to be British.
MMS = Mineral Management Service
Statement of Kenneth W Abbott:
"My background and training is in the field of engineering project management. For over 30 years, I have worked in the management of a wide variety of large engineering projects. My employers have been among the largest engineering construction managers in the world including M.W. Kellogg, GTE Mobilnet, Stone & Webster, Brown & Root, Shell Oil, Jacobs Engineering and others. While I have worked on a wide variety of projects, the large majority have involved petrochemical and energy projects, including refineries and offshore facilities. (Resume attached as Ex. A)
Engineering project management is a field dedicated to management of large engineering projects. I am not an engineer and I do not do engineering. I provide management support for engineers by establishing project schedules and budgets and auditing performance against them. In addition, I manage engineering document control systems, database records, financial records and other types of management records necessary for the engineers to do their work.
Importance of Engineering Documents
Before a skyscraper, or a petrochemical plant, or an offshore production facility, or a wireless data network or any other major project can be physically constructed, it is first constructed on paper, or now in computers.
The first phase of building a project is to design the project, from overall concept down through systems and subsystems to individual parts. A complex project usually involves thousands of engineering drawings and documents; each one of which goes through many drafts and revisions before the final design is approved. Part of my job is to organize and
manage those drawings and documents so that engineers can find the correct document when they need it. The design phase ultimately arrives at an approved design which is certified by the engineering staff for the owner of the project.
After a design is certified, it is typically necessary for new drawings to be prepared to be used in the fabrication and construction of the project. These fabrication or construction drawings add details needed for the manufacture or construction of the physical equipment. These drawings are also approved and certified, again by the engineering staff for the owner. They are then turned over to vendors who use them for the actual fabrication or construction.
During the fabrication and construction phase, it often becomes necessary to make changes to account for unforeseen issues, such as how equipment physically fits together or takes up space. All such changes must be approved by the engineering staff for the owner and the drawings are modified and certified by engineering as matching the physical construction.
At the end of the project, the owner then has, not only the physical facility, but a large body of engineering drawings and documents which correctly record the actual physical construction, along with the history of changes made during the project which led to the final result. These final documents are referred to as “As-Built” drawings and documents; the term “as-built” means that these documents are up to date and correspond to the physical equipment in the facility. Therefore, someone can learn the physical facility by looking at the “as-builts.”
Many of the as-builts will be used by the Operations Department (the department which actually operates the facility) to create safe operating procedures, testing and maintenance procedures, training procedures, etc.
One of the important categories of drawings is P&IDs -- the abbreviation for Piping and Instrument Diagrams. Their importance lies in the fact that a petrochemical operation is similar to a giant spider web of pipes that connect vessels which contain the product with valves, pumps, heaters, and instruments which measure temperatures, flow rates and pressures. The Operations Department of the facility must constantly start, stop, redirect or maintain product flow or flow rates, or raise, lower or maintain
temperatures and pressure. Electronic signals are used to control the valves, heaters, pumps and other equipment based on information gathered by instruments and computerized operation procedures. The P&IDs document all of this equipment and how it is interconnected from the wellhead to where the product leaves the facility, and are the basis for developing the operating procedures.
In my experience, it is universally true that, for petrochemical facilities, as-built P&IDs must be turned over to the operations department that will operate the facility before startup of the facility. It is my training that a facility cannot be safely operated without up to date P&IDs. Textbooks say that P&IDs serve as a guide for those who will be responsible for the final design and construction. Based on this diagram:
1. Mechanical engineers and civil engineers will design and install pieces of equipment.
2. Instrument engineers will specify, install, and check control systems.
3. Piping engineers will develop plant layout and elevation drawings.
4. Project engineers will develop plant and construction schedules.
Before final acceptance, the P&IDs serve as a checklist against which each item in the plant is checked.
(Richard Turton, Richard C. Bailie, Wallace B. Whiting, Joseph A. Shaewitz, Analysis, Synthesis, and Design of Chemical Processes, 2nd Edition, 2003)
Experience at BP Atlantis
BP Atlantis is the world’s deepest moored oil and gas production facility; it is located in over 7,000 feet of water in the Gulf of Mexico about 150 miles south of New Orleans. It is rated to produce 200,000 bbls. of oil per day and large quantities of natural gas, far more than the Deepwater Horizon well now fouling the Gulf and its beaches.
In August, 2008, I started work under contract for the BP project management office for the BP Atlantis Project, on the Subsea Team. I was hired as a “project controls lead” and had responsibility which included management of the engineering documents.
The BP Product Execution Plan (PEP) for Subsea Atlantis fit into this system. BP Lead engineers were assigned to each sector of the project. Outside vendor Technip Offshore, Inc. was primary engineering contractor. At each phase, the BP Lead Engineers were to review and approve designs and technical documents for their respective sectors. It was specifically provided that: As-Built Documentation
The Lead Engineer for each discipline area will ensure that all technical documentation is updated to reflect the as-built condition of the equipment prior to deployment to the field.
A project such as Atlantis is incredibly complex in two ways: First, there are many components produced by many vendors which must all work together. Second, there are many challenges created by the extreme water depth which must be overcome by cutting edge engineering techniques. One of the functions of the owner/operator, BP in this case, is to assure that engineering knowledge and expertise look at the system overall to be sure that all of the parts function together; this is called “integration.” The signature of the BP engineer signing off on a given drawing signifies approval taking into account this integration function.
Almost immediately upon reporting to work, I was confronted with the problem that BP Atlantis Operations was demanding as-built P&IDs and we did not have them to provide to Operations. At this time, Atlantis had already been in operation for about a year and the equipment had long-since been deployed to the field.
I received a copy of an email (attached as Ex. B) written by my immediate predecessor in my job, Barry Duff, who had been promoted to another position. In it, he wrote why he was refusing to provide P&IDs to Operations. He wrote that:
“The P&IDs for Subsea are not complete have have [sic] not been approved or handed over to Operations.”
“This could lead to catastrophic Operator errors due to their assuming the drawing is correct. Turning over incomplete drawings to the Operator for their use is a fundamental violation of basic Document Control, the IM Standard and Process Safety Regulations.”
“Currently there are hundreds if not thousands of Subsea documents that have never been finalized, yet the facilities have been turned over.”
From this time until I was fired on February 5, 2009, I worked to obtain BP engineer approved, as-built P&IDs and all other as-built project drawings with little, if any, progress. Technip, the vendor company which was the lead engineering contractor did not have and could not provide up to date P&IDs. The lead engineers responsible for various sectors within the project did not have and could not provide up to date P&IDs. The more I insisted that we had to develop or obtain them, the more unpopular I became. At one point, BP management vetoed one plan because of its estimated cost of $2 million.
BP Atlantis Deficiencies
While I was at BP Atlantis, we developed a database in which we had all of the engineering documents and coded the database with the completion status (or latest approval status) of each document. We also obtained and put in the database the completion status as shown by Technip’s document control system. This allowed us to analyze overall what documents we had and their completion status.
The results were astounding to me. The Table (attached as Ex. C) shows the completion status for all documents in the various sectors of the project. The overwhelming majority of documents and drawings had never received any engineering approval at any phase of development. The last column shows the percentage never having any approval at all. Out of the total of over 7,000 drawings and documents, almost 90?ever received any approval of any kind, not even for design.
With reference to specific systems:
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. For all of these system, less than 10?ere certified as approved by engineering.
The wellhead is the equipment which controls pressures inside the well at the upper end of the casing, below the tree -- none of those documents ever had any engineering approval.
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 critical part of the Safety Shutoff System. On Atlantis, they also include valves to control flows related to the manifolds. Of these critical components, 98?ever received any engineering approval.
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.
I have now learned that MMS regulations as well as BP internal procedures and project execution plan require that designs for these facilities be approved by BP engineers specializing in the design of offshore structures. BP records reflect that the design was not, in fact, approved by engineers.
The Subsea portion of Project Atlantis was being constructed in “Drill Centers (DC’s),” each one of which collects the product from several wells and passes it to the surface facility. When I went to work for Atlantis, DC-1 was in production and DC-3 was under construction. It came to my attention that we did not have “approved for construction” documents for DC-3. In my experience, entering into construction without “approved for construction” documents can be a major problem. I immediately attempted to obtain approved for construction documents, but was never able to obtain them.
During development of such a project, it is normal that much of the equipment must be tested before being placed into service. I learned that the nature of the records kept by BP for such testing did not allow the results of a given test to be correlated to the item which was tested. As a result, there was no way for anyone to learn from the database whether a particular item had been tested with a particular test, or the results of the testing actually done on a particular component. In November 2008, I was
advised that BP personnel and Malcolm Voss, engineer for Technip, had reached an agreement on how to resolve this problem. However, a number of such agreements were reached which were never carried out; I have no knowledge of whether this agreement was actually completed.
While I was at BP, I spent many hours in meetings with my management and others on the Subsea Team attempting to solve the problems of the non-existent as-builts. It was never solved.
The lack of As-Builts is a common thread running through BP disasters from Texas City (15 dead) to Alaska (200,000 gallons spilled into Arctic tundra) to Deepwater Horizon (blowout preventer modified and would not close) to BP Atlantis.
Dept. of Interior and MMS Refuse to Act
Within a few days after being fired, I made a complaint about the situation to the BP Office of the Ombudsman which I understand was created after BP failed to respond to employee concerns regarding unsafe conditions at its Texas City Plant. It is my understanding that the Office of the Ombudsman is supposed to be sure that complaints of unsafe conditions are dealt with properly. I provided full information to the Ombudsman and had a number of meetings, telephone calls and written communications with them over the next several months. I did not receive any substantive reply from them for over a year. I will discuss that response later in my statement.
On March 9, 2009, I emailed Earl Devaney, Inspector General of the Dept. of the Interior at doioig.gov. I sent him full information on the unsafe conditions. I never received any response. Several months later, someone from that office contacted my attorney and confirmed that my email had been received. An employee from the OIG did contact me by phone once in mid 2009, but said he could not help since I was not a government employee. No one else from the DOI OIG ever contacted me about the unsafe conditions of the Atlantis project or took any other action to my knowledge.
After receiving no further response from the Department of the Interior, I contacted an attorney from the firm of Perry & Haas in Corpus Christi,
Texas. They asked me to furnish them with all of my documentary information and they wrote a letter providing all of that information to the Attorney General and the local United States Attorney (attached as Ex. D). They felt that the evidence showed that BP was committing fraud on the Federal Government by operating in violation of the statutes and regulations which govern oil and gas operations in the Gulf. On April 21, 2009, my attorneys filed a qui tam suit to force BP to repay to the Government the amount it had taken fraudulently. They also provided the Government with a report from an engineer detailing the importance of the BP Atlantis deficiencies and explaining that those deficiencies could lead to a catastrophic failure with resulting catastrophic harm to the environment of the Gulf of Mexico.
My attorneys have informed me that on May 19, 2009, they had a personal meeting in Houston, Texas with an Assistant United States Attorney. Also present by telephone were an attorney from the Department of Justice; another attorney from the Department of the Interior; and four representatives of MMS, Mr. Saucier, Mr. Domangue, Ms. Moser, and Mr. Herbst. My attorneys have reported to me that the MMS personnel strongly took the position that BP Atlantis was safe and they did not need to take any action.
On May 27, 2009, my attorneys wrote a lengthy letter to the attorney from the Department of the Interior warning that the kind of problems I have told them of created an imminent risk of catastrophe to the Gulf of Mexico (attached as Ex. E.). In this letter, my attorneys pointed out in writing the great threat to the environment created by deep water drilling if proper procedures are not following.
At a later date, I participated in a personal meeting with the Asst. United States Attorney, the attorneys from DOJ and DOI and the MMS representatives. Again, the MMS representatives strongly expressed their opinion that BP Atlantis was safe.
Since that time, I have relied on my attorneys and Food and Water Watch to seek action from the Government. In general, I am aware that they have been in contact with MMS continually for about a year, and have urged upon the MMS the importance of taking action to prevent a catastrophe in the Gulf. FWW has also contacted Members of Congress who have demanded action from MMS.
In April, I finally received a written response from the ombudsman. We have now learned that a BP internal investigation through Judge Sporkin, the ombudsman, verified my complaints about the absence of documentation for Atlantis (letter attached as Ex. F). Judge Sporkin was interviewed by AP and confirmed that BP did not have the necessary documents for Atlantis (attached as Ex. G). Regardless, MMS still refuses to take action.
Atlantis Deficiencies Similar to Deepwater Horizon
I am personally sick at heart over the Horizon tragedy. Like millions of others, my family and I have vacationed and fished in the Gulf, and used it for recreational purposes. My work and career are tied to the oil and gas industry, much of which is in the Gulf. I feel that the pollution of the Gulf, the destruction of the beaches, the destruction of its recreational and economic value is a national tragedy. I feel strongly that it would not have happened with proper procedures.
Several different causes for the blowout have been reported on the news. Many of them would be caused by the same problems I have seen on Atlantis.
blowout preventers did not close -- on Atlantis, safety shutdown system logic has not been engineer-approved; this could cause failure of shutdown systems;
rig crew did not understand makeup of blowout preventers -- this would be due to failure to have up to date as-built documents; same problem as Atlantis;
a mechanic apparently did not have access to manual shutdown procedures for diesel engines -- again, failure to have proper documentation;
there was apparently no gas sniffer and automatic shutdown for the diesel engines -- failure to have safety equipment which should have been present happens when proper engineering procedures are not followed.
etc! etc etc
I still think there is some onus on my government, the British government, to do something about such companies.
You can hardly expect Bush / Cheney to sort out the oil industry!
Now what will Obama do?
I WILL apologise for what happened. I WILL also apologise to the Nigerians as well! I will ease my conscience in any way i see fit.
A culture, like the one at BP, does not happen overnight. If the British legislators or regulatory authorities had been on the ball then a culture, like the one at BP, would never have developed to that stage in the first place.
Kinda reminds me of working at Glaxo - madness!!!
Sassy: yes, maybe its his attention to detail and concern for red tape issues like health and safety that got him fired?
Why don't we let BP run a nuclear power station??! I'm sure they'd pay out good dividends for their shareholders.
I'm glad I don't work on BP Atlantis!