FISH

BP’s Atlantis: Will It Cause a Catastrophic

Accident in the Gulf of Mexico?
Fact Sheet • July 2009

What is the Atlantis?

The Atlantis is the deepest moored semi-submersible oil and gas platform in the world. Located in “hurricane alley,”
more than 150 miles off the coast of New Orleans at a water depth of more than 7,000 feet, the Atlantis weighs 58,700
metric tons and has a production capacity of 8.4 million gallons of oil and 180 million cubic feet of gas a day. Accord-
ing to Andy Inglis, BP’s chief executive of exploration and production, “the water depths and reservoir structure make
Atlantis among the most technologically challenging developments undertaken by BP.”

Why does the Atlantis pose a serious,
immediate and potentially irreparable
threat to the Gulf of Mexico’s marine
environment, oil workers and
communities?
ed safely. Unfortunately, the agency has not been respon-
sive to concerns about the Atlantis. The project became
active during the Bush Administration’s tenure and began
operating in October 2007. See the Food & Water Watch
letter to the agency on page 2.

BP has repeatedly skirted the law in developing the At-
lantis project. BP’s own database from November 2008
shows that it does not have the required engineering
certification for 85 percent of the project’s subsea piping
and instrument diagrams and many of its safety shut-
down systems’ logic diagrams. More than 6,000 docu-
ments that should have required engineering approval
— including those for pipelines, flowlines, wellheads,
and other important systems — do not have the required
engineering documentation. Over 95 percent of its subsea
welding specifications have no final engineering approval
and undersea manifolds have already been leaking. This
situation could lead to an unprecedented disaster in the
Gulf, because hurricanes create incredible stress on the
welds that are critical for containing oil and gas under
high pressure far beneath the surface of the ocean. Inter-
nal BP documents characterize the situation as having the
potential for “catastrophic operator errors.”
What can I do?
Tell Secretary of the Interior Ken Salazar to launch an
immediate investigation and, given the seriousness of the
situation, immediately suspend production at the Atlan-
tis. Ask your member of Congress to call for oversight
hearings on MMS regarding the regulation of the Atlantis
and what role the Bush Administration played in allowing
BP to operate the platform without proper safety docu-
mentation. Visit www.foodandwaterwatch.org/press for
more information.
An unnamed oil platform. Photo by Vee TEC/

Which federal agency is responsible for

regulating offshore drilling and why
hasn’t it taken action?
Stock.Xchng

The U.S. Department of Interior’s Mineral Management

Services (MMS) is the primary federal agency responsible
for ensuring that all aspects of oil, gas, leasing, explora-
tion, development and production activities are conduct-
Secretary Ken Salazar
Department of the Interior
1849 C Street, N.W.
Washington DC 20240

Liz Birnbaum
Director
Minerals Management Service
U.S. Department of the Interior
1849 C Street, N.W.
Washington DC 20240

Photo by StockXpert.
July 8, 2009

Dear Secretary Salazar and Director Birnbaum:

On behalf of Food & Water Watch (FWW), a non-profit
consumer organization that works to protect the food sup-
ply, clean water, and ocean resources, I write this letter
to express our grave concerns about new information we have learned about the British Petroleum Atlantis Oil and
Gas production platform (BP Atlantis). We urge MMS to suspend the platform’s production immediately so that the
agency can complete an investigation and prevent a catastrophic failure.

First producing oil in 2007, the BP Atlantis is the largest moored floating dual oil- and gas-production facility in the
world. It has a production capacity of 8.4 million gallons of oil and 180 million cubic feet of gas a day.

It has come to FWW’s attention that a company database shows the platform lacks a large percentage of engineer-ap-
proved and up-to-date documents for its subsea equipment, notwithstanding that the platform has been operating for
more than a year and a half. These vital drawings are necessary for the project’s safe operation and maintenance. For
example, we understand that the platform lacks a large percentage of “issued for design,” “issued for construction,”
and “as built” subsea piping and instrument diagrams (P&IDs). It is our understanding that such P&IDs demonstrate
the interconnection of subsea piping and control instrumentation and that they are significant because they illustrate
the physical sequence of equipment and systems. Such schemes are the basis for hazard and operability analyses
(HAZOP), which are required to maintain safe systems. It has come to FWW’s attention that database shows that 85%
of the platform Atlantis’s subsea P&IDs have no engineering approval whatsoever. This raises serious questions, such
as how the facility can verify that its HAZOP analyses are reliable.

As another example, FWW understands that the database shows that over 95% of the platform’s subsea-welding speci-
fications have no final engineering approval. The organization has also been told that the platform lacks approval for
close to 90% of other critical subsea engineering documents.

FWW is very concerned that the apparent lack of final, engineer-approved documentation may mean that the plat-
form has serious design problems. The organization also fears that these deficiencies increase the risk of catastrophic
operator errors, leading to harm to platform workers, the marine environment, and local fishing communities. For
example, the company’s failure to document all actual work performed could result in such a seemingly minor mistake
as installing a valve backwards; yet this allegedly caused the near sinking of the BP Thunder Horse Platform. (See im-
age on the next page.) Indeed, last fall, BP staff drew the same conclusion about the risk of catastrophic error from the
incomplete documentation.

These deficiencies are especially disconcerting because our nation is 37 days into hurricane season. This year, the
National Oceanographic and Atmospheric Administration predicts a 70 percent chance of between nine and 14 named
tropical storms. Four to seven of these could become hurricanes, with as many as three reaching the category three
level or higher. Tropical storms can wreak havoc on energy platforms in the Gulf of Mexico, posing serious harm to
the marine environment and the local fishing communities that rely on it. For example, in 2008, 60 platforms were
destroyed as a result of Hurricanes Gustav and Ike. The Associated Press reported at least 448 releases of oil, gaso-
line, and other substances in Louisiana and Texas as a result of Hurricane Ike. The worst spill identified was nearly
266,000 gallons of oil released from a battery of storage tanks on Goat Island, Texas. All of this damage pales in
comparison to that caused by Hurricanes Katrina and Rita, which destroyed 113 platforms, and during which 9 million
gallons of oil were released from six major and five medium-sized spills.
 Platform Thunder Horse after Hurricane Dennis.
Photo courtesy of the U.S. Coast Guard.
Oil is toxic to the plants and animals at the base of the marine food chain. It also sickens and kills birds, mammals,
and fish. Oil spills can severely harm coastal economies, including the country’s $32 billion commercial fishing and
$60 billion ocean and coastal tourism and recreation industries.

Given the extent of the platform Atlantis’s apparent lack of documentation, and the serious dangers that can result
from operating without it, we urge MMS to launch an immediate investigation, pursuant to 30 C.F.R. § 250.193
(2008). MMS should examine whether the platform presently possesses a complete set of “as built” certified engineer-
ing documents for the entire project including the subsea portions of the project. The platform’s apparent documenta-
tion failures seem to violate MMS regulations including those requiring compiling and retaining “as built” documents
for the life of the project. See e.g., 30 C.F.R. § 250.903 (a)(1) (2008). If the company now claims to have proper
documentation, we ask that MMS obtain copies and have them verified by independent experts.

While this investigation is being completed, we urge MMS to order an immediate suspension of the platform’s produc-
tion, as authorized under the 30 C.F.R. § 250.172 (2008), because the continued production of the platform “poses
a threat of serious, irreparable, or immediate harm or damage . . . to life[,] []including fish and other aquatic life[],
property, . . [and] the marine, coastal, or human environment.”

We understand that this information was first reported to the Department earlier this spring. Therefore, FWW also
asks to be kept informed about the status of all past, current, and future Department activities to investigate the plat-
form’s documentation failures.

We appreciate your time and attention dedicated to this very important matter.

Sincerely,

Wenonah Hauter
Executive Director
Food & Water Watch

For more information:

web: www.foodandwaterwatch.org
email: info@fwwatch.org
phone: (202) 683-2500 (DC) • (415) 293-9900 (CA)

Copyright © July 2009 Food & Water Watch