Bud's Offshore Energy (BOE)

BOE has returned in time for an interesting day of testimony by Mr. Duncan,  PTTEP’s well construction manager.  Tom Howe, Commission attorney, was in fine form (as usual) and took Mr. Duncan to task for the root-cause cementing and barrier decisions, and PTTEP’s seeming reluctance to accept responsibility.  When told that MMS requires 2 tested barriers, Duncan tried to equate the brief period when BOPE is removed (after cementing) to install a new wellhead section with leaving a well suspended for months without a legitimate barrier.  He continues to claim claim that PTTEP had a tested and verified barrier in the annulus despite the cement miscalculation and the absence of any log or test to verify the top of the cement.

Random thoughts while reading the testimony:

1. Are mud line suspensions acceptable, if (as was the case at Montara) there is no means of monitoring casing pressures during the suspensions?
2. Kudos to Advanced Well Technologies, a completion contractor that told PTTEP (prior to the blowout) they were taking undue risks to save money, and stopped working for the company.  Why hire experts, if you don’t intend to listen to them?  PTTEP seemed intent on cutting costs without assessing the risks.
3. Where is the independent review that was prepared for PTTEP’s parent company and why hasn’t it been provided to the Commission?

Of particular interest to BOE are the philosophical questions raised by the quotes below:

Q. Howe: What about sending a request to the regulator in the middle of an afternoon on a Friday, asking for approval to substitute PCCs for a cement plug to enable you to get cracking doing that the very next day and the day after, that is, over the succeeding weekend – do you think that that signifies at all the fact that things were being done on the run, you were getting around to doing things belatedly and barely staying on top of things?
A.  Duncan: That particular event, to an extent, yes.

If you are going to administer a command-and-control regulatory regime, you better be prepared to respond to frequent requests for program deviations, and you better be able to say no.  If you are a regulator, you are not part of the operating team and you shouldn’t think of yourself as such.  Absent compelling justification, changes in fundamental safety measures should not be authorized.  More philosophically, if you have to approve everything a company does, should that company be allowed to serve as an operator?  Also, how much accountability does the regulator assume by approving these deviations?

BOE will summarize Days 8-12 during the Commission’s Easter break.