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Archive for April, 2010

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Coast Guard Photo

“It’s burning pretty good and there’s no estimate on when the fire will be put out.”  Mike O’Berry, US Coast Guard

The Coast Guard is hoping to locate the missing in an escape capsule or life raft. link

All BP personnel are reported to be safe.

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Preliminary (and unsubstantiated) information:

  1. Fire is uncontrolled
  2. BOPE actuated
  3. MSRC activated (oil spill response cooperative)
  4. Search and rescue ongoing
  5. Rig is listing
  6. Approximately 20,000 bbl diesel on rig

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The Coast Guard reports:

  1. 7 critical injuries

  2. 11-12 missing

  3. The fire is still burning

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Deepwater Horizon

The Coast Guard is reporting an explosion last night on the Deepwater Horizon, a Transocean drillship working for BP in the Gulf of Mexico.  The Horizon was working in Mississippi Canyon Block 253 about 52 miles off the coast of Venice.

Details are sketchy, but 126 people are reported to have been evacuated.  Local news is reporting 8 critical injuries and some missing personnel.

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My experience is that you unfortunately often need a major accident or even a disaster to engender political support for streamlining regulatory regimes.   Moreover, history shows that major accidents apparently must happen in your own jurisdiction to have such an effect on political support. Magne Ognedal

Magne’s astute comment repeatedly came to mind while I was reading the Montara testimony.  Our political systems are good at reacting, but are not so good at making tough decisions when the spotlight is elsewhere.  Crises provide the political capital needed to make major changes, but seldom yield the best solutions.

Will the Montara blowout provide the impetus needed for other countries to review and improve their offshore regulatory regimes?  These Montara issues should be of concern to all of us:

  1. Multiple regulators with unclear divisions of responsibility
  2. Regulatory gaps and overlap
  3. Ineffective use of standards and best practices
  4. Lack of clarity regarding operator and contractor responsibility and accountability
  5. Balancing goal-setting with prescription
  6. Monitoring operations effectively without taking “ownership”
  7. Applying regulatory resources efficiently and where the risk is greatest
  8. Absence of meaningful performance measures for operators and regulators
  9. Authority to remove rogue operators
  10. Ability to update standards and regulations in a timely manner
  11. Weaknesses in training programs for operators, contractors, and regulators

I’ll stop at ten (now eleven :)).

Many of these issues will be discussed at the International Regulators’ Offshore Safety Conference in Vancouver (18-20 October). I hope you plan to attend!

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Like mowing a 40 acre field with a 1/4 inch lawn mower. ~ Ed Tennyson, 1989

Reading today’s transcript reminded me of my colleague Ed Tennyson’s famous comment about the response to the Valdez spill in Prince William Sound, Alaska.  Ed’s comment, which appeared on the front page of the Wall Street Journal, was typically colorful and fitting.  A media darling, Ed was given a time-out for that one, but rebounded nicely.

I’m not suggesting that the Montara spill and response were a mismatch of Valdez proportions.  The Montara responders seemed to be competent and made reasonable decisions.  However, the testimony does suggest the need for some improvements in the response regime.  A few observations:

  1. There appears to be a need to clarify responsibilities and liability limits for studies and damages.  Also, consideration should be given to an oil spill trust fund (paid for by a per barrel production and transportation fee) to cover any additional authorized costs.
  2. It seems that all of the slick monitoring was visual.  Mr. Berger is right in alleging that there are now more accurate methods.  AMSA should investigate  aerial slick mapping and thickness measurement capabilities.
  3. It seems at least one Federal agency did not step up and provide requested assistance during the crisis.  Further explanation is necessary.
  4. When a well is blowing out, you shouldn’t rely solely on slick data to estimate the spill rate.  PTTEP should have used reservoir and well design data to model the flow and estimate the spillage rate.

Howe (Commission): I have been absolutely struck by the technology and the accuracy of the transcript and the promptness with which it comes up

Amen to that; great job by the recorders!

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Q. Mr. Berger (Commission): Do you recall my putting to both Mr Marozzi and Mr Whitfield a commentary on Mr Marozzi’s evidence to the effect that it was not a good day for the Northern Territory?
A. Mr. Trier (NT DoR) Yes.
Q. Having sat through Mr Marozzi’s evidence and the other evidence that you have heard in the Inquiry, you would agree with that assessment, wouldn’t you?
A. Yes, I agree
Q. That would be fairly sobering evidence, I take it, for you to hear, given your role within the department?
A. I am not trying to be smart. That’s an understatement.

Comment: Mr. Trier and Mr. Whitfield, senior managers with the Northern Territory Department of Resources, demonstrated the approach that managers should take when their organization is partially or fully accountable for a major accident – be contrite, promise changes, and seek external guidance.  The Montara blowout was a pollution spectacular that reflects poorly on all of us.  While assigning blame, we should make sure that our own houses are in order and that we are doing everything we can to prevent a recurrence – anywhere in the world.

Q. Berger: You also heard evidence that Mr Marozzi considered PTT one of the less risky, or safest, operators that he was dealing with; do you remember that evidence?
A.  Trier: Yes, I do.

Comment: I wonder what the other NT operators think about that statement?  How would you like to be like to be ranked below PTTEP?

Other comments:

  1. While some of the PTTEP witnesses appear to get it, the official company position still seems to be that it’s okay to withhold internal reports, that corrosion caps are equivalent to cement plugs and packers, and that barrier policies are fluid and negotiable.
  2. It seems that the current NT regime allows operators to specify how they will submit data.  Assuming information is only required for important resource, safety, or environmental management purposes, submission requirements should, in my view, be as prescriptive as possible (even in a goal-setting regime).  How else can the responsible agency compile data, assess trends, and conduct comparative analyses?
  3. According to the testimony, a governmental auditing agency identified staffing and resource needs in the NT DoR.  While this may be the case for DoR, what percentage of internal government audits draw similar conclusions?  How many of these audits find that you have sufficient resources, and that they are appropriately managed and distributed?  None that I’ve ever seen.
  4. The hearings close tomorrow.  Who’s hosting the party?  Can we participate online? 🙂

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Sometimes I feel a little foolish spending hours each day reading Montara transcripts and commenting to my small blog audience.  Then I get a call or an email message from people who are closely following this investigation and understand its significance – regulatory experts like Odd Finnestad in Norway, experienced engineers like Tom Maunder in Alaska, serious reporters like Anthea Pitt with Upstream and Kevin Spear with the Orlando Sentinel, and representatives from all sectors of the offshore industry.  That’s when I realize the effort is worthwhile.  Even more gratifying was Mr. Berger’s acknowledgment (beginning on page 109 of today’s transcript) of my Day 18 blog entry.  I appreciate the Commission’s outstanding efforts on behalf of offshore safety, and their interest in the opinions expressed on BOE.

Q. Mr. Berger (Commission): So you say it is not your job to read the daily drilling report to determine whether things like barriers have been installed offline in a batch drilling operation?
A. Mr. Marozzi (Northern Territory Department of Resources): I’m not saying that.
Q. That’s someone else’s job, is it?
A. I’m not saying that. It is my job, but I can only do it to a level that our resources allow.
Q. These daily drilling reports are hardly War and Peace, are they? They’re typically two or three pages; that’s right, isn’t it?
A. That’s true, yes.

Comment: I couldn’t resist this entirely fitting “Not My Job” mention.  If an important task is not your job, you need to either make it your job, or see to it that the operations cease until someone has been identified to do the job and do it well.

THE COMMISSIONER: All I’ve heard is that Mr Marozzi and his unit don’t have the resources to respond properly. I doubt very much if the department doesn’t have sufficient resources, should it so choose, to allocate sufficient resources to this task. It’s a matter of choice on their behalf, I would have thought, but that’s something that can be established at some stage over the next day or do.

Comment: The Commissioner has clearly been in the government long enough to know it’s all about priorities, and perhaps senses that the NT DoR’s were a bit misplaced.

Other comments:

  1. Mr. Marozzi indicated that he had limited experience with horizontal wells.  One gets a sense that neither the operator nor the regulator dedicated sufficient resources to technical training.
  2. It seems that Mr. Marozzi may have been thinking more in terms of a casing shoe that was about to be drilled out than about a shoe in a well that was going to be suspended.  If the well was drilled out, the cement channels would have been less of an issue and the Formation Integrity Test would have evaluated the integrity of the shoe.
  3. In reading the NT submission on the Commission’s website, I was surprised that the NT DoR refused to admit that the cementing of the 9 5/8″ casing and the absence of barriers were contributing factors to the blowout.  Thanks to Mr. Berger’s questioning, the NT has finally conceded on these points.
  4. The legislative response in Australia will be very interesting.  The Commonwealth-State jurisdictional issues clearly need to be sorted out.  While the Montara review does not reflect well on the NT, the WA and Victoria regulators seem to have acquitted themselves well.
  5. Most countries have jurisdictional challenges similar to Australia.  Will they learn the lessons from Montara?  Regulatory mosaics don’t work.  Gaps, overlap, confusion, finger-pointing, and turf battles increase safety and environmental risks and regulatory and operational costs.

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Q. Berger (Commission): Even if you do have a drilling background, Mr Marozzi, I suggest that how drilling activities are undertaken is often as important, if not more so, than what is going to be undertaken?
A. Marozzi (Northern Territory Department of Resources): Not really. To the operator, yes, but not really to the regulator. It doesn’t really matter how it is done, to  the regulator, in a lot of cases.

Transcript

To this outside observer, it was not a good day for the Northern Territory Department of Resources.  While it is premature to speculate on the Commission’s conclusions and the followup actions by the Australian government, today’s testimony has not helped the NT cause.   The witness’s attitude seems to be that if it’s good enough for the operator, it’s good enough for the regulator; and it’s not a good time to be giving that impression.  While, operator responsibility should be a fundamental tenet of any regulatory regime, the regulator needs to verify the effectiveness of the management and operational systems.  This can be accomplished through some combination of audits, inspections, program and plan reviews, performance measures, and other means.  However, the regulator cannot be passive in any type of regime – performance-based, prescriptive, or hybrid.

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