On Nov. 17, the Coast Guard reported a “crude oil release” in the Gulf of Mexico near the Main Pass Oil Gathering (MPOG) company’s pipeline system southeast of New Orleans. After 3 weeks of investigation, no pipeline leak has been identified.
The cause and source of the incident remain under investigation. The entire length of the main pipeline has been assessed to date, along with 22.16 miles of surrounding pipelines with no damage or indications of a leak identified. Remotely operated vehicles (ROVs) and divers continue to reassess the main pipeline and surrounding pipelines as a sustained effort to locate the source of the suspected release.
Postaccident investigation determined that the containerships MSC Danit and Beijing had dragged anchor near the pipeline months before the oil release, on January 25, 2021.
Firstly, taking 2.5 years to publish an investigation report is unacceptable for an organization with BSEE’s talent, resources, and safety mandate. Unfortunately, such delays now seem to be the rule as the summary table (below) for the last 4 panel reports demonstrates. The most recent report implies that the actual investigation was completed in 2-3 months. Why were another 2+ years needed to publish the report? (Note that the lengthy and complex National Commission, BOEMRE, Chief Counsel, and NAE reports on the Macondo blowout were published 6 to to 17 months after the well was shut-in.)
incident date
report date
elapsed time (months)
incident type
5/15/2021
10/31/2023
29.5
fatality
1/24/2021
7/24/2023
30
fatality
8/23/2020
2/15/2023
30
fatality
7/25/2020
2/15/2023
31
spill
Four most recent BSEE panel reports
The subject (May 2021) fatality occurred during a casing integrity pressure test, and some of the risk factors were familiar:
The platform was installed 52 years prior to the incident, and had been shut-in for more than a year.
The well of concern (#27) was drilled in 1970, sidetracked in 1995, and last produced in February 2013.
Diagnostic tests clearly demonstrated communication between the tubing, production casing, and surface casing.
In light of the known well integrity issues and the absence of production for more than 8 years, the prudent action would have been to plug and abandon the well in a timely manner. However, under 30 CFR 250.526 as interpreted at the time, Fieldwood had another option – submit a casing pressure request to BSEE to confirm the integrity of the outermost 16″ casing and (per p. 10 of the report) “continue to operate the well in its existing condition.” Given that the well had not produced for 8 years and that the platform had been shut-in for more than a year, the option to continue operating the well should not have been applicable.
The only issue for Fieldwood to resolve with the regulator should have been the timing of the plugging operation. Additional well diagnostics would only serve to create new risks and further delay the well’s abandonment.
The resulting pressure test of the outermost (16″) casing was solely for the purpose of confirming a second well bore barrier. Per the report (p.10), there is a “known frequency of outermost casings in the GOM experiencing a loss of integrity as a result of corrosion.” Whether or not the 16″ casing passed the test, the inactive well had clear integrity issues and should have been plugged.
Fieldwood proceeded with the pressure test rather than correcting the problem. The regulations, as interpreted, thus facilitated the unsafe actions that followed. These factors heightened the operational risks:
Extensive scaffolding and a standby boat were needed for the test.
Process gas via temporary test equipment was used to conduct the test.
The Field-Person In Charge (PIC) heard about the test for the first time on the morning of the incident.
The PIC and victim had no procedures to follow, and had to figure out how to conduct the test on the fly.
A high pressure hose was connected without a pressure regulator or pressure safety valve.
The digital pressure gauge had two measurement modes, one to display pressure in psi and the other in bars. (One bar is equivalent to 14.5 psi. Assuming that the readings were in psi rather than bars would thus result in serious overpressure of the casing.)
Seconds after the victim told the field-PIC the pressure was 175 psi (presumably 175 bar and 2538 psi), the casing ruptured. The force of the explosion propelled the victim into the handrail approximately 4 feet away, which bent from the impact. The victim’s hardhat was projected 60 to 80 feet upwards, lodging into the piping.
The investigation report fails to address the wisdom of conducting the pressure test and the regulatory weaknesses that enabled Fieldwood to defer safety critical well plugging operations. The pressure test option in 30 CFR § 250.526, was not intended for long out-of-service wells with demonstrated well integrity issues. The only acceptable option was corrective action (plugging the well) without further delay. The pressure test option added risks without addressing the fundamental problem and helped enable the operator to further delay decommissioning obligations.
Postscript: According to BOEM data, the lease where the fatal incident occurred expired on 7/31/2021. Per the BSEE Borehole and structures files, neither the platform (#14) nor any of the other 4 structures remaining on the lease have been removed, and the well (#27) has yet to be plugged.
An excellent compliance and incident update by Jason Mathews is attached. BSEE’s focus on risk assessment, compliance and incident trends, high potential near-misses, medivac capabilities, hot work safety, lifting operations, and gas releases is encouraging. Good work by the folks in BSEE’s Gulf of Mexico Region.
Observations:
Zero 2023 occupational fatalities through Q3. Hoping this holds through the end of the year and beyond.
INCs/component are down but INCs/inspection are slightly higher. This may imply a relative increase in the inspection of high component deepwater facilities.
No. of hours worked is increasing; good sign for the offshore program.
Hand and finger injuries are driving up the injury count.
Well control incidents are stable at a low level.
Improved fire data help facilitate risk assessments
No YTD explosions
No. of collisions is down
10 YTD spills> 1 barrel (total volume not specified)
Some evidence of decline in lifting incidents in Q2 and Q3
Gas releases are up (aging facilities, decommissioning related?)
BSEE shouldn’t have to issue guidance about helicopter loading precautions that every worker and visitor should be taught before going offshore, but apparently they do. See the safety alert that is attached below.
In this alarming near-miss event, a helicopter was stationed on the facility’s helideck and a crew member approached the aircraft from the rear, entering the rotor arc area before the rotor blades had come to a complete stop. This unsafe action posed a significant threat to the safety of all personnel involved. An offshore helideck assistant repeated the unsafe behavior by approaching the helicopter from the rear, entering the vicinity of the tail rotor, and positioning themselves within the main rotor’s danger zone immediately after the helicopter had landed on the facility’s helideck.
When the findings from important investigations are delayed, information leaks serve to control the narrative and satisfy political or economic objectives. Why are these intelligence organizations so eager to assign blame within the Ukrainian government? Why are the actual findings of the investigations not being released? Perhaps the WP and Spiegel reporters can answer those questions.
Former secret service agent Roman Chervinskyi in court in Kyiv in April; photo: Nikita Galka
According to the joint research by DER SPIEGEL and The Washington Post, Chervinskyi’s name is circulating both in Ukrainian and international security circles in connection with the attack on the Nord Stream pipelines. The former agent allegedly coordinated the attack and also provided support for the specialist unit behind the sabotage operation.
Cautionary note:
People in Western security circles say that the Ukrainian security apparatus is plagued with rivalries and infighting, and that information obtained from sources there must be handled with caution.
Per the IRF guidelines, “Helicopter operations at or near an Offshore Installation” are supposed to be counted. The fatal 12/29/2022 incident clearly happened at the platform’s helideck (photos below).
NOPSEMA has kindly provided links for the slides presented at the 3-4 October International Regulators’ Forum Offshore Safety Conference in Perth, Australia. They will be uploading the video recordings at a later date.
On day 2 (stream 2) Bryan Domangue (BSEE) presented updated data on the progress that is being made in plugging inactive wells and decommissioning idle platforms (see the charts pasted below). In the following session, Bryan made an interesting presentation on the capping stack deployment exercises in the GoM (picture below).
For excellent slides on investigation and sharing the lessons learned, see session 9 (day 2, stream 1).
Consistent with the findings of their inspections and data gathering (as discussed further here), BSEE has published a safety alert (attached) that identifies significant shortcomings in medical evacuation planning and performance.
The findings suggest that a renewed focus on medevac preparedness should be an immediate industry priority. Note the evacuation time, supply, training, and other planning issues summarized in the BSEE alert. Also note the helideck safety issues that were identified. These issues are particularly troubling in light of last December’s fatal crash.
Bud's Offshore Energy (BOE) 