Archive for the ‘well control incidents’ Category

There are a number of recent articles related to the Guyana Supreme Court ruling on Exxon’s financial assurance obligations. An Oil Now piece (quoted below) is the most informative. It seems that the Supreme Court decision is based on a provision of Exxon’s EPA permit and that EPA is siding with Exxon in this dispute.

The Guyana government and the Environmental Protection Agency (EPA) are set to appeal a recent Guyana Supreme Court ruling that determined that the EPA and ExxonMobil affiliate, Esso Exploration and Production Guyana Limited (EEPGL), breached the terms of the Liza 1 environmental permit. The permit was revised and granted to EEPGL last year for operations in the Stabroek Block, offshore Guyana.

Justice Sandil Kissoon granted several declarations, including that the EPA failed to enforce compliance by EEPGL of its Financial Assurance obligations to provide an unlimited Parent Company Guarantee Agreement and/or Affiliate Company Guarantee Agreement to indemnify and keep indemnified the EPA and the Government of Guyana against all environmental obligations of the Permit Holder (EEPGL) and Co-Venturers (Hess and CNOOC) within the Stabroek Block.

While acknowledging the court’s ruling, the Government of Guyana, as a major stakeholder, maintained in a statement that the Environmental Permit imposes no obligation on the Permit Holder to provide an unlimited Parent Company Guarantee Agreement and/or Affiliate Company Guarantee Agreement. The government believes that Justice Kissoon erred in his findings and that the ruling could have significant economic and other impacts on the public interest and national development.


Unlimited liability is a rather daunting and open-ended obligation that would trouble permittees in any industry.

In the US, the liability for oil spill cleanup costs is unlimited for offshore facilities, but there is a liability cap for the resulting damages. That cap is currently $167.8 million after a recent inflation adjustment. BP, of course, paid far more than that for damages associated with the Macondo blowout. BP’s costs, which amounted to an astounding $61.6 billion, were both voluntary and compulsory as a result of agreements and settlements. Keep in mind that the damage liability limit was only $75 million at the time. One can imagine what would have happened if a company with less financial strength or more inclination to fight had been responsible for the spill.

Read Full Post »

Sharing this touching tribute to the 11 men who died on the Deepwater Horizon on April 20, 2010. These American heroes gave their lives exploring for energy to power our economy. The video is introduced by singer Trace Atkins, a former Gulf of Mexico rig worker. Please take a moment to watch.

Other Macondo posts.

Read Full Post »

Per yesterday’s post, below are US OCS fatality data from a 2014 presentation. Ten year intervals were selected for 1975-2004. The longer 1953-1974 era was selected so the activity indicators (well starts and production) would be comparable with the next 3 intervals. The last interval (2005-2013) was limited because the presentation was prepared in 2014.

Fire/explosion fatalities exceeded fall/struck fatalities only in the first interval (1953-1974). As one would expect, the fire/explosion deaths were associated with a limited number of better known incidents (e.g. Main Pass 41, Bay Marchand, Macondo). While the overall trend is favorable, fall/struck incidents and helicopter fatalities at offshore platforms have proven to be more chronic.

I hope to update these data in the not too distant future.




Read Full Post »

Now that the 2021 US OCS incident spreadsheet has been posted and I have commented on the fatalities, I’ll be looking at some incidents by category starting with losses of well control (LWCs). Incident summaries and links to investigation reports follow the bullet points.

  • 4 LWCs incidents in 2021
  • None posed a significant threat to worker safety or the environment
  • All were deepwater wells
  • 3 were during exploratory drilling and 1 was during completion operations
  • All 3 drilling incidents involved water flows after setting 22″ surface casing.
  • The completion LWC was the result of the inadvertent opening of fluid control devices. The report on this incident provides important information for well completion risk assessments.

Incident summaries

Spreadsheet incident 19: Well completion operation. Inadvertent shearing and opening of the fluid loss control devices were not adequately assessed during the planning and review phases of the completion. While displacing the wellbore from 14.8 ZnBr to 14.8 packer fluid, the downhole equivalent circulating density sheared the upper and lower fluid loss control devices. The rig immediately began to experience fluid losses of 600 bph. A 50 bbl fluid loss pill was spotted and losses slowed to 345 bph. A second fluid loss pill was pumped which significantly decreased the losses eventually resulting in zero losses. After losses stopped, the rig experienced approximately a 14 bbl gain on the trip tank. The well was shut in on the annular and circulated out using the driller’s method. Oil was observed in the returns. While waiting on additional fluids and materials, wellhead pressure was managed by bullheading 14.8 brine when required. The well was killed via bullheading down the annulus followed by bullheading down the workstring with 3 CaCo3 pills. investigation report

BOE comment: While the cause of this incident is classified as “human error,” the failure to properly assess and plan for risks associated with the inadvertent shearing and opening of the fluid loss control devices is an organizational/management issue.

Incident 186: Shallow water flow during exploration drilling. Lost well. A shallow water flow was observed from one of the ports in the 38″ wellhead housing following cementation of the 22″ riserless casing string at Caramel Keg (GB 962 #1). Additional wireline logging (casing bond log and temperature log) runs were performed to gain additional insights into the potential source/location of the flow, as well as the quality and presence of cement behind the 22″ casing string. Approval from BSEE Lafayette district was received on April 1st to proceed with running the riser/BOP and continue with subsequent planned operations. Flow from the wellhead was monitored and a general reduction trend in flow from wellhead port was observed. Approval was received from BSEE on April 19th to install and close ball valves on two wellhead ports to isolate flow from wellbore. On April 20th, the ball valves were closed and flow from the wellbore ceased approximately 23 days after initial observation. Approval to temporarily abandon the well was received from BSEE on April 25, along with a monitoring plan of the wellbore and the surrounding area. TA operations concluded on April 27th. The ongoing monitoring program has since identified no indications of flow/broaching at or near the GB 962 #1 wellbore as of May 7th. No personnel were injured or evacuated as a result of this subsurface shallow water flow. report

Comment: The BSEE incident investigation team determined that salt contamination probably caused the cement to go under-balanced triggering flow and channeling behind the 22-in casing.

Incident 478: Exploration well – 7188′ WD; exploration. The 22″ casing cement job went as planned with positive cement returns to the mudline from dye and pH meter. The rig observed post cementing flow. Flow was predominantly gas. The flow started with a single source from the seabed, about 20 ft away from the wellhead. Within the next 2-3 hours, two other flow sources developed, one immediately adjacent to the jetpipe while another flow source surfaced about 10ft away from the wellhead. The rig continued to monitor the post cementing flow and completed multiple ROV wagon wheel surveys. No new seafloor anomalies or active flow points were identified away from the wellhead. Minor flow of water and gas continued at the wellhead. No investigation report.

Incident 507: Post Cement Flow Summary: The 22″ casing was cemented in place at 2:30 AM on August 18, 2021. At approximately 5:45 AM, a minor post cementing flow was observed by the ROV. The flow was only observed from 1 cement port/ball valve connected to the 28″x22″ annulus. The flow composition was predominately cement and absent hydrocarbons. The ROV continued to monitor the flow. No investigation report.

Read Full Post »

Details on the Santa Barbara blowout from last year’s BOE post.

Read Full Post »

Raphael is a highly regarded offshore safety leader and a positive force for continuous safety achievement in Brazil and internationally.

Read Full Post »

The comment (pasted below) by the trade associations asserts that BSEE ignored the requirements of the National Technology Transfer and Advancement Act (NTTAA).


  • BSEE and its predecessors (MMS and the Conservation Div. of USGS) have been incorporating industry standards since 1969, 27 years prior to the enactment of the NTTAA (1996).
  • 127 standards are currently incorporated into the BSEE regulations. Does this imply ignoring the NTTAA?
  • The keystone of the BOP regulations, API Standard 53, is cited in 250.730, the very section of the rule that is under discussion. Seven other industry standards are cited in that section of the rule. Does this imply ignoring the NTTAA?
  • Regulators cannot cede their authority to standards development organizations. If a standard is outdated or deficient, the regulator must address the issues of concern.
  • Deviations between provisions in the regulations and API Standard 53 are expected and specifically provided for in 250.730 as follows: “If there is a conflict between API Standard 53 and the requirements of this subpart, you must follow the requirements of this subpart.
  • For years, the production safety system regulations specified different leakage rates for surface and subsurface safety valves than those allowed in the API standards. An MMS research project addressed and helped resolve these differences.
  • While essential to safety and regulatory programs, standards are not a panacea; nor is the standards development process without weaknesses. One need only consider the case of the delayed cementing (zonal isolation) standard to appreciate both the importance of standards and the potential weaknesses in the development process.

Read Full Post »

I recommend we Nationalize the Oil and gas industry. I think the government is the right entity at this time to seize all the assets and infrastructure of the cartels. The resources mostly on public lands and water, belong to the USA anyway. It is time we transition more rapidly to renewables to break the leverage of the cartels on governments, and people, to stop wars and profiteering.

People are paying high prices and cartels like API, Exxon, Sinclair are making record profits from American’s purses. All the while escaping the costs of oil spills and leaks, and denying responsibility for climate change disasters and their costs.

Anonymous WCR commenter (0010)

Diverse input on proposed regulations is healthy and desirable. However, comments should not be posted at Regulations.gov unless (1) the commenter is identified and (2) the comments include at least one sentence about the regulation being proposed.

Read Full Post »

Per Regulations.gov. BSEE received 30 comments on the proposed revisions to the Well Control Rule, 25 of which have been posted. The other comments were presumably deemed inappropriate for posting per the guidance at Regulations.gov.

Two of the responses were submitted collectively by 8 industry trade associations. Only 3 operating companies commented and their comments largely echoed the trade association responses. Only 2 drilling contractors responded independently. Four service and engineering companies commented.

Three environmental organizations, a group of Atlantic states, a government watchdog, and a law school provided comments.

Three individuals and 4 anonymous or unknown parties commented.

Below is a list of the respondents preceded by their comment identifiers. More to follow.

  • 0003 Foley Engineering
  • 0004 Frank Adamek
  • 0005 Anonymous
  • 0006 Project on Government Oversight (POGO)
  • 0007 E.P. Danenberger
  • 0008 Chevron
  • 0009 B. Mercier
  • 0010 Anonymous
  • 0011 Anonymous
  • 0012 Foley Engineering (2nd comment)
  • 0013 HMH (?)
  • 0014 NYU School of Law
  • 0015 Beacon Offshore
  • 0016 Shell
  • 0017 Diamond Offshore
  • 0018 7 industry trade associations: API, IADC, IPAA, NOIA, OOC, EWTC, USOGA
  • 0019 NOV (service company)
  • 0020 NRDC
  • 0021 Oceana
  • 0022 Transocean
  • 0023 Louisiana Mid-Continent Oil & Gas Association
  • 0024 Kinetic Pressure Control Limited
  • 0025 Attorneys General of Maryland, Connecticut, Maine, Massachusetts, New York, and North Carolina
  • 0026 Ocean Conservancy
  • 0027 Rigscope International

Read Full Post »

Comments on the proposed revisions to BSEE’s Well Control Rule are due on Monday (11/14/2022). My comments were submitted yesterday, and I have attached a copy for those who might be interested. Bud

Read Full Post »

Older Posts »