link: Investigation of May 15, 2021, Fatality, Eugene Island Area Block 158 #14 Platform
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 |
The subject (May 2021) fatality occurred during a casing integrity pressure test, and some of the risk factors were familiar:
- The operator, Fieldwood Energy, was facing bankruptcy, and had a poor performance record.
- 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.
The report also fails to address the lease administration practices that enabled a problem operator to expand their lease holdings. Indeed, BOEM’s inexplicable proposal to eliminate a company’s performance record in determining the need for supplemental bonding would exacerbate the risk of more such incidents. (See these comments on the BOEM proposal).
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.
Bud's Offshore Energy (BOE) 
This Well Control Rule comment, endorsed by 7 trade associations, hit a nerve. Here’s why.
Posted in drilling, Offshore Energy - General, Regulation, well control incidents, tagged BSEE, NTTAA, standards, standards vs. regulations, trade association comments, Well Control Rule on November 30, 2022| Leave a Comment »
The comment (pasted below) by the trade associations asserts that BSEE ignored the requirements of the National Technology Transfer and Advancement Act (NTTAA).
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