Comments on BSEE’s proposed revisions to the Well Control Rule are due in 27 days (by Nov. 14). Given the fundamental importance of well control to offshore safety and pollution prevention, all interested parties are encouraged to comment. Although some of the proposed revisions are rather nuanced, the document is neither long nor complex.
My completely independent comments are being drafted and will be posted here after they have been submitted to Regulations.gov.
My comments will explain why the proposal may reduce the rigor of the BOP system performance standard and will address a related shear ram issue. The comments will also discuss the management of BOP equipment failure and other safety data, the use of independent third parties and standards development organizations, dual shear rams on surface BOP stacks, ROV intervention capabilities, and BOP test data reporting and management.
Forensic evidence from independent post-incident testing by Det Norske Veritas (DNV) and evaluation by the Transocean investigation team confirm that the Deepwater Horizon BOP was properly maintained and did operate as designed. However, it was overcome by conditions created by the extreme dynamic flow, the force of which pushed the drill pipe upward, washed or eroded the drill pipe and other rubber and metal elements, and forced the drill pipe to bow within the BOP. This prevented the BOP from completely shearing the drill pipe and sealing the well.
In other words, Transocean contends that properly maintained BOPE was not up to the task of shutting-in and securing a high-rate well. If true, this finding has significant implications for the offshore industry. I’m looking forward to reading the government’s findings on the BOP failure when the Joint Investigation Team report is issued next month.
Because of recent involvement with products and systems that have Safety Integrity Level (SIL) ratings, I read the comment (below) in the PSA Deepwater Horizon review with interest. While administrative and effectiveness issues must be carefully assessed, the application of SIL should be part of the BOP performance dialogue. SIL ratings may also be appropriate for entire well control or well integrity systems.
Today’s requirements stipulate a risk analysis for the control system of a drilling BOP, with specified minimum requirements for its safety integrity level (SIL). As a result of the DwH incident and of the fact that blowouts are not confined to drilling operations, the question is whether such an analysis, with a specified minimum SIL level, should also apply to all types of BOPs, including well-intervention models. In addition, consideration should be given in this context to whether other control and management systems related to well integrity/control exist which should be subject to such requirements.
From the standpoint of post-Macondo safety and regulatory issues, this concise summary is the most comprehensive and useful report that I have read since the blowout.
I have pasted (below) comments about information management – one of the many important topics considered in the report – and hope you take time to read the entire summary. It is only 12 pages.
Conducting a critical review of the information used to manage major accident risk is one of the measures relevant for the companies. This work could include an assessment of the relevance, reliability and modernity of the indicators used to follow up risk trends inappropriate use of indicators, incentives and reward systems the need for better indicators and other information about the business which can be used to secure an early warning about a weakening in safety-critical barrier elements. The PSA is of the opinion that the quality of information applied in managing major accident risk is also a question of what overview the players have of their own business, and thereby a question of the players’ own control. The PSA assumes that managing major accident risk cannot be outsourced. In light of the DwH accident, it could be relevant for the companies to review the processes intended to provide the necessary information about the business, assess in part how these processes support a culture ofaccountability and how various management and audit functions, third-party verifications and so forth contribute in this connection.
“It would seem to me, reading between the lines, that the cockpit crew weren’t confident of the information that was being presented to them on the data displays. Maybe — and it’s only a maybe — they took some action that led to the stall warning, and the plane stalling and then being unable to correct it.”
The above quote from a new article on the Air France crash should sound familiar to BOE readers. At both Montara and Macondo, the evidence of hydrocarbon influxes was clear, but personnel misinterpreted or ignored that information. Was this wishful thinking on their part? Was their training flawed? Lack of sleep? Overstressed? Distracted? These issues need to be carefully studied.
Improving well control preparedness is not simply a matter of modifying stack design. The thought processes and human response tendencies that contribute to well control incidents and other accidents must be fully considered. Monitoring systems must provide timely, accurate, and understandable information, and training programs must teach workers not to rationalize negative signals, but to respond with caution pending further assessment. Trainers must remind students about past disasters and how they could have been prevented.
Good report and relatively timely. Nice job by the team.
Good discussion of the heater-treater and production safety issues.
This was a very serious incident and lives were jeopardized. Sadly, no oil spill means no public attention.
Why didn’t the Coast Guard participate in the investigation? Will they be reporting on the haphazard evacuation?
Age old question: Is the rather extensive discussion of violations appropriate for an accident report? Should violations and enforcement actions be managed independently from accident investigations?
BOE: Floating liquefaction facilities open interesting possibilities for producing natural gas in remote offshore locations, possibly including the arctic. The first FLNG facility will be 488 m from bow to stern! Offshore to the future!
BOE: Lots of posturing and not much in the way of meaningful proposals from either party. Unlike Australia, the US has not responded to its blowout with necessary legislative action, most notably the establishment of a single offshore safety and pollution prevention regulator.
Deepwater Wells: Lessons and Recommendations focuses on the critical prevention programs, and is perhaps the most important of the GIRG reports. Since Macondo, the GIRG team and other industry committees have worked diligently on well planning and integrity issues, and are commended for their outstanding efforts. However, the recommendations presented in the GIRG report are surprisingly modest, and do not reflect the technological and management innovation that industry has demonstrated in pioneering offshore development. The recommendations fail to break new ground, lack specifics, and, in some cases, appear to be a step backward. In short, the oil and gas industry is capable of much more. Initial comments follow:
Incident data (problem): The absence of comprehensive and verified incident data is one of the “systemic” industry weaknesses identified by the National Commission. OGP has tried to address this problem for years, but has not had the industry-wide support needed to develop a credible program. GIRG has wisely recommended a Wells Expert Committee (WEC) to review selected incident data. However, the recommended program suffers from the same weaknesses that constrain existing OGP reporting programs. OGP must rely on “encouraging” its members to participate voluntarily, and non-members are not included. This type of voluntary program was not good enough before Macondo/Montara, and is certainly not good enough now.
Incident data (solution): Industry and regulators need an ironclad commitment that all operating companies will submit incident data in accordance with defined protocols. Contractor data must be included. Companies should execute binding agreements with OGP, or some other entity, to provide this information. The data must be managed by a completely independent entity that cannot, in any way, be directed by an industry advocacy group. Regulators and other independent representatives should be included on the management committee. Regulators should prohibit companies that don’t agree to submit these data from from operating within their jurisdictions. A comprehensive incident reporting and data management system is long overdue, and continued delays are not acceptable.
Montara: While GIRG is supposedly in response to both Macondo and Montara, the latter seems to have been largely ignored. The deepwater theme does not apply to the Montara platform, which was in only 80m of water. Despite the post-Macondo focus on water depth, shallow water was arguably a more significant contributing factor to the Montara blowout (batched completions using a cantilevered jackup, mudline suspensions, and two-stage platform installation) than deep water was at Macondo. Also, well capping, which was feasible and ultimately successful at Macondo, could not even be attempted at Macondo because of the manner in which these platform wells were suspended. Finally, GIRG ignores the special gas migration and kick detection issues associated with horizontal completions like Montara, and the relief well rig availability and release issues that were never fully addressed during the Montara inquiry.
Emergency worldwide notification system: In conjunction with the incident reporting system, industry needs an emergency notification procedure that goes beyond safety alerts and requires the immediate attention of every operator and wells contractor. During the Montara inquiry, worldwide attention should have been drawn to the inability of the Montara operator to identify a hydrocarbons influx through the shoe track and into the production casing. Could an effective notification system have prevented Macondo? No one can say for sure, but the probability of a blowout at Macondo would have been greatly reduced if key BP and Transocean personnel had participated in discussions about Montara and the importance of proper negative pressure tests.
Dependence on regulator: On page 21 of the report, GIRG recommends that a company “carry out a more extensive programme of self-audit” when there is a lack of competent regulatory oversight. An operator should never depend on the regulator to verify its well or management programs, and should never relax its programs regardless of the level of regulation. Detailed regulatory reviews of specific drilling or management programs are never a substitute for operator diligence. Did the operators at Montara and Macondo rely on the regulator to protect them from themselves? Read the official investigation reports and make your own judgement.
Best practices: GIRG recommends “refraining from using the term ‘best industry practice’ until this definition is clarified; we prefer ‘good oilfield practice’ for the time being.” Isn’t the clarification of best practices the role of groups such as this and industry standards committees? This attitude explains some of the technical recommendations in this report which may be “good oilfield practices,” but fail to raise the bar for safety achievement. Would you be satisfied with “good” if family members were working on rigs or if operations were conducted off your coast? While “best practices” vary depending on the conditions and circumstances, it’s industry’s responsibility to identify those practices, and industry and regulators must set the bar high and keep raising it.
GIRG recommends established practices: Some of the GIRG recommendations, such as the “two-barrier” policy have been standard practice for most operators for years.
API RP 75: There are numerous endorsements of RP 75 as an important reference for management systems covering the design of wells and other activities. RP 75 was a reaction to an MMS regulatory initiative 20-years ago to impose safety management requirements on offshore operators. BP, Transocean, and PTTEP had management systems that were generally consistent with the guidance in RP 75. GIRG needs to go beyond RP 75 and focus on improvements that will make safety management systems more effective.
API Bulletin 97, Well Construction Interface Document (WCID): Despite the complete absence of public attention, this is perhaps the most important post-Macondo initiative. It’s thus particularly disappointing that this document is now five months late. How does GIRG recommend the use of a document that is not complete and has not yet (to the best of my knowledge) even entered the balloting process? Another recommended and highly important document, updated RP 96 – Deepwater Well Design, has also yet to be finalized.
BOP recommendations: Nothing new or innovative is offered by GIRG. The report calls for 2 shear rams, but only one need have sealing capability, which means that the Deepwater Horizon stack met the GIRG specification. While many BOP advances require additional study, some (such as real-time function and pressure monitoring systems) already exist. Other GIRG technology recommendations are rather timid and generally in the form of suggestions for future study (e.g. study cement bond log technology).
Training: This section of the report is good, but doesn’t address deficiencies identified in the Montara inquiry and reviews of historical blowout data. Montara and other accidents have demonstrated that senior rig personnel may have limited understanding about well planning and construction practices. These topics are not covered in well control training programs. How does industry plan to address this major deficiency? While well planning is the responsibility of the operator (often a separate group than is represented on the rig), well control decisionmaking requires a fundamental understanding of well construction practices. Also evident in the Montara testimony was the total absence of understanding on the part of operator, drilling contractor, and cementing personnel about the historical causes of blowouts. The cementers at Montara were unaware that gas migration/influxes during cementing operations were a leading cause of blowouts. Training programs need to be expanded to provide for the discussion of past accidents and how they could have been prevented.
“I didn’t have a lot of set ideas about how things should work in the energy industry,” Jahnke said. “So I thought ‘Why can’t we try a curved blade?’ like the curved hook on a Swiss Army Knife can opener.”
Since January, T-3 has been testing Jahnke’s design, slicing through just about every size of drill pipe and casing used in the Gulf.
National Oilwell Varco is showing customers its new shear rams — a pair of trident-like blades that puncture a drill pipe before cutting it to shreds. The ShearMax Low Force Casing Shear Rams are aimed at cutting through tool joints – the thickest section of a drill pipe where it screws into another section of pipe.
GE Oil & Gas’ Hydril line of blowout preventers include a hardware and software system that allows an operator to know exactly how far shear rams close within the blowout preventer.
Another new Hydril product captures the natural pressure thousands of feet underwater to help activate a shear ram.
Weatherford International has touted its new “closed-loop” drilling system, which allows for better monitoring for gas as mud comes back from a well during drilling.
“The Deepwater Horizon BOP was unreasonably dangerous, and has caused and continues to cause harm, loss, injuries, and damages to BP (and others) stemming from the blowout of Macondo well, the resulting explosion and fire onboard the Deepwater Horizon, the efforts to regain control of the Macondo well, and the oil spill that ensued before control of the Macondo well could be regained,” BP said in the suit.
The following question is based on an interesting email message that I received from JL Daeschler, a pioneering subsea engineer:
One of the final acts on the Deepwater Horizon crew appears to have been the activation of the emergency disconnect sequence (EDS). The DNV report concludes that this emergency sequence was triggered, but never actually initiated, probably because of a loss of communication to the BOP stack after the initial explosion. Is it possible that the EDS sequence actually was initiated, but that the incomplete closure of the shear ram terminated that sequence?
Looking forward to next week’s hearings. Hopefully C-SPAN will televise the proceedings, because there is not indication that the Joint Investigation has arranged for live streaming.
Bud's Offshore Energy (BOE) 
Comments on BSEE’s proposed Well Control Rule are due by Nov. 14
Posted in drilling, Offshore Energy - General, Regulation, well control incidents, tagged BOP, BSEE, comments, Well Control Rule on October 18, 2022| Leave a Comment »
Comments on BSEE’s proposed revisions to the Well Control Rule are due in 27 days (by Nov. 14). Given the fundamental importance of well control to offshore safety and pollution prevention, all interested parties are encouraged to comment. Although some of the proposed revisions are rather nuanced, the document is neither long nor complex.
My completely independent comments are being drafted and will be posted here after they have been submitted to Regulations.gov.
My comments will explain why the proposal may reduce the rigor of the BOP system performance standard and will address a related shear ram issue. The comments will also discuss the management of BOP equipment failure and other safety data, the use of independent third parties and standards development organizations, dual shear rams on surface BOP stacks, ROV intervention capabilities, and BOP test data reporting and management.
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