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Posts Tagged ‘safety’

Following the Piper Alpha tragedy (1988) and the Exxon Valdez spill (1989), the Minerals Management Service, under the direction of Dr. Charles Smith, embarked on new research to address the human and organizational factors that are fundamental to offshore safety. An important 1993 report, MMS project 167, Management of Human Error in Operation of Marine Systems by Robert Bea and William Moore, observed that:

High consequence accidents resulted from a multiplicity of compounding sequences of breakdowns in the human, organization, and system; often there are precursors or early-warning indications of the breakdowns that are not recognized or are ignored.” The human element is complex and “states” such as “fatigue, negligence, ignorance, greed, folly, wishful thinking, mischief, laziness, excessive use of drugs, bad judgement, carelessness, physical limitations, boredom, and inadequate.” Environmental factors such as weather conditions, time of day, smoke, and noise further complicate human performance.

Bea and Moore, 1993

COVID 19 has further complicated human performance and facility management. In an effort to better understand human factors during COVID, NOPSEMA (the Australian offshore safety regulator) has partnered with industry, and labor organizations, and universities to survey offshore workers.

Per the survey announcement:

Your unique insight on the impacts of the COVID-19 pandemic on members of the offshore workforce are vital to informing industry and the development of strategies that best support employee mental health and well-being.

BOE is looking forward to learning about the results of this survey and other efforts to better assess and understand mental health challenges facing offshore workers. The effective integration of mental health considerations into management systems is critical to safety achievement.

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Phil Rae piece in Fuel Fix

  1. The well clearly had losses through the shoe during the initial displacement of the heavy spacer with seawater, immediately prior to the negative test.
  2. Allowing for, and accepting, losses of ~80 bbls during spacer displacement, explains ALL pressure and flow anomalies without the need to create or invoke undocumented and unsubstantiated valve closures or manipulations that contradict witness testimony of events. It also eliminates the need to adopt unrealistically-low pump efficiencies for the rig pumps, hypothetical washed-out tubing and ridiculously high viscosities for the drilling mud, in an effort to fit questionable computer models.
  3. Despite extensive examination by investigators and the publication of several reports, the fact that the well experienced losses, making it even more severely underbalanced than was planned, has been given little credence or has received little or no attention, despite several clear indications that this was the case. While this statement regarding losses may be self-evident, its significance on the outcome at Macondo merits closer examination since it explains many previous, apparently-contradictory aspects of the disaster.
  4. Under-displacement of heavyweight spacer, as a result of losses during displacement, caused U-tubing and partial evacuation of the kill line, the lower end of which was later refilled with heavyweight spacer, driven by pressure and flow from the formation. The vacuum, initially, and subsequent invasion of heavy fluid rendered the kill line useless for monitoring the well since the line was effectively blind to pressure changes in the well.
  5. While initial flow into the well was through the shoe, pressure above the casing hanger seal during the negative test was reduced to levels that could have allowed the casing to lift, compromising the seal and possibly also allowing flow from the external annulus.
  6. The well encountered further losses during the second displacement (to displace the riser), after completion of the negative test. These losses, which were perhaps as much as 200 bbls, effectively replaced heavy mud with sea water in the casing below the drill pipe. This further underbalanced the well to the point that it was being kept under control only by pumping friction pressure. As the pump rate was reduced prior to shut down for the sheen test, effectively reducing system backpressure, the now severely underbalanced well began to flow.

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Much ado about nothing courtesy of the Associated Press:

Copies of the forms submitted by more than 100 inspectors, engineers and permit reviewers in five Gulf coast offices were obtained by the AP under the Freedom of Information Act. Personal information, such as the names of the employees, their friends and their family members, was blacked out to protect privacy. But the companies with ties to government workers were disclosed, and they represent a who’s who of the offshore oil and gas industry, from majors like Chevron, Shell and BP to smaller companies such as W&T Offshore Inc., Ankor Energy LLC and Hilcorp Energy Co.

So yesterday we linked an article about proposed legislation that would, among other things, require that offshore inspectors have “at least three years experience in the oil and natural gas field.” Today, we read contradictory (and silly) comments like the one below in the AP piece that criticize such experience. How would you like to be an oil and gas inspector or prospective offshore regulator?

“It’s nearly impossible to determine where the oil industry ends and the government’s regulatory agency begins,” said Scott Amey of the Project on Government Oversight, after reviewing AP’s data. “These new instances indicate that BOEMRE staff are connected to individuals and oil companies, which raises concerns about lax oversight and the integrity of the agency. Without enhanced enforcement authority and independent oversight of these potential conflicts, I’m uncertain that BOEMRE can assure the public that it is truly watchdogging the offshore oil industry.”

Give these people a break. I have seen absolutely no evidence that improper government-industry relationships or compromised inspections had anything to do with the Macondo blowout or any other recent incident. Inspection and engineering personnel are under continuous scrutiny well beyond what most employees would accept, and recuse themselves from assignments if there could be even a perception of a conflict of interest.

The US offshore program, and every other safety regulator, needs people who understand the operations and technology that they regulate. These regulators need to communicate regularly with industry personnel on operational and regulatory issues. Too little interaction with their professional peers is a greater danger than too much. You don’t advance safety technology and procedures, and resolve concerns, without communication.

DOI offshore personnel have had and will continue to have more than enough oversight; time to move on to another cause.

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from Platts Oilgram News:

Representatives Ed Markey of Massachusetts and Rush Holt of New Jersey introduced the so-called No Free Inspections for Oil Companies Act (H.R. 2566) July 15, in reaction to House Republicans’ proposal for funding the Bureau of Ocean Energy Management, Regulation and Enforcement. About $35 million short of the Obama administration’s request, the GOP’s $154 million budget rejected new and more expensive fees on offshore operators. The administration wanted to ratchet up industry fees to $65 million a year, from $10 million, to pay for a tougher inspections regime.

The annual inspection fees debate, a budget season ritual for 20+ years, has picked up intensity and financial significance in the post-Macondo spotlight. However, discussions about regulatory philosophy and the fundamental program decisions that dictate inspection strategy are still absent. Safety and pollution prevention are the goals, not inspections. While inspections are an essential part of any safety regime, they are just one component of a comprehensive regulatory program. More inspections would not have prevented Macondo. Better standards, training, technology, and attention to prior incidents (most notably Montara) may have.

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Encouraging report from Steve Walker and his HSE colleagues.

Figures from the Health and Safety Executive (HSE) show that there were 73 major or significant hydrocarbon releases associated with offshore installations in 2010/11, compared with 85 the previous year. There were 61 recorded in 2008/09 – the lowest since HSE began regulating the industry. Overall, there continues to be a downward trend in the total of all reported hydrocarbon releases offshore.

For the fourth year running, no workers were killed during offshore activities regulated by HSE and 2010/11 also saw a fall in the number of major injuries. There were 42 reported compared with 50 the previous year, bringing the total in line with the average of the previous five years.

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Our friend Tore Fjågesund from WellBarrier sent us this clever poster.

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14.07.2011 | On Wednesday 13 July, a fire broke out in the compressor area of Valhall PCP. Today the Petroleum Safety Authority Norway (PSA) will send two representatives to Valhall to investigate the incident.

The fire, which was reported to the authorities yesterday afternoon, started at around 4.40 p.m. A standby vessel was deployed to put out the fire and at 6.45 p.m. it was confirmed that the fire had been extinguished. All personnel were evacuated and there were no injuries.

link

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If someone had asked me a few years ago what the highest risk offshore system was, I certainly would not have said a fully cased well in the process of being suspended. Yet that was the scenario for both of the recent mega-incidents, Montara and Macondo.

I would have instead suggested that dynamic production risers were the highest risk offshore system. The combination of relatively new technology, movement,  fatigue potential, exposure in the splash zone, and continuous hydrocarbon flow poses risks that must be carefully managed.  That is why investigations of incidents like the Visund gas leak are so important. In that regard, PSA does an excellent job and prominently posts all of their reports so that we all may benefit. I recommend that you take a look at this one.

In connection with the planned shutdown on Visund on 9 April 2011, a hydrocarbon leak occurred from well A21’s 6” flexible riser UK-18-0009. The Petroleum Safety Authority Norway (PSA) has carried out an investigation of certain aspects of the incident.

 We have identified three nonconformities within the areas of establishment and follow-up of preconditions for safe operation of dynamic risers, training and expertise and governing documentation.

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From the West Australian:

A new system to regulate the offshore gas and oil industry – a direct response to the 2009 Montara north of the Kimberley – has been approved by the Federal Parliament’s lower house.

Under the changes, the seven state and territory authorities will be replaced by a single Commonwealth body, the National Offshore Petroleum Safety and Environmental Management Authority.

It will regulate all safety issues from exploration to well decommissioning.

In the US, the jurisdictional conflicts (offshore) differ in that they typically involve multiple Federal regulators with overlapping jurisdiction and different priorities. Since most of the necessary streamlining would only involve Federal agencies, one would think that regulatory reform would be achievable, especially after a major blowout that killed eleven. Unfortunately, meaningful US reform appears to be highly unlikely.

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Per information provided by one of our readers (see comment on the original Marianas post), the rig was in transit offshore Ghana, west of Takoradi. This report indicates that “they have got control over the list at the moment.”

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