The investigation of the Gulf of Mexico Macondo well blowout, rig explosion, and oil spill has found significant regulatory and operations gaps that need to be closed, government and industry witnesses told a National Academies of Science committee studying the Apr. 20 event and its causes.
"When the inspector looks at the fit-for-purpose state of the drilling rig, he looks for a certificate from the [US] Coast Guard or flag state," said David Dykes, chief of the field operations safety management office in the US Bureau of Ocean Energy Management, Regulation, and Enforcement's Gulf of Mexico Region.
"There's a misunderstanding of what the certificate means," Dykes said, adding, "Some inspectors have understood that it covered the whole aspect of the vessel, including the drilling package. We have since discovered that it doesn't always include the drilling package, sometimes at the election of the drilling contractor."
Offshore drilling contractors and well operators can have separate safety and environment programs that need to be brought together, observed Erik Milito, the American Petroleum Institute's upstream and industry operations director.
"Companies which operate worldwide may have in place procedures and processes that are not required in the United States," he said. "A lot of these came out of the Piper Alpha platform incident in 1988. Drilling contractors may use a safety case incorporating these ideas, while operators have their own programs which include risk assessment, personnel training, and approaches to changing situations."
'Moving ahead'
"The investigation is still in midstream," said BOE Director Michael R. Bromwich. "There are still two hearings to be held, one of which will occur once the [Macondo well's] blowout preventer is brought up from the sea floor. Much of the raw factual material already is in the public record, and we are, for example, bringing our regulations in line with those of the [US Occupational Safety and Health Administration] as is the case in onshore oil and gas operations. We anticipate that there will be revisions to make our program more hard-hitting."
US Interior Sec. Ken Salazar asked NAS's National Research Council and National Academy of Engineering to examine causes and scientific implications of BP PLC's Macondo well blowout and the explosion and destruction of Transocean Ltd.'s Deepwater Horizon semisubmersible rig, which killed 11 workers. The committee of experts has been meeting since June but did not hold its first Washington hearing until Aug. 12. Proceedings were scheduled to continue the next day.
Bromwich said since he became director of the renamed US Minerals Management Service on June 21, he has noticed a perception that the US Department of the Interior agency relied heavily on the oil and gas industry's standards for its own regulations. "I'm uncomfortable with that, and I'm going to examine alternatives," he said. "Not all the standards are incorporated in toto, but the parts we include are included as is. There is no manipulation."
Other BOE officials explained that the agency's employees have worked hard to keep current with technology as oil and gas activity moved into deeper water. "We use a technical operation and support group that stays on top of leading edge technology and evaluates it to make sure it helps maintain a safe compliance operation," said Dykes. They conceded, however, that while staff members attend API and Society of Petroleum Engineers offshore technical meetings, budgetary constraints have kept MMS inspectors from being as well trained and equipped as industry employees.
Milito said when the industry formed four task forces to address issues raised by the accident and spill, one of the groups eventually recommended that the offshore well operator and its contractors agree on how to manage operations safely. "We have a subcommittee working on what a well construction interfacing document will have to contain," he told the committee.
Initial ideas
Early ideas that have emerged include engaging a casing hanging mechanism so that the first line of casing doesn't move; providing two independent barriers, including one in the annulus; using negative and positive tests to ensure the well casing's integrity; determining how the BOP is engaged during well construction to make sure it closes during displacement of seawater and other fluids; monitoring volumes during displacement; and ensuring shearing ability by lining up the drill string with the rams in the right places, Milito said. Several of these ideas have been adopted by DOI, which put the immediate ones out in its June 8 notice to lessees and plans to put others in interim rules, he said.
"Over 30 organizations are looking at these issues. Their goal is Aug. 25 to look at ways to modify the equipment as it exists today as well as how it looks after a blowout. Lessons from the BOP in the Deepwater Horizon incident will be critical," said Milito. "All the considerations need to be in place for drilling a relief well and for getting vessels and contractors in place for controlling or killing a well. Some companies have had success with subsea stripping and stuffing, which is coiling tube into a well bore to try and shut it down. A coffer dam or containment dome could be an alternative to shutting the well down completely."
John McCarroll, a BOE staff engineer, said the agency's inspectors are judged by whether the wells they monitor operate safely or if they are simply giving waivers that cause problems. "One of the things we try to resolve is consistency, which is one of the biggest problems we have in five different districts with different qualifications," he said. "We work mostly on consistency between the groups and to help people recognize their limitations when they receive a [drilling permit application] APD for a well they don't feel qualified to assess. They may go not only to their manager, but also to a peer who has evaluated similar wells. It's one of the primary benefits of the electronic edge. There is cross-flow between the engineers, as well as up toward management."
Dykes said new regulations require an offshore well's operator to identify personnel with well control responsibilities. The contractor may provide training, but the operator has to evaluate it. "Having said that, most operators and contractors are sticking to the old [International Association of Drilling Contractors] 48-hr training standard, and then stepping it down to lower levels for certain employees," he said.
The two BOE officials said the agency, as MMS, revised its regulations in 2006 so that shallow gas events also were included because independent producers were going into mature fields, drilling deeper, and finding under-pressured or overpressured zones, which had not been encountered previously. "We saw the need to get rid of subjective words such as 'serious' and define the situation more specifically," said Dykes. "OSHA had already invented that wheel somewhat, so we decided to change the incident reporting rules so the operator wasn't unduly burdened."
Changed rule
BOE's new requirement for operators to report crane operation incidents stemmed from reports in the last 10 years showing incidents had increased significantly, and needed to be studied to determine if they were caused by equipment problems, employee errors, transfers from vessel to vessel, or other factors, he continued. "You may have a derrick hooked up with an air hoist that is causing contact with personnel. We changed the rule to require reporting equipment other than cranes," he said.
Other API witnesses said that industry groups also are examining this problem. "Lifting and hoisting is an area which needs to be addressed," said Andy Radford, the trade association's senior policy advisor for offshore issues. "We have been working with companies to develop programs to make sure employees have enough training."
He said two of API's standards and practices specifically applied in the Macondo well's case: specification 16-A, covering BOPs, and 16-D, covering their choke-and-kill systems. "The other key element in well construction would be well cements," Radford said. "API is responsible for 16 standards ranging from laboratory testing of cements, including Recommended Practice 65, a specific application for shallow water well flows which is sited in BOE regulations.
Another key offshore committee is responsible for 17 standards already "and more as the list evolves," including remote operated vehicles and tools which provide a standard interface so ROVs can latch onto equipment and perform subsea functions, he continued. "We also have a drilling and production subcommittee responsible for 13 standards, including RP-53, covering BOP and associated operations onshore and offshore, surface and subsurface; RP-59 on well control, and RP-90, which is a guide to managing pressure in offshore wells," Radford said.
"RP-96 is a new effort we've just kicked off," added Ronald Goodman, API's offshore standards manager. "We've been meeting once a month since June to discuss this document on deepwater well design. We have 25-30 individuals who are participating, representing 10-12 companies including majors and mid-size independents, major contractors, and casing and tubing manufacturers. We have all the relevant parties who are interested in participating in this process, which we hope to have out as a ballot by the end of the year."
The subcommittee is looking at Gulf of Mexico operators' barrier philosophies, risk considerations, and other factors, he said. "We look at this as just a starting point," Goodman emphasized. "Trying to get a standard out in 6 months means this won't be a perfect document. Work will go on to fine tune it and consider issues we're not aware of yet."
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