Expert comment from Bill Campbell (right), retired HSE Group Auditor, Shell International

John

The attachment ( A Can of Worms) is a reaction to the BBC News/Robert Peston article posted on your website. Please publish all or part as you see fit or otherwise file for reference.

Yesterday’s event in context

The explosion yesterday in the Gulf of Mexico again highlights the dangers of having an explosive gas air mixture concurrent with a source of ignition.  It seems a miracle that 13 men apparently blown into the sea survived. Ironically many such accidents happen when facilities are shutdown and vessels are opened up.

A major explosion on Cormorant A in 1989 occurred when gas leaked from the open end of the Western leg pipeline thought to have been purged free of gas.  There were 240 souls on board.  The cellar deck on Cormorant was known to be weak and unable to withstand the explosive overpressure but was protected in this instance by the relief vents on top of the enclosed column opening.  Methane/air explosions contribute to the largest loss of life worldwide due to industrial activity.  This should be no surprise as natural gas, mainly methane is the biggest killer in the industrialised world – for example thousands on miners in the unregulated Chinese coal mining industry have died in recent years.

Deepwater Horizon

Returning to the Gulf of Mexico, the explosion yesterday will again bring focus to that region in the follow up to Deepwater Horizon.  This incident happening in a region of the world which had dominated the blow-out league table.  The historic data (including Shell’s Bay Marchand in 1970) shows in the Gulf of Mexico in the 37 year period 1964 to 2001 that there were 11 blowouts there has been a mean time between blowouts of just 3.4 years and the consequences of these blowouts was often disastrous with 31 associated fatalities and massive environmental pollution.  This represents a quarter of all blowouts worldwide with a third of the associated fatalities. By comparison, with similar levels of drilling activity over the same period, the UK North Sea has had the three blowouts and one fatality, with negligible pollution.

Yet Big Oil, some 85 energy companies including Shell and BP, having forked out $3.5 billion for leases, in its presentation to the US Government to allow it to go into deepwater, stated that blowout are rare events.  Not as rare it seems as they should have been.

Testimony from the inquiry into Deepwater Horizon continues to open up a can of worms.  Why was a modern, technologically advanced, so called fifth generation rig apparently falling apart with defect lists growing by the day and no adequate response to that.  And to answer the Robert Peston question, who was the guilty party that allowed this to happen.

Bill

A Can of Worms

Accountability is inexorably linked to responsibility

Whether it be under the formality of the UK Health and Safety at Work Act or under less formal state or federal law in the US the concept of accountability is clearly set out in statute with precedence set over many years.

In simple terms, it is the person or persons primarily responsible for an activity who will be held accountable in Law for that activity.

So with reference to the Robert Peston article How Guilty is BP published on your web-site today I would argue not guilty because BP did not design, operate or maintain Deepwater Horizon.  That was the sole responsibility of the owner Transocean.

Opening up a Can of Worms

As testimony gathers, page after page, it becomes clearer and clearer that there were so many warnings but so little action ahead of the Disaster such that this disaster was not only foreseeable, it was probably inevitable. This despite the US regulator request to exercise caution.

Transocean, one of the largest drilling contractors in the world

If you visit the web you will read that Transocean were no Mickey Mouse outfit.  They state that they are the world’s largest offshore drilling contractor, providing the most versatile fleet of mobile offshore drilling units to help clients find and develop oil and natural gas reserves. Building on more than 50 years of experience with the highest specification rigs, our 18,000 employees are focused on safety and premier offshore drilling performance.

Deepwater Horizon according to Transocean fleet specifications was a modern, 5th Generation Deepwater exploration rig, technologically advanced and built in South Korea as recently as 2001.  This rig was contracted by BP to drill into their functional asset, the reservoir, but BP had no responsibility whatsoever for the design, construction, operation and maintenance on a day by day basis of the rig.  This belonged solely to Transocean.

Again with reference to the web in their highest level policy statement on responsibilities they say quote Transocean makes safety a fundamental aspect of what we do — the safety of our people and everyone associated with our operations; the protection of the environment; and the operational integrity of our equipment. We firmly believe that we can conduct our operations in an incident-free environment — all the time, everywhere. We intend to achieve that vision unquote.
However in a relatively short space of time this state of the art vessel was apparently falling apart by 2009?

The large defect list was growing every day, maintenance was needed to return equipment to a functional state.  This maintenance was not getting done, obsolescence was apparently a factor in that spare parts were difficult, if not impossible to obtain, and all this in what was said to be a modern facility.

Jostling for position, we see in testimony, Lawyers for BP, Transocean and Haliburton trying to shift blame bur repeatedly it is reinforced that Transocean staff, who operated and owned the rig, had the authority to stop operations at any time.  Their Installation Manager needed no approval from any party.  It was he who was singularly responsible for the health and safety of all the direct employees on the rig, including indirect employees from BP et al.

So what were Transocean responsible for?

From the testimony of survivors it is apparent that high levels of gas were being released on Deepwater Horizon in the months and weeks prior to the fateful day on the 20th May.  All activities were halted on several occasions with gas being emitted from the drilling cuttings in the mud treatment area.  There was no general platform alarm sounded during these events workers were informed of the situation via PA systems.

There appears to be have been a tolerance by Transocean to the risks of all those on board from the repeated presence of flammable atmospheres on the rig despite the warning from the Regulator to exercise caution.

Testimony from various sources confirms that the gas alarms on the rig had been in inhibited mode for a year prior to the incident to prevent false alarms disturbing the crew.

NB:The Washington Post July 23rd indicates from their research that this inhibition of safety critical systems was not unique to Deepwater Horizon.  In case after case they say that rig operators paid fines for allegedly bypassing safety systems that could impede routine operations.

Testimony also describes that systems designed to prevent combustible gases from reaching potential sources of ignition had also been deliberately disabled.  In the event of a major gas leak the rig was equipped to shutdown ventilation inlets to for example the engine rooms.  But this safety feature was also disabled and according to the testimony of witnesses it appears the seat of the explosion was Engine Room No 3.

Hundreds of pages have been written about concerns that back-up supplies to operate the BOP were known to be unserviceable and the BOP itself may have been functionally impaired.

Testimony describes how safety critical computer control systems to monitor and control drilling operations, including mud flow and balance etc, intermittently froze.  This was collectively referred to on the rig as the blue screen of death where for periods of time at least the driller and the mud engineer would be as they say flying blind.

From previous testimony whether damaged by the explosion or otherwise it is a recorded fact that the emergency disconnect that would allow the vessel to move away from the BOP in the minutes following the explosion did not operate when most needed.

Witnesses told federal panels probing the disaster that the gas and fire alarm system was just one of an array of critical systems that had been functioning unreliably in the run up to the blow-out.

Inspections of the rig in the spring, shortly before the disaster found extensive maintenance problems and the rig would need to be in the shipyard for a lot longer than anticipated because the rig was in very bad condition.

This is supported by testimony from a BP attorney.  He provided evidence that an Audit carried out by BP in September 2009 had a litany of findings including the inhibition of the fire and gas alarm system and it listed 390 other general issues that needed addressing.

My observation and opinion on all of this is that the Transocean maintenance regime for Deepwater Horizon appeared to hinge on what we in the business call batch, or campaign maintenance.

In summary, every 5 years at the time of the vessel class inspection it would plan to return to a shipyard for extensive work to rectify failed equipment or return degraded equipment to as designed functionality.  But clearly the operational life of much of the equipment was less than the period between visits to the yards and it was failing leading to a long defect list that grew over time.

Perhaps in reference to the North Sea all the above would be more understandable if the rig was a first generation installation well past its original design life where equipment obsolescence and the ravishes of the North Sea weather had caused corrosion making maintenance costly and difficult.  But Deepwater Horizon declares Transocean was a modern vessel, technologically advanced, the best that was available for the task in hand.

Despite the warning by the US Regulator to exercise caution the reverse of this appears true.  On the rig operated and owned by Transocean shortcuts were taken, danger signals ignored and employee concerns (like many of the safety systems) were overridden.

Summary

The owner and operator of the Deepwater Horizon who publicly declares they were focussed on safety allowed intolerable risk levels to be attained.

When significant gas levels were occurring, rather than bolstering the reactive defences to mitigate against any undesirable event, gas alarms were inhibited and automatic actions to prevent gas from entering areas where ignition sources were present were purposefully overridden.

I have no doubt that the witness testimony will stand audit in criminal proceedings, and this testimony paints a picture of criminal neglect of maintenance on a significant scale including the operation of equipment whilst it was known to be in a degraded condition with its functionality impaired.

That BP may have contributed to this state of affairs may make them partially culpable but at all times on board they were under the management control of Transocean.  Transocean had a duty of care to stop any operations that they considered unsafe.  This duty could not be overridden.  Not by BP, or for that matter any other member of the Deepwater Horizon alliance team.

In the last analysis it was Transocean stated policy that they were singularly responsible to maintain the operational integrity of their rig, to protect the environment and provide an incident free workplace for all the persons employed on board including BP personnel.  That they did not do that is self evident from the resulting Disaster and the immediate reaction to it for which they will be held accountable in due course.

Comment by Tim Bartram on Sep 5th, 2010 at 9:44 am

This website and sisters royaldutchshellgroup.com, shellnazihistory.com, royaldutchshell.website, johndonovan.website, and shellnews.net, are owned by John Donovan. There is also a Wikipedia segment.