Sep10:
From: Energy and Climate Change Committee To: www.NEALE.THOMAS.net Cc:
YEO, Tim Sent: Thursday, September 16, 2010 10:08 AMSubject: RE: Energy and
Climate Change Committee has issued a call for written evidence for its
forthcoming short inquiry into UK Deepwater Drilling – implications of
the Gulf of Mexico oil spill ~ RESPONSE
Dear Mr Thomas
Thank you for your email, your evidence will be circulated for the
Members’ attention. Regards,
ECC Committee
Oh dear, my input sent
in good faith expectation that my firsthand expert experience would not be
spurned yet my message was not even acknowledged and now I find that what I
said was central to select committee considerations ~ limed bits below.
Picturing Comm Chair TY for his comments connecting directly with my remarks,
hoping he'll take you to task for dereliction of due diligence.
From: Safety Health Practitioner To: Neale@Thomas.Net Sent: Thursday, September
16, 2010 9:34 AMSubject: SHPlus - Regulator accused of not being tough enough
on employers BP criticised for inadequate training procedures on North Sea
installations More revelations of safety lapses on BP installations - this time
in its UK operations - have emerged just as outgoing chief executive Tony Hayward
was preparing to face a grilling by MPs on the risks of deepwater
drilling. BP criticised for
inadequate training procedures on North Sea installations 15 September 2010 More
revelations of safety lapses on BP installations – this time in its UK
operations – have emerged just as outgoing chief executive Tony Hayward
(pictured) prepares to face a grilling by MPs on the risks of deepwater
drilling.
Following separate Freedom of Information Act requests by the Daily
Telegraph and the Financial Times, both newspapers published reports yesterday
(14 September) on evidence of the oil giant’s lack of attention to basic
safety matters at several of its installations in the North Sea. The Telegraph
obtained a letter that was sent last October to BP executives from the HSE, in
which the regulator concludes – as a result of an investigation into
complaints by workers on the Clair rig off the Shetlands – that “training
of some new personnel to basic safety standards was ineffective”. The letter goes
on to highlight “evidence of a culture among [BP’s] contractor,
Seawell – up to senior levels of management – of working outside of
procedures, permit, or permit conditions”. The Telegraph
also revealed that these allegations were “strongly refuted” by BP;
nevertheless it did report back to the HSE that its processes had been reviewed
and improved by November of last year. Seawell told the paper that the HSE
investigations did not result in any enforcement action being taken against it,
and that it has the highest regard for health and safety. Inadequate
training of personnel was also cited in offshore inspection records obtained by
the Financial Times. Inspectors from the Department of Energy and Climate
Change had found that BP had not complied with rules for regular training of
offshore operatives on how to respond to incidents, or carried out adequate
oil-spill exercises. Again, BP
responded to the DECC to say it had rectified the situation and was now in full
compliance with the rules on oil-spill exercises. The revelations
come just as the Energy and Climate Change Committee is about to question Tony
Hayward as part of its inquiry into deepwater drilling in the UK, in the wake
of the Gulf of Mexico disaster earlier this year. The committee, chaired by
Conservative MP Tim Yeo, has already questioned Paul King, MD of the North Sea
operations of Transocean (the drilling contractor involved in the Deepwater
Horizon explosion).
Mr Yeo told the Telegraph that training of North Sea staff will be a key
area of interest. He said: “There are some extremely important aspects of
training that do need improving.” The head of the HSE’s offshore
division, Steve Walker, added that training is a “pretty central part of
major-hazard control”. In BP’s
own report of its internal investigation into the Deepwater Horizon incident,
personnel competence was one of 25 areas recommended for action if another
Deepwater Horizon is to be prevented. See also Paul
Verrico and Kevin Elliott’s SHP feature on the Deepwater Horizon incident
and what would happen if a similar disaster occurred in the UK.
From Neale Thomas
(FRED.ltd, Aston SciPark, Bham B7 4BB; 01214714149) as author of HSE-OSD Report
OTO98-162( http://www.hse.gov.uk/research/otopdf/1998/Oto98162.pdf )
commissioned for Cullen compliance post Piper Alpha regarding inadequacies in
design and training software for explosive escapes of complex compositions from
HP-HC pipes and tanks including subsea complications. Hereby notified for
manifest ongoing industrial and regulatory failures to embrace its findings
despite endorsement by sector experts, failure even to enforce express
dissemination despite initial rapid release badged urgent immediate attention
as required by Cullen, yet recalled and blocked for five years 1992-7 after a
software vendor threatened legal action for commercial defamation.
Whilst PA was a gas
production platform whereas DH was an oil exploration platform, the report
covered live crude cases where multiphase and thermodynamic essentials are
shared with regard to release scenarios, although mud rheology admittedly adds
complications of bubble behaviour during blowout initiation and evolution ~ an
arena to which I also contributed with regard to a PhD project on empirically
founded fundamentals for important improvements to Schlumberger's simulation
software following fatal accident on N Sea platform Ocean Odyssey, not
dramatically different from DH because water depth had nothing to do with
initiating events despite clamour from campaigners determined to disrupt
everything deemed unnatural!
As closing comment
must mention that all codes convey key components in their calculations by way
of correlations carrying considerable uncertainties being derived from subsets
of simplified circumstances with little confirmation of coupling complexities,
certainly nothing by way of verification to compare with exhaustive protocols
imposed for pharmacological approval yet catastrophic consequences can be
comparable as we know from fatal accidents that continue to occur despite
accumulating awareness! Moreover exactly same reservations apply to so-called
climate change codes, even more so insofar as their calibration correlations
have been increasingly constrained by recent decades of anomalously accelerated
adjustment that cannot be adequately accommodated without forced fudging which
has been directly responsible for panic prognostications for coming decades ~
nutshelled, then, excessive thermal inertia in their cobbled characterisations
is why they undershot changes since seventies and why they're overshooting
future ones. And whilst that's not central to the DH Inquiry, it should have
been a crucial consideration many moons ago in the wider context of the
commitment to a so-called low-C economy (redlined below).
http://www.parliament.uk/business/committees/committees-a-z/commons-select/energy-and-climate-change-committee/news/new-inquiry/
23 July 2010 The Energy
and Climate Change Committee has issued a call for written evidence for its
forthcoming short inquiry into UK Deepwater Drilling – implications of
the Gulf of Mexico oil spill.
On the 20th April an explosion on the Deepwater Horizon drilling rig
–operated by Transocean in the Gulf of Mexico, under contract to BP
– led to the deaths of eleven workers and an oil leak at an unprecedented
depth. The full extent of the environmental impact and the effect on communities
is not yet known. In light of
the incident, DECC conducted a review of the existing safety and environmental
regulatory regimes and found them to be “fit for purpose”, but
announced that annual inspections of drilling rigs were to double and insurance
requirements were to be reviewed. The US has currently suspended all deepwater
drilling until the leak is under control and factors leading to the incident
have been identified, a position also adopted by Norway, while the European
Energy Minister has urged EU national governments to ban any new drilling
temporarily. The Committee
wants to find out about the safety and environmental regulations of oil and gas
operations on the UK continental shelf – especially in the deepwater to
the west of the Shetlands – and the potential positive and negative
impacts of a moratorium on deepwater drilling. Respondents are free to comment
on any issues they consider relevant, although the Committee particularly
welcomes evidence addressing the effectiveness (or otherwise) of: What are the implications of the
Gulf of Mexico oil spill for deepwater drilling in UK? To what extent is the
existing UK safety and environmental regulatory regime fit for purpose? What are the hazards and
risks of deepwater drilling to the west of Shetland? Is deepwater oil and gas
production necessary during the UK’s transition to a low carbon
economy? To what extent
would deepwater oil and gas resources contribute to the UK’s security of
supply? The deadline for the
submission of written evidence is Monday 13 September 2010. NOTES ON SUBMISSION OF WRITTEN
EVIDENCE Written evidence
should be in Word or rich text format-not PDF format-and sent by e-mail to
ecc@parliament.uk. The body of the e-mail must include a contact name,
telephone number and postal address. The e-mail should also make clear who the
submission is from. Hard copy submissions should be sent to: The Clerk, Energy
and Climate Change Committee, 7 Millbank, London, SW1P 3JA. The deadline is
Monday 13 September 2010. As
a guideline submissions should be no longer than 3000 words. However, please
contact the Committee staff if you wish to discuss this matter. Submissions
should be in the format of a self-contained memorandum. Paragraphs should be
numbered for ease of reference, and the document should, if possible, include
an executive summary. Further guidance on the submission of evidence can be
found at www.parliament.uk/parliamentary_committees/witness.cfm. Submissions should be original
work, not previously published or circulated elsewhere. Once submitted, your
submission becomes the property of the Committee and no public use should be
made of it unless you have first obtained permission from the Clerk of the
Committee. Please bear in mind that Committees are not able to investigate
individual cases. The Committee
normally, though not always, chooses to publish the written evidence it
receives, either by printing the evidence, publishing it on the internet or by
making it publicly available through the Parliamentary Archives. If there is
any information you believe to be sensitive you should highlight it and explain
what harm you believe would result from its disclosure; the Committee will take
this into account in deciding whether to publish or further disclose the
evidence. For data
protection purposes, it would be helpful if individuals wishing to submit
written evidence send their contact details in a covering letter. You should be
aware that there may be circumstances in which the House of Commons will be
required to communicate information to third parties on request, in order to
comply with its obligations under the Freedom of Information Act 2000. FURTHER INFORMATION: Committee Membership is as
follows: Mr Tim Yeo MP,
Conservative, South Suffolk Dan Byles MP, Conservative, North Warwickshire
Gemma Doyle MP, Labour/Co-operative, West Dunbartonshire Tom Greatrex MP,
Labour, Rutherglen and Hamilton West Dr Philip Lee MP, Conservative, Bracknell
Albert Owen MP, Labour, Ynys Môn Christopher Pincher MP, Conservative,
Tamworth John Robertson MP, Labour, Glasgow North West Laura Sandys MP,
Conservative, South Thanet Sir Robert Smith MP, Liberal Democrat, West
Aberdeenshire and Kincardine Dr Alan Whitehead MP, Labour, Southampton
Test Media Enquiries: Nick
Davies, Tel: 020 7219 3297, e-mail: daviesnick@parliament.uk Specific Committee Information:
Tel: 020 7219 2569, e-mail: ecc@parliament.uk Watch committees and parliamentary
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Material: Copies of all select committee reports are available from the
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Stationery Office (0845 7023474). Committee reports, press releases, evidence
transcripts, Bills; research papers, a directory of MPs, plus Hansard (from 8am
daily) and much more, can be found on www.parliament.uk
BP enGULFment REPORTING OBSCURES ACTUALITY THAT ACCIDENT AROSE FROM FAILURE TO
ADOPT REPEATED RECOMMENDATIONS AFTER EARLIER EXPLOSIONS ~ IT CERTAINLY WASN'T
DUE TO DEPTH AS CLAIMED BY CAMPAIGNERS
From: Safety Health Practitioner To: Neale@Thomas.Net Sent: Thursday, September
09, 2010 10:27 AMSubject: Rig explosion caused by “complex sequence of
failures by multiple parties”
Rig explosion caused by “complex sequence of failures by multiple
parties” The actions of “multiple companies and work teams”
contributed to the Deepwater Horizon explosion and fire in the Gulf of Mexico
earlier this year, a report released by BP has concluded.The actions of
“multiple companies and work teams” contributed to the Deepwater
Horizon explosion and fire in the Gulf of Mexico earlier this year, a report
released by BP has concluded.
Eleven workers were killed and 17 injured on 20 April when hydrocarbons
escaped from the Macondo well on to the Transocean-owned Deepwater Horizon oil
rig. The fire, which was fuelled by the hydrocarbons, continued for 36 hours,
while oil continued to spew into the Gulf for 87 days, causing major
environmental damage. BP’s
report – based on a four-month investigation led by its head of safety and
operations, Mark Bly, and conducted independently by a team of more than 50
technical and other specialists – found that the incident arose from
“a complex and interlinked series of mechanical failures, human
judgements, engineering design, operational implementation, and team
interfaces”.
The investigation revealed that: • cement barriers at the
bottom of the well failed to contain hydrocarbons within the reservoir,
allowing gas and liquids to flow up the production casing; • a negative pressure test
was accepted despite no verification having been made as to the integrity of
the well; • Transocean
rig crew failed to react quickly enough when faced with the influx of
hydrocarbons into the well; •
upon reaching the rig, the well-flow was routed to a mud-gas separator, which
caused gas to be vented directly on to the rig instead of overboard; • the flow of gas into the
engine rooms through the ventilation system created a potential for ignition;
and • the rig’s
blow-out preventer on the sea bed should have activated automatically to seal
the well, but failed to operate. The report makes
25 recommendations to prevent a recurrence of such an incident, covering the
use of blow-out preventers, well control, well-integrity pressure testing,
emergency systems, cement testing, rig audits, and personnel competence. Among these
suggestions, it proposes the enhancement of Drilling and Completions (D&C)
competency programmes to improve personnel’s operational and leadership
skills; and calls for an advanced and mandatory deepwater well-control training
programme for all BP and drilling contractor staff who are directly involved in
deepwater operations. Recommendations
aimed at improving process-safety management include the establishment of
D&C leading and lagging indicators for well integrity, well control, and
safety-critical equipment; and a requirement on drilling contractors to
implement an auditable integrity-monitoring system in relation to well-control
equipment.
Commenting on the report, BP’s outgoing chief executive, Tony
Hayward, said: “The investigation report provides critical new
information on the causes of this terrible accident. It is evident that a
series of complex events, rather than a single mistake or failure, led to the tragedy.
Multiple parties, including BP, Halliburton [which performed several services
on the rig, including cementing] and Transocean, were involved.” Hayward’s
replacement, Bob Dudley, added: “We are determined to learn the lessons
for the future and we will be undertaking a broad-scale review to further
improve the safety of our operations. We will invest whatever it takes to
achieve that. It will be incumbent on everyone at BP to embrace and implement
the changes necessary to ensure that a tragedy like this can never happen
again.”
The publication of the report comes the day after a committee of MPs
grilled UK oil and gas industry representatives on whether a similar incident
could occur in British waters. The hearing in front of the Energy and Climate
Change Select Committee saw the UK managing director of Transocean, Paul King,
refute accusations that safety representatives had been bullied and intimidated
for raising safety concerns. Mr King
described any incidents of this nature, which are highlighted in an unpublished
report by the HSE, as “isolated” cases. He added: “I would
not let my son work for this company if I didn’t believe it cares deeply
about its people. I actually find it quite offensive that people think we take
rules for granted.” Guidelines
discouraging the use of the ‘Not Required Back’ (NRB) practice
– where an owner of an offshore installation contacts the
operative’s contracting employer to tell it the individual is no longer
required on that installation – without justification were introduced
last year by the industry body Oil & Gas UK. Asked if
Transocean still operates NRB, which it has been claimed sends a strong signal
to workers that it might not be in their best interests to raise safety issues,
Mr King was insistent. He told the MPs: “If we have a problem with
anybody on our rigs who is not performing from a safety perspective or a
competency perspective, we would talk with them offshore before they leave the
rig to advise them what our thoughts are about their work, and, if it is the
case that we find their work unacceptable, why they will not be coming back to
the rig.”
Malcolm Webb, Oil & Gas UK’s chief executive, pointed out that
a survey on workforce engagement, carried out as part of the HSE’s KP3
report into asset integrity, gave “very high assurance from the workforce
that they are free and able to intervene on safety, and without fear of
retribution”. Defending the
UK’s regulatory regime, he said: “We have a regime where safety is
divided from economic regulation, which is not the case in the US. We have the
whole safety-case regime, which obliges the operator and the owners of the
vessels to make sure that they’re operating to a standard that reduces
the risk of the operation to that which is as low as is reasonably practicable.
And we have independent verification of well design and independent
verification of safety-critical equipment.” Following the
publication of the BP report, the group’s communications director, Trisha
O’Reilly, did however pledge that the findings of the Deepwater Horizon
investigation would be studied in detail. She said: “The UK’s
safety-case regime obliges the industry to examine its existing arrangements in
light of incidents around the world and put into action any consequent
improvements that can be made.”
From: Process Engineering To: neale@thomas.net Sent: Thursday, September 09,
2010 1:02 PMSubject: PE Newsletter 81: Attitudes to Wireless survey
results
Comment: BP's Deepwater Horizon report lack depth London – That
BP’s report into the Gulf of Mexico disaster has failed to get to the
bottom of the matter suggests that the company’s managers have at least
learnt some lessons about digging too deep. Very many
process operations involve complex operations and interactions between multiple
parties: for BP to offer this as the underlying reason for the Deepwater
Horizon accident is well short of the mark. In the process
industries, it is the meticulous management of these interactions and level of
adherence to risk assessment and management procedures, and safety standards
such as IEC61508 and IEC61511, that offer the best defence against serious
accidents.
The uncomfortable truth surrounding the incident on the Deepwater
Horizon rig – the clue is in the name – is that there are as yet no
effective rules and regulations for pioneering drilling operations in such
deepsea locations – an issue that BP’s investigators were
apparently less keen to explore.