WIT.1000.0005 · 9.t Facility Safety Cases 3Le-3fl ... 1920 The operations team will ultimately...

CoMMISSTON OF INQUTRYMONTARA WELL HEAD PLATFORM

UNCONTROLLED HYDROCARBON RELEASE

COMMONWEALTH OF AUSTRALIA

DECLARATION UNDER THE STATUTORY DECLARATIONS ACT 1959

I, Andrew Charles Jacob of care of Level I , I ó2 Colin Street, West Perth, in the State of Western Australia, I

Chief Operating Officer, make the following declaration under the Statutory Declarations Act I 959 (Cth) as

follows:

Table of topics - Andrew Charlcs Jacob

10264499 l.doc

Topíc Paragrophs

Current position 32

2 My role and responsibilities !+

J Qualifications and work experience 45-61

4 Montara Development Project 78 -e_lo

5 Atlas Drilling rl0- r45

6 My involvement in the Montara Project t65-+9n

7 The Well Construction Department 20L-2eg

8 My role in relation to events before 2l August 2009 ÐN

9 PTTEPAA's and Atlas Drilling's Standards and Regulatory Requirementsrelating to the construction and suspension of the Montara Hl ST-l Well

9.t Facility Safety Cases 3Le-3fl

9.2 Key documents to manage the Well - PTTEPAA 368 - 54ó

9.3 Key documents to manage the Hl ST-l Well - Altas Drilling/Seadrill s51- s49

9.4 Environment Plans for the Montara well construction operations s8é0 - se6_t

r0 Steps taken to ensure that people involved in the construction and suspensionof the Montara Hl ST-t Well were aware of and complied with the West AtlasSafety Case, Drilling Environment Plan and the Well ConstructionManagement System

l0.t Training in relation to Safety Case, Drilling Environment plan and WellConstruction Management System prior to the Uncontrolled Release

623- 668

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Topic Pøragrøphs

to.2 Auditing of compliance with Safety Case, Drilling Environment plan and WellConstruction Management System prior to the Uncontrolled Release

649-7&9

n Compliance with the standards and regulatory requirements relating toconstruction and suspension of the Montara H I ST- I Well

788e - eetol

132 The interaction of PTTEPAA & Seadrill Well Control Documents 1002- r0g?

t34 Compliance with Standards - Baniers during the intervention on 20 - 2lAugust 2009

u08 - r r?9

t54 The H I ST- I Well Uncontrolled Release and the evacuation of the ll'est Atlas læ{8- r26g

t65 Failures in communication between PTTEPAA and Atlas Drilling t2+9- t346

t+6 Actions taken by PTTEPAA since the Uncontrolled Release in order toprevent a similar incident

r35Z- 153é

l&7 Stopping the Uncontrolled Release t541- 16ür+

tv.I

Selecting an option 16158

t8L.2

Capping the well t62s9 - t6!+

r 8.3 Subsea option t652- t6l e

t&7.4

Relief Well t126e- tn8p

198 Regulatory approval for the Relief Well tels-?-+99

æ19 Managing the environment and oil spill response 20te -2265

2+9 DEWHA's role as Incident's Environmental and Scientific Coordinator 2214 -2295

22L Environmental Monitoring Plan and Scientific Monitoring Studies 2Dæ-3t6s

2t2 Environmental Monitoring in Indonesia 3+6!"1-32!t

2Q Comment 3254

I I make this declaration in response to the request from the Montara Commission of Inquiry (the

Commission) into the uncontrolled release of oil and gas from the Montara Wellhead Platform in the

Timor Sea to provide evidence in relation to specified areas of interest relevant to the Commission's

Terms of Reference.

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2 I have revised my original statutory declaration dated 8th March 2010 in order to clarifu certain

asPects as having attended the Commission for the first two weeks. it apneared to me that some ofmY comments may be misunderstood and in order to update the Commission on the position with

resDect to matters that were indicated in my orisinal statutory declaration as having been expected to

be comPleted prior to ml¡ sivine evidence. I have not made anv substantive changes to the content ofmy evidence other than where it has come to my attention since swearins my first declaration that an

error had been made in the earlier statutory declaration or as a result of new information coming to

my attention subseguent to swearing my earlier statutory declaration.

Current Position

23 I am the Chief Operating Officer (COO) of PTTEp Australasia.

My role and responsibilities

34 As the COO, I have reporting to me:

(a) Production Operations;

Éel(b) Health Safety and Environment (HSE);

(c) Logistics: and

@

6Ð(d) Well Construction (since September 2009),

and I oversee the fi.¡nctions ofall ofthose.

Qualifications and work experience

45 | have a BSc (Hons) in Civil Engineering from the University of Salford in the United Kingdom.

56 I have been involved in the oil and gas industry in operational, engineering and management roles

for 29 years.

"i

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67 I have been with PTTEP Australasia and its predecessor companies forjust over l0 years. I I

commenced in October 1999 when the company was known as Newfield Exploration. Originally, I

was employed as the Production Manager, then I became the Executive Manager when the company

changed to Coogee Resources and in 2005 my title changed to Chief Operating Officer.

The Montara Development Project

78 PTTEP Australasia (Ashmore Cartier) Pty Ltd (PTTEPAA) is developing the Montara, Skua, ''1 - -

SwifVSwallow Fields in the East Timor Sea. The development of these fields is referred to as the

Montara Development Project and is located about 690 km west of Darwin, Northern Territory, near

the Ashmore Cartier reef.

89 The Montara Development Project involves four production wells including the H l-STl well (Hl I

Well), in the Montara Field, two production wells in the Skua Field and three production wells in the

Swift/Swallow Field.

910 The PTTEPAA Montara Development facility currently includes a wellhead platform (WHP) at the I

Montara Field.

Atlas Drilling

{41 I Atlas Drilling (S) Pte Ltd (Atlas Drilling) was contracted by PTTEPAA for the Montara Drilling '1 - -

campaign, including the construction of the H I Well, on the Montara WHp.

lll2 Atlas Drilling owns the llest Atlas jack-up drilling rig(l{est Atlos), which is a type of Mobile

Offshore Drilling Unit (MODU).

{413 The contract with Atlas Drilling to provide well services including the provision of the West Atlas

commenced on l5 September 2007 and ended on I November 2009. During that period, Attas

Drilling provided services to PTTEPAA in relation to the Montara wells during the periods l8

January 2009 to 20 April 2009 and I 9 August 2009 to 2 I August 2009. At other times during the

contract period Atlas Drilling provided services either to PTTEPAA in relation to its Skua and Swift

wells and exploration wells in other permits or to Vermilion or East Puffin in relation to their wells

under contract novation agreements.

'1314 Atlas Drilling operates the ll/est Triton jack-up drilling rig(|/est Tr¡ton), which is a type of MODU.

{415 Atlas Drilling was contracted by PTTEPAA on 23 August 2009 to provide well services including

the provision of the lVest Triton for the relief well campaign.

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My involvement in the Montara Project

*51ó Prior to the incident, my involvement with the Montara Project was extremely limited.

16l7 Whilst the Montara project is under construction, it is the responsibility of the Montara Project

Manager. Throughout the Montara Project, the Montara Project Manager have reported to the CEOs.

'l-718 We have the operational team involved with the Montara project team to ensure operability of the

Floating Production Storage and Offloading facility (FpSO) and the WHp.

l8l9 The Production Operations Manager, who is head of the operational team, has a dual reporting line

to myself and to the Montara Project Manager for the purpose of his involvement within the Montara

Development.

1920 The operations team will ultimately take on the operation of the Montara FPSO and WHP and report

through the Production Operations Manager to me. Once the Montara Project becomes operational, I

will take over responsibility for it.

The Well Construction Department

2e2l The Well Construction Department reported to the Montara Project Manager prior to the incident. '-l -

This was because the majority of PTTEPAA's drilling work was being undertaken at the Montara

Project.

2122 the expectation of the company was that the Montara Project Manager would manage the drilling

programme as per the Drilling and Completion Programs, Well Operations Management Plans

(\ilOMPs) and Well Construction Management System.

/223 The head of the Well Construction Department is the Well Construction Manager, Craig Duncan

who, prior to the incident, reported to the Montara Project Manager and now reports to me.

*24 I' the then CEO and the then Montara Project Manager, interviewed Craig Duncan and assessed his

suitability for the role based on his CV, the interview, our own experience and reference checking.

Craig Duncan was then appointed to the position of the Well Construction Manager.

?4'25 the Well Construction Manager has then been responsible for engaging the rest of the personnel

for the Well Construction Department. The company requires as a minimum in the Well

Construction Management Standards, that the Drilling Superintendent, Drilling Supervisor, and

Drilling Contractor Personnel above Driller all hold a recognised Supervisory Level Well Control


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Training Certifïcate from the IWCF or Wellcat, and the drillers, assistant drillers and denickman

all hold a Driller Level Certificate. After the incident, our legal counsel audited the personnel and

it was found that they continued to hold these certifications.

2526 Both the Montara Project Department and Well Construction Department work under the Corporate

Safety Management System (SMS).

%27 ln approximately September 2009, after the incident, responsibility for the Well Construction

Department was transferred to me in my role as the COO. This occurred because the response to

the incident fell into my area. I became the Incident Commander and as a result was responsible

for the drilling of the relief well. It was previously agreed that subsequent to the completion of the

Montara project, the Well Construction Department would move over into the Operations

Department. It was decided that having moved responsibility for the relief well component, that we

might as well leave responsibility for the Well Construction Department with me from then on

instead ofhaving its reporting lines go backwards and forwards.

1428 The majority of the Well Construction personnel are contractors rather than employees. At the time

the company established the Montara project it did not have a Well Construction Department and

had a limited drilling campaign in terms of the Montara development work. Rather than the drillers

being direct employees, the company decided to engage them as consultants and re-assess at the

end of the project whether or not we needed a permanent in-house Well Construction Department.

It was not unusual in the industry for a large numberofdrilling personnel to work as consultants on

a contract basis.

*29 The company did employ some graduate engineers and a completions engineer who were part of the

Well Construction Department. It was recognised that there was a need for continuing ongoing well

completions involvement in production operations and that those roles would be best suited as direct

employees.

My role in relation to events before 2l August 2009

?930 For the reasons relating to the PTTEPAA organisation structure set out in the proceeding paragraphs,'-l

I did not have a role in the construction or suspension of the H I ST- I Well. My knowledge of, and

views about, the construction and the suspension of the H I ST- I Well as set out in this declaration

has been acquired since 2 I August 2009 as a result of my role as the Incident Commander and my

involvement in examining events that led up to the incident for the purposes ofregulatory

investigations and the Commission.


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UNCONTROLLED HVDROCARBON RELEASE

PTTEPAA and Atlâs Drilling's Standards and Regulatory Requirements rclating to thc construct¡onand suspension of the Montara Hl ST-l Welt

Facílíty Safety Cases

3l There are two Safetv Cases (and their respective revisions') relevant to the facilities in the Montara +

field area in March 2009:

(a) the Montara Construction and Installation Safety Case (Document Number TM-CR-GEN-

R-090-00004. February 2008. Revision l) as revised by the WHP & Subsea Installation

Hookup & Pre-Commissioning (Document Number TM-CR-CEN-N-t70-00080. Revision

0. June 2008) This Safety Case was applicable to Montara facilities includine the WHP

and was developed by PTTEPAA: and

(b) West Atlas Safety Case as revised by the West Atlas Safety Case Revision for Operations on'Wells in the Vulcan Sub Basin - Territory of Ashmore and Cartier Islands (.Document No:

HSE SCR WA 070002. Rev 4. l3 January 2009) which was developed b)¡ Seadrill/ Atlas

Drilling.

3e32 There are three Safety Cases (and their respective revisions) relevant to the facilities in the Montara

field area on 2l August 2009:

(a) the Montara Construction and Installation Safety Case (Document Number TM-CR-GEN-

R-090-00004, February 2008, Revision l) as revised by the WHP & Subsea Installation

Hookup & Pre-Commissioning (Document Number TM-CR-GEN-N-170-00080, Revision

2, May 2009) and as revised by the Montara Development SIMOPS plan (Document

Number TM-CR-CEN-G-090-0006 July 2009, Revision 3). This Safety Case was

applicable to Montara facilities including the WHP and was developed by PTTEPAA. The

second-mentioned revision covers simultaneous operations (SIMOpS);

(b) West Atlas Safety Case as revised by the West Atlas Safety Case Revision for Operations

on Wells in the Vulcan Sub Basin - Tenitory of Ashmore and Cartier lslands (Document

No: HSE SCR WA 070002, Rev05,@) and the Montara

SIMOPS Addendum - Forming Part of the West Atlas Safety Case for Operations on Wells

in the Vulcan Sub Basin - Tenitory of Ashmore and Cartier Islands (Document No: HSE

SCR WA 070002, Rev 02, 4 August 2009) which was developed by Seadrill/ Atlas Drilling

(collectively the West Atlas Safcty Case Revision or the MODU Safety Case Revision).

The second-mentioned revision covers SIMOPs; and


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the Java constructor safety case as revised by the Montara Project Java constructor

Safety Case Revision (Document No. 12090-HSE-DOC-C-0001 - Rev No. 0, l9 May

2009), developed by Clough. This revision covers SIMOPS.

3{33 Section 4.3.2 of Seadrill's West Atlas Safety Case Revision states that Seadrill's Offshore

Installation Manager (OIM) is responsible for the management of safety on the l(est Atlas.

(c)

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+234 At the time of the incident on 2 I August 2009, the three facilities were operating under their

respective SIMOPS Safety Case revisions which makes the West Atlas OIM the top of the command

and control organisation (and the ultimate permit authority) for any SIMOPS of all facilities at the

field location.

3335 The llest Atlas OIM was the person with ultimate management and control of all activities at the

WHP facility whilst the lYest Atlas is at the location: [paragraph 3.1 of SIMOPS Plan TM-CR-GEN-

G-090-0000ó July 2009 Rev: 31. Any operations undertaken on the WHP whilst the drilling rig is at

the location falls under the ultimate control of the OIM of the llest Atlas. Works that are undertaken

for the purposes of well construction activities are managed under the Permit to Work system that is

part of the SMS of the þlest Atlas. Work that would be undertaken that was not related to drilling

activities would be undertaken under the PTTEPAA SMS Permit to Work system, but those permits

would be countersigned by the OIM of the llest Atlas to ensure that he was aware and had final say

in any activity that was undertaken. PTTEPAA planned to undertake pre-commissioning work at the

WHP that was not related to drilling activities but no such work had commenced as of 2l August

2009.

3436 Atlas Drilling was the operator of the llest Ailas facility and therefore had ultimate control of the

drilling operations-f¡gm-algfely-pgËpcç!¡v9. PTTEPAA was the client and gave direction as to

work that it required to be carried out.

3537 l¡ this regard, any activity that is undertaken by the facility, being the West Atlas, is under the

control of the operator's representative which in this case would have been the OIM.

Key documents to manage the Well - PTTEPAA

3638 The key PTTEPAA documents in managing the construction of the Montara wells including the Hl ''l -

Well were:

the Well Construction Management Framework (WCMF) (ie Well Construction

Management Framework - D4l-502432 Rev 3; 23 June 2009);

(a)

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the Well Construction Standards (WCS) (ie Well Construction Standards - D4l -502433 Rev

2; l3 March 2009);

the Construct, Service or Abandon Well Process standard or manual (ie Construct, Service

or Abandon Well Process Management Standard - D4l-502434 Rev 2; l3 March 2009);

the Basis Of Well Design (BOWD) (ie Montara Development Basis of Well Design -

Montara Hl - TM-CR-CEN-E-150-00008 Rev 0; July 2008);

WOMP (ie Montara Hl Well Operations Management PIan - TM-CR-MON-G-150-00002

Rev 0; 3 November 2008);

the contract between PTTEPAA and Atlas Drilling for Atlas Drilling to provide well

services to PTTEPAA utilising the llest Atlas including for the construction of the H I Well;

the Drilling Program (DP) (ie. Montara GI, H I & H4 (Batch Drilled) Drilling Programme -TM-CR-MON-B-150-00001; Rev:2; 6 January 2009); and

the Drilling and Completion Program (DP lB) (ie Montara Phase I B Drilling and

Completion Program - TM-CR-MON-B-150-00003 Rev: 0; 30 June 2009).

t739 lnlate2007 Angus Knowles at Uzma Consultants was engaged by PTTEPAA to assist in preparing '-lwell design and construction documentation. In consultation with the consultants, the Well

Construction Manager and the Well Construction Team at PTTEPAA generated and prepared three

documents that made up the PTTEPAA Well Construction Management System.

3840 One of those documents was the WCMF. The WCMF is an interface document between the

PTTEPAA management systems, the management process and standards applicable to well

construction. The WCMF links the PTTEPAA corporate system to the well construction

requirements and includes detailed job descriptions for the positions of Well Construction Manager,

Drilling Superintendent, Drilling Superviso¡ Drilling Engineer, Completions Engineer, Well Test

Engineer and Materials and Logistics Supervisor.

3941 Another of those documents was the WCS. The purpose of the WCS is to provide standards for

aspects ofwell design, construction, testing, abandonment and intervention that involve a risk to

safety, quality or integrity. The WCS are applicable to aspects of well design, well construction,

well servicing and well abandonment. The WCS was generated through a series of reviews and

workshops with the Well Construction Team.

(b)

(c)

(d)

(e)

(0

(e)

(h)


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404'2 The WCS allows the Well Construction Manager to approve deviations from the WCS, for instance,

when a situation is not directly covered by the WCS [see section 1.3].

4f43 PTTEPAA's well construction personnel applied the WCS to the process of identiffing, assessing

and managing the risks associated with the drilling, suspension and completion of the Montara

production wells, including when:

(a) formulating and approving the drilling programs;

(b) supervising the implementation of the drilling programs by the MODU facility personnel;

and

(c) managing the implementation of any changes or deviations from those drilling programs.

4244 The third document was the Construct, Service or Abandon Well Process Manual that provides a '-lmore detailed description of the construct, service or abandon well process which is applicable to

PTTEPAA's drilling, completion, testing, abandonment and well intervention activities. It sets out

the various activities involved in the well construction process and details ofthe various component

tasks.

4345 Qne document required as an input in the Well Construction Management System was the BOWD.

4446 the BOWD was required to communicate well requirements/objectives from the PTTEPAA sub

surface group to the well construction team and included information such as the planned surface

location, target locations, formation tops, expected formation pressures, risks to consider based on

offset well data or seismic interpretation and the well evaluation requirements.

4547 the WOMP illustrates how the Well Construction Management System ensures drilling activities in

respect of the wells meet regulatory requirements, specifically that:

(a) the design and implementation of downhole activities is in accordance with an accepted well

operations management plan, and

(b) risks are identified and managed in accordance with sound engineering principles and good

oil field practice.

4el8 PTTEPAA's WOMPs for Montara drilling and completion operations were prepared in accordance 'lwith the 'roadmap' format advocated by the Western Australian regulator at the time of inception ofthe Petroleun (Subnerged Lands) (Managentent of Well Operations) Regilations 2004. That is, the

WOMP summarises the PTTEPAA management system applicable to maintaining the integrity of,

and managing the risks associated with, well operations, by directing the reader to the PTTEPAA

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Well Construction Management System documents and documents such as the Drilling Programs,

which are generated through the application of the well construction management process.

+749 | signed the letters sending the WOMPs to the Northem Territory Department of Regional

Development Primary lndustry Fisheries and Resources (DA), but I did not formally approve the

WOMPs. My role was to interface with the Regulator to ensure that the document was submitted.

The actual content of the document was not something under my authority as that was dealt with by

the Well Construction Department. My role was to make sure that proper internal approval was

honoured in preparing the document before it was submitted to the Regulator.

4850 A drilling program, Montara G l, H l & H4 (Batch Drilled) Drilling program - Document Number:

had been developed forTM-CR-MON-B-150-00001 - Rev: 0, September 2008 (Drilling Program),

the Montara Project and approved by the Well Construction Manager.

4951 The Drilling Program assumed that the WHP Topside would be in place and the wells would be

drilled and completed. The Drilling Program was revised in November 2008 to incorporate the fact

that the WHP Topside would not be in place and the wells would be sequentially drilled down to the

9 5/81 casing shoe and suspended. The Well surface and target locations, formation tops and

directional profile were not changed. The well design was changed to include an MLS that would

allow wells to be suspended below the top of the jacket. The Drilling Program was further revised in

January 2009 (the DP). This last revision was based on the WHP Topside not being in place and the

wells being batch drilled. All wells were to be batch drilled to the 9 5/8: casing shoe and suspended.

5052 The program for drilling and completing the wells at the Montara WHP was subject to change during

the course of the Montara Project. The original plan had been to position the MODU adjacent to a

completed WHP and to then drill and complete the wells. The sequencing of the drilling campaign

was influenced by other aspects ofthe project construction schedule.

5t53 The original plan to drill and complete the wells was unable to be executed as the contractor

installing the WHP ran into difficulties. This resulted in only the jacket component of the WHP

being installed in 2008. In order to utilise MODU time, the original drilling plan was adapted to

enable the wells to be drilled and suspended using a Mud Line Suspension (MLS) system. This

arrangement is not uncommon and is fìt for purpose,

5254 Revision 0 of the Drilling Program assumed that the WHP Topside would be in place and the wells

would be drilled and completed as a batch drilled sequence. This was updated as Revision I (which

includes the MLS, and a change to sequential drilling) once it became known that installation of the

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topsides component of the WHP was unlikely before mid 2009. Revision 2 (the DP) was then issued

for use; it changed the sequentially drilled sequence back to a batch drilling sequence. Batch drilling

involves setting all the conductors, then all the surface casing strings in little batches. This is

normally more efficient as the learnings from each well section are immediately incorporated into the

remaining wells.

5355 The drilling of the horizontal reservoir section of the H I ST- I Well, the running of the sand

exclusion screens and completions was covered by a new version of the DP (the DP lB) that was

issued with "As Built" information after the well had been suspended.

5456 The DP and the DP I B were sent to the DA for approval.

Key documents to manage the Hl ST-l Well - Atlas Drilling/Seadrill

5557 The Atlas Drilling key documents in managing the construction of the Montara wells including the '1Hl ST-l Well were:

West Atlas Safety Case Revision;

the Atlas Drilling SMS and, in particular two components of that SMS being:

(i) the Seadrill Well Control Manual; and

the West Atlas SDI Operations Procedures Manual which incorporates Seadrill's

Cementing Intermediate Casing Procedure.

5658 The Seadrill Well Control Manual sets out how responsibility for controlling the drilling operations ''l -

operated onthe llest Atlas. In section 2.1 it states:

2.I RESPONSIBILITIES2.1.1 Offshore lnstallation Manager (OlM)The OIM has the responsibility of ensuring that all operations onboard the installation arecarried out according to agreed plans and procedures and measures to guard against loss ofprimary well control are implemented at all times. The OIM will rely on the Rigsuperintendenuroolpusher and operator's Representat¡ve(s), as drilling professionals, toguide him in his final decision making.2.1.2 Rig SuperintendenUToolpusherThe Rig SuperintendenVToolpusher is responsible to the OIM for the safe, efficient, and costeffective management of drilling operations onboard the installation. The RigSuperintendent/Toolpusher has the responsibility of planning, directing, and controlling drillingoperations to ensure that they are conducted in as safe a manner as is reasonablypracticable. ln particular, the Rig SuperintendenVToolpusher is responsible for supervisinglhe maintenance of primary well control by the constant monitor¡ng of drilling fluid propertiès,fluid volumes and return flow rates so that imminent or actual loss of primary well control isprevented, or minimised and contained.

(a)

(b)



(ii)

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2.1.4 Driller and Drill CrewThe Driller, as the person in direct control of drilling operations, has the responsibility for thema¡ntenance of primary well control by the constant monitoring of drilling fluid properties, holeconditions, fluid volumes and return flow rates so that imminent or actual loss of primary wellcontrol is prevented, contained or mitigated. He must immediately inform the RigSuperintendenVToolpusher on duty of any concerns he has about the conduct of operat¡ons.He must act on his own ¡n¡tiative, to shut the well in and thus minimise any influx, if hesuspects that primary well control has been compromised for any reason. As the supervisorof the Drill Crew, the Driller must ensure that all members of the crew are competent andexercised in the performance of the well control functions that may be required of them.2.1.5 Operator's Representative (íe the PTTEPAA drillÍng superuisors)The Operator's Representat¡ve has the responsibility of cooperating with the OIM and the RigSuperintendenUToolpusher in planning drilling operations to ensure that they are conductedin as safe a manner as is reasonably practicable.

5759 The West Atlas SDI Operations Procedures Manual contains standards and instructions for aspects '-l - -

ofwell operations carried out at the ll/est Atlas facility.

Environment Plans for the Montara well construction operations

5860 Environment Plans required under the Petroleum (Submerged Lands) (Management ofEnvironntrn\'1

Regulations I 999 (Cth) (now the Olfshore Petroleum and Greenhouse Gas Storage (Environment)

Regulations 2009 (Cth) accepted by the DA for the Montara Project are the:

Montara Development AC/L1 and AC/L8 Production and Exploration Drilling Environment

Plan accepted by the DA on I I January 2008 document number TM-CR-CEN-C-091-00001

(the Drilling Environment Plan); and

Montara Development AC/L7 and AC/L8 Installation and Commissioning Environment

Plan accepted by the DA on 22 May 2008 document number TM-CR-GEN-G-091 -00002

(thc Construction Environment Plan).

5961 The Drilling Environment Plan is the only environmental plan that was applicable to the drilling of '1the Montara wells. The Construction Environment Plan is applicable to facility installation and

commissioning activities, not drilling or well construction activities.

Steps taken to ensure that people involved in the construction and/or suspension ofthe Montara Hl-STI Well were aware of and complied with the West Atlas Safety Case, Drilling Environment Plan,Drilling Programs and Well Construction Management System

Trøíníng ín reløtion to Safety Cøse, Drìllíng Envíronnent Plan, Drillíng Progrøms and llell ConstructíonManagement System prior to the Uncontrolled Releøse

6062 Prior to the commencement of Atlas Drilling's operations for PTTEPAA, PTTEPAA convened a 'l - -

Hazard Identification workshop (HAZID) between PTTEPAA well construction personnel and Atlas

(a)

(b)

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Drilling personnel to consider well hazards and the controls for managing those hazards. Atlas

Drilling then used the output from this workshop to prepare its revision to the West Atlas Safety

Case, in consultation with PTTEPAA . The Ilest Atlas Safety Case revision establishes the system

for managing well hazards during the Montara well construction operations canied out at and from

the West Atlas. That system is Seadrill's llesr Ailas Safety Management System as interfaced with

PTTEPAA's Well Construction Management System.

6t63 Chris Wilson, PTTEPAA's Drilling Superintendent, developed a Drilling Supervisor Induction I

program that consisted of at/z day presentation and workshop as well as a hard copy manual. A key

objective of this induction was to ensure that the drilling supervisors were cognisant of the

requirements of the Drilling Programs, WOMPs and PTTEPAA WCS. The initial Drilling

Supervisor lnductions were held on 27 February 2008.

6264 PTTEPAA coordinated with Atlas Drilling to hold a Pre-Spud meeting prior to the commencement I

of Atlas Drilling's operations for PTTEPAA. A key objective of the Pre-Spud meeting was to ensure

that the PTTEPAA well construction personnel, the Atlas Drilling personnel and the personnel ofPTTEPAA's other well services contractors were familiarised with the requirements of the West

Atlas Safety Case Revision (including its interface with the PTTEPAA rrtry'ell Construction

Management System), and the Drilling Environment Plan.

6365 When the SIMOPs Safety Case revisions were developed aHAZID was conducted on the West Atlas I

on l2 June 2009. This further familiarised the PTTEPAA well construction personnel, the Atlas

drilling personnel and the personnel of PTTEPAA's other well services contractors with the

requirements of the West Atlas Safety Case Revision (including its interface with the PTTEPAA

Well Construction Management System).

6466 Based on the experience ofthe Drilling Supervisors and their attendance at the induction, which I

would have familiarised them with the requirements of the West Atlas Safety Case Revision and its

interface with the WCM$, I would not have expected any further training on this topic to be I

necessary and consider this level oftraining to be entirely appropriate.

6567 An additional step in the training process that is currently being considered by PTTEPAA is to add a I

test at the end of the induction training session. PTTEPAA is unable to comment on whether having

such a test would have identified any failings in the understanding ofany person involved in the

incident, but given their level ofexperience does not anticipate that it would have.

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WIT.1000.0005.0014

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6é68 Another potential improvement being considered by PTTEPAA is to either include the MODU I

facility operator's supervisory personnel in the induction training or confìrm that the MODU facility

operator has carried out similar training.

Audìtìng of complìance with Safety Cøse, Dríllittg Envíronnent Plan, Drillíng Programs and llellConstructíon Managenent Systen príor to the Ancontrolled Release

6169 PTÍEPAA canied out the following audits in relation to compliance with the relevant standards, '1plans and regulatory requirements relating to the Montara well construction operations:

(a) May 2008, Labrador Petro-Management's audit of compliance of Atlas Drilling with west

Atlas Safety Case / Safety Management System;

(b) 26 -27 March 2009, PTTEPAA's audit of compliance of PTTEPAA, Atlas Drilling and

other drilling services contractors of PTTEPAA with Drilling Environment Plan; and

ÉÐ(c) I April 2008, l5 April 2008,20 April 2008, 30 April 2008,24 June 2008, l7 October 2003, '1-:27 Jamary 2009, I February2009,25 March 2009,30 March 2009,9 April2009, t4 April

2009, l8April2009, l6July2009,29July2009,30July2009andAugust2009auditsin

relation to compliance with Drilling Programs and Well Construction Management System.

6870 No issues ofany relevance to the Uncontrolled Release were identifìed during these audits.

6971 The Well Construction Manager was responsible for monitoring compliance with the Drilling

Programs, WOMPs and Well Construction Management System by the Drilling Superintendent, the

Drilling Supervisors and Atlas Drilling.

1472 The Montara Project Manager was responsible for auditing that the Well Construction Manager was

doing what he was reporting he was doing. I understand in this regard that an audit conducted by a

drilling engineer from Thailand had been planned for September 2009. This audit did not take place

due to the incident.

4173 Eleanor Stoney, the PTTEPAA HSE Co-ordinator conducted an audit of the llest Atlas on26 and27

March 2009 to check compliance with the Drilling Environment Plan (Environmental Audit).

1274 As part of the Environmental Audit, Ms Stoney identified only a few minor issues with the West

Atlas MODU. The main issue identified was that the waste management of oily discharges from the

MODU equipment could be improved.


Formatted: Headino 3


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coMMISSTON OF TNQUIRYMONTARA WELL HEAD PLATFORM


4475 the Environmental Audit Report was sent to Chris Wilson, the Drilling Superintendent who then

submitted it to Seadrill requesting that the identified actions be addressed.

7476 lf there is nothing being reported from ofßhore to indicate any potential problems:

in a non-phased drilling campaign of less than a year I would expect there to be scheduled

one audit of compliance with the MODU Safety Case; and

in a phased campaign or a campaign lasting for more than one year, I would have expected

that an audit of the compliance with the MODU safety case would be scheduled for each

part of the campaign.

I consider this to be reasonable bearing in mind that in addition to PTTEPAA audits, the National

Offshore Petroleum Safety Authority (NOPSA)'s practice would be to inspect the facility, and the

MODU facility operator should have their own audit program for compliance.

1577 The PTTEPAA system relied upon the personnel involved in well construction following the 'lrequirements of the Well Construction Management System and, in particular, the Drilling Program,

and any change control instructions, the Forward Plans and any supplemental Forward Plans. It also

relied on the expertise of the MODU facility operator's supervisory personnel and the PTTEPAA

drilling supervisors to monitor and check that the MODU facility personnel complied with the

Drilling Programs, any change control instructions, the Forward Plans and any supplemental

Forward Plans.

7678 The audit planned e$e*

Management System was be:ng eemplied with.

77 The ITTEP¿!Â system relied uper the persennel invelve*i++vell eenstruetier fellewing+he

Þrilling Supervisers te meniter and eheek that theMeÞU faeility -ersennel eemp'ied witlÈth€

Ferwar*Plan+

1&79 I note that an audit of the West Atlas Safety Case compliance was conducted in May 2008 and the

Project Manager had planned a further audit to take place in September 2009. The audit planned for

(a)

(b)


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CoMMISSION OF INQUTRYMONTARA WELL HEAD PLATFORM


September 2009 was designed to check that the Well Construction Management System was being

complied with.

Compliance with the standards and regulatory requirements relating to the construction and/orsuspension of the Montara Hl Well

Ð80 As has been demonstrated in PfiEPAA's submissions to the Commission, it had sought to have in '1 -

place the required regulatory approvals prior to undertaking the well construction operations.

Environntenlal regulatory reqtirentent

808 I Two potential areas of commencing work without required approvals being in place have been raised'-l -

in the submissions from the DA and the Commonwealth Department of Environment, Water,

Heritage and the Arts (DEWHA). The following is the background to those alleged breaches:

(a) the Drilling Environment Plan covered all ÃC/L1 and AC/L8 Montara Development drilling

and completion operations (including the Montara Hl Well), plus a couple of exploration

wells drilled in AC/L8. PTTEPAA submitted it on l8/10/2007 requesting its acceptance in

respect ofa// tlrose operations. The DA instead decided to notiff acceptance ofthe

Environment Plan on a well-by-well basis at the same time it issued a drilling approval for a

well. On I l/01/2008 the DA accepted it in respect of the Skua development wells in

AC/L8. The DA then omitted to notify acceptance of the Environment Plan at the time ofeach subsequent Montara Development well drilling approvals issued during the 2008-2009

period. PTTEPAA pointed this out to the DA which led the DA to issue its 9/4/09

confrrntation letter. By sending ìts 9/4109 letter the DA confirmed that its l8/l l/08 letter

approving the drilling of the Montara H I Well was also acceptance of the environment plan

for Montara H I Well operations.

the oil spill contingency plan was submitted to DEWHA before the drilling commenced in

January 2009 and the possible breach concerns the timing of DEWHA's written approval

which was not issued until June 2009.

DEWHA is the regulator for the Environnental Protection and Biodiversily Conservation

Act 1999 (EPBC Act). PTTEPAA has an environmental approval under the EpBC Act for

the Montara development. The approval was granted by DEWHA in 2003, It is a condition

of that approval that DEWHA approves PTTEPAA's oil spill contingency plan "before

operations commenced". In its submission DEWHA acknowledges that there is an argument

that the wording of the condition means that DEWHA's approval of the oil spill contingency



(b)

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coMMrssroN oF TNQU|RYMONTARA WELL HEAD PLATFORM


plan is not required until the commencementof protluction operations from the Montara

wells. The drilling of the Montara wells commenced in January 2009.

PTTEPAA submitted its oil spill contingency plan to DEWHA on 6 June 2008. On l0 July

2008, DEWHA advised PTTEPAA that it was satisfied with the oil spill contingency plan

but that it required PTTEPAA to revise the plan to include more speciñc details of the oil

spill equipment described in the plan. PTTEPAA submitted the revised plan to DEWHA on

14 January 2009. ln May 2009, DEWHA advised that it did not receive that submission

and a further copy was provided. DEWHA then proceeded to issue the formal written

approval of the oil spill contingency plan on 5 June 2009. A read receipt received by

PTTEPAA tends to indicate that DEWHA probably received the oil spill contingency plan

on l5 January 2009.

PTTEPAA's oil spill contingency plan also requires approval by the petroleum regulator

under the Petroleum (Submerged Lands) (Management of Environment) Regulations 1999

(Environment Regulations). The petroleum regulator, the DA (as delegate of the

Commonwealth Minister for Resources and Energy) approved the oil spill contingency plan

when it accepted PTTEPAA's Drilling Environment Plan in January 2008.

Nothing of consequence to the actual incident turns on the fact that DEWHA's written

approval ofthe oil spill contingency plan was not issued until June 2009, several months

after the commencement of Montara development drilling. The oil spill contingency plan

was in existence in the form acceptable to DEWHA when the drilling commenced, ready for

implementation as and when required. The oil spill contingency plan was then expeditiously

and effectively implemented by PTTEPAA as soon as the incident occuned. The response

to the oil spill (i.e. containment and clean-up operations) proceeded in accordance with the

oil spill contingency plan because PTTEPAA initiated efforts to mobilise oil spill

equipment, notified the regulators and in consultation with the petroleum regulator handed

over combat control of the oil spill response to the Australian Marine Safety Authority

(AMSA) in the manner contemplated by the oil spill contingency plan and Australia's

National Plan for the Combat of Pollution by Oil and Other Noxious Substances.

DEWHA's submissions highlight a possible technical breach of the EPBC Act approval

condition; ifthere is a breach then it is a technical breach which results from administrative

oversights and delays within DEWHA and has nothing to do with the integrity, effectiveness

or acceptability of the oil spill contingency plan to DEWHA.

l8

WIT.1000.0005.0018



Ile I I opera tion s re gu la to ry req u i ren en ts

&t82 The DA approved the suspension of the H I ST- I Well on the basis that it contained two pressure '1 - -

containing caps in accordance with the PTTEPAA's stage I application to suspend dated 6 March

2009 and PTTEPAA's stage 2 application to suspend submitted on l2 March 2009.

8¿83 At the time that PTTEPAA sent the as-built diagram of the Hl ST-l Well to the DA, it provided it in

good faith and in the belief that it was accurate and that there were the following baniers in place for

theHl ST-l Well:

(a) a cement shoe;

(b) two pressure containing conosion caps CBÇÇÇI(9-51[-qn!_l] l{8:l _

(c) hydrostatic head of fluid (not relied uBon as beine a verified barrier. it was just noted as

being present); and

(d) cement in the annulus.

8384 Since the Uncontrolled Release it has been identified that the suspension diagram provided to the 'lDA did not accurately reflect the state of the H I ST-l Well at the time of the suspension. When

work commenced to tie back the H I ST- I Well in August 2009, it was discovered that the l3 3/8"

pressure containing cap had not actually been installed.

8485 Our investigation into the Uncontrolled Release has also identified that events occurred during the

process ofcementing the shoe in the 9 5/8" casing, which potentially indicated that the cementing of

the shoe may not have provided an adequate well barrier and that the 9 5/8" o

was not pressure tested at the time it was installed.

&586 It has now become apparent that a report from Halliburton, dated 8 March 2009, had been received

at least on the rig prior to the llest Atlas departing, which may have enabled the potential issue with

the cementing of the shoe to be identifÌed. This report was not provided to onshore well

construction personnel and was not considered by the Well Construction Manager and Drilling

Superintendent prior to 2l August 2009. As it had been reported to the Well Construction Manager

on 7 and 8 March 2009 that:

c "Checked cenrcnt integrity - OK."

o " Relest Float Good. ",

FoÍmatted: Bullets andNumbering

Formatted: Font: Bold


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CoMMISSION OF TNQUTRYMONTARA WELL HEAD PLATFORM


he concluded the cemented shoe had been repeat pressure tested after the suspected float valve

failure and therefore the resulting suspension diagram was prepared, included in the DP I B and sent

to the DA in the format in which it was sent indicating that the cement shoet was a competent barrier.

87 The information which would have enabled the potential issue with the cementine of the shoe to be 'identified was also contained in the Daill¡ Drilling Report (DDR). but was not comprehended at the

time by any of the oersonnel who received the DDR.

Complíance wíth standards - the suspensìon of the HI ST-I llell

8688 As explained above, the drilling and completion of the Hl ST-l Well was originally planned to occur''l

in a single phase operation and that plan was changed when the West Atlas operations were divided

in to two phases: an initial phase ofdrilling and suspension and a later phase ofhorizontal drilling

and completion,

8789 When you suspend a well you are supposed to have sufficient baniers in place to prevent a potential I

blow out of the well.

8890 The WCS do not specifically deal with the phased drilling and completion scenario applicable to the

H I ST-l Well nor with batch drilling. Neither section 5 in the WCS entitled Barriers, nor section l4

entitled Abandonment or Long Term Suspension were written to apply a standard to the particular

circumstances of the suspension of the Hl ST-l Well.

!![Section 5 Baniers does not specifìcally deal with the temporary suspension of a well that occurs

during a batch drilling campaign as the MODU moves between well locations because the intent

when the WCS were drafted was that a short term suspension was when a well was being drilled and

there was an intenuption of the MODU's operations due to heavy weather or some similar event.

9e92 Section l4 Abandonment or Long Term Suspension did not apply to the temporary suspension

during the 5 month period between the initial and later phases of the H I ST- I Well drilling and

completion operations. This is because the intent when the WCS were drafted was that a long term

suspension was when sub-sea wells drilled from a semi-submersible MODU as possible future

producers were suspended with a decision not having been made whether they would be converted to

producing wells or abandoned and they were to be left in a position such that they could be

abandoned without the reintervention of a rig. This is not the situation with the H I ST-l Well

Drilling Program as it was known that the West Atlas was returning to the location to work on the

well further for the purpose of completing it as a production well.


Formâtted: Bullets and

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WIT.1000.0005.0020

CoMMISSION OF TNQUIRYMONTARA WELL HEAD PLATFORM


9t93 The WCS are not intended to be a prescriptive set of rules dealing with every conceivable operation

or activity that may be encountered in the course of a well operation. The WCS exist within a Well

Construction Management System that includes a process that requires ongoing risk assessment in

developing and implementing programs for well operations. Hence the WCS allows the Well

Construction Manager to approve deviations from the WCS such as when a situation is not directly

covered by the WCS. Part 1.3 of the WCS allows for the Well Construction Manager to risk assess

any deviation in accordance with the Well Construction Risk Management Process and approve that

deviation. This is what occurred in the case of the Hl-STl Well.

9?94 The proposed barriers for suspension of the H I -ST I Well differed from the suspension of the H2, H3

and H4 wells which were to have a cemented shoe casing and a cement plug in them, The Change

Control Document approved by the Well Construction Manager under the Well Construction Process

provided for a change from the cement plug that was in the original drilling program, to the

installation ofa 9 5/81 pressure containing suspension cap. The Change Control document also

provided that the l3 3/81 pressure containing cap be installed. This change was on the basis that it

would be an improvement in the well integrity during suspension. There was concern over

cementing, in particular putting an internal cement plug into an area ofcasing that is un-cemented

externally, since when re-entering the well there is a risk that you may back-out the casing and cause

a well integrity problem. This is another reason why it was felt that this was a better method ofsuspending the Hl ST-l well.

9395 The risk assessment carried out in relation to the determination ofthe barriers for suspending the Hl

ST-l well resulted in a situation where, ifthe well had actually been suspended as designed and as

senior PTTEPAA well construction personnel in Perth understood them to be reported the well

would have been compliant with the WCS;

¡ The casing was pressure tested and subsequently inflow tested in accordance with Section 8.1 of

the Seadrill Well Control Manual and Section 5 of the WCS. PTTEPAA well construction

personnel in Perth understood this was complied with.

o Section 5 of the WCS describes cement validation methods. PTTEPAA well construction

oersonnel in Perth understood Tlhis was complied with.

o The PCCC's, whilst not specifically listed, I understand comply with the banier defìnitions and

are comparable to a hanger packer / tubing hanger referred to in section 14 of the WCS. The

WCS define barriers by their functional characteristics - the references to tubing hanger and

Formatted3 L¡ne spacing: 1.5lines

2l

WIT.1000.0005.0021



RTTS packer are essentially interchangeable and are synonyms for PCCCs in the context ofa

choice as a banier. Each of a RTTS packer, tubing hanger and PCCC are designed to allow the

pressure beneath them to be checked and released while they are in place. Two such PCCC

devices were planned to be installed. PTTEPAA well construction personnel in Perth

understood two PCCCs had been installed.

o The displacement fluid used in conjunction with the cementing in the cased hole was

overbalanced to formation in compliance with the WCS although not verifìed. +heeeme*

9496 Qn 6 March 2009, PTTEPAA had submitted an application to the DA for approval to suspend the H I 'Well with these barriers. This application was for stage one of the suspension. That included one

pressure containing cap.

9597 This plan was approved on a preliminary basis on 6 March 2009 and final approval was given on I I

March 2009.

9698 A second stage application to suspend was submitted on l2 March 2009 which included two pressure

containing caps.

9799 This plan was approved on 13 March 2009.

98100 That approved application required the following barriers to be in place in the well ât the time of

suspension: the cemented shoe casing and annulus; fluid rvith hydrestatie head pressure greater than

*e+ma+ien+ressure-and two pressure containing caps. There was also a hydrostatic head of fluid

in place which was an unverified barrier.

99101 The barriers which PT'TEPAA understood to be in place at the time of suspension were the cement

plug, fluid with hydrostatic head pressure greater than the formation pressurelþnve¡ified) and

according to the documentation, two pressure containing caps. However, on 20 August 2009 it was

discovered that there was actually only one pressure containing cap in place.

Interaction of the PTTEPAA and Seadrill rvell control documents

*00102 Inrelationtothetwoprimaryorrootcausesoftheincident-theapparentfailureofthecementshoe *

and the failure of the hydrostatic fluid the¡q stop the flow in the H I ST- I Well - the PTTEPAA and

Seadrill procedures relevantly interact in the following manner.

Formattedt Eullets and

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WIT.1000.0005.0022

coMMtssloN oF TNQUIRYMONTARA WELL HEAD PLATFORM


-l4ll03 Section 6.6 of the WCS states relevantly that:

Primarywell control shall becarriedoutinaccordancewiththe RegisteredOperatorWell ControlManual. Any additional procedures and deviation shall be specified in the Vessel SafeÇ CaseRevision.Flow checks shall be performed in the following circumstances using the Registered Operator'sprocedures unless otherwise specified in the Safety Case Revision. ln addition to the requirements ofthe Vessel Safety Case the following must be flow checked:. Any indications of downhole gains or losses. lmmediately known hydrocarbon bearing objective is penetratedo Prior to POH, prior to pumping a slug, at the last casing shoe, just pr¡or to pulling the BHA

and if trip displacement is ¡ncorrecto Dr¡ll¡ng breaks in the reservoir section exceeding 1.5m (Sft) in lengtho Prior to dropping a survey or dropping a core ball

{S2104 That is, the Seadrill Well Control Manual was applicable to the cementing procedure for the Hl ST-l'-l

Well and, in relation to situations of failures of float valves and waiting on cement, that manual has a

flow chart on page I 07 requiring that the rig wait on cement until the cement reaches a certain

strength or 8 hours have elapsed.

*03105 The Seadrill Cementing Intermediate Casing Procedure contemplates float failure, but does not

mention pumping back into the well or the need to re test casing.

{ell06 Pages 103 - 109 of the Seadrill Well Control Manual set out the intended involvement of Seadrill

personnel in the cementing process. I note that this differs from that set out in paragraph l7 ofthe

statutory declaration of Mr David Couldin, dated 23 February 201 0.

{e5107 The requirements of these Seadrill procedures were applicable to the cementing in the circumstances

encountered with the H I ST- I Well and these procedures were followed with regard to waiting on

cement.

.l€6108 The WCS deal with completion fluids in exposed formations/open holes but do not expressly deal

with the characteristics of any displacement fluids used in cementing in cased holes (the

circumstance of the suspension of the H I ST- l Well) other than to refer to fluids being overbalanced

to formation. Section 5 of the WCS refers to "fluids" being overbalanced to formation.

{07109 Section 2.3. I of the Seadrill Well Control Manual states, without defining "drilling fluids", that "all

drilling fluids be of sufficient density to contain formation pressure". This requires all "drilling

fluids" to be overbalanced to formation pressuro.

Compliance with standards - Barriers during the intervcntion on20-21August 2009


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CoMMISSION OF TNQUIRYMONTARA lryELL HEAD PLATFORM


I

casingon the Hl ST-l Well were set out in paragraph 5.17 ofthe DP lB.

5.6 Tie-back 508mm (20") casing - Montara H1 ST-i

1) Remove the trash cap from the well using a tugger

o Check the threads on the 508mm (20") conductor

2') Rig-up to run 508mm (20") conductor

3) Make,up the landing string (Figure 28) and run in the hole

4) Carefully make-up the Leopard connection on the MLS and engage the anti-rotat¡ontabs

5) Rough cut the casing above the mezzanine deck and recover the landing string.

6) Skid to well slot 13-WD-009 (Montara Gl)

7l Offline cut the 508mm (20") casing at 4.661m above the platform main deck (Figure28) with a cold cutter and recover the cut-off.

8) Offline install the Braden Head and orient per Appendix 5 (Due North or parallel to theaft of the rig pointing starboard). Record wellhead serial number on the DDR

9) Offline install Aker debris cover P/N 585776-P5

5.16 Tie-back 3¿Omm (13 3/8") casing - Montara Hl ST-1

10) Run in the hole with the corrosion cap runn¡ng tool.

11) Make up the TDS before engaging the running tool onto the corrosion cap (this willallow for any pressure below the corrosion cap to be observed on the standpipe andthen bled-off through the choke manifold)

121 Engage the corrosion cap and check for any pressure below the corrosion cap. Noteany pressure on the IADC and the DDR. Bleed-off any pressure via the chokemanifold.

13) Remove the corrosion cap by rotating clockwise for 8-9 turns with a torque oi 2034 -4745Nm (1 500-3500 ftlbs) and recover same to surface.

'14') Rig-up to run 340mm (13 3/8") casing

15) Make-up the MLS tieback tool to the landing string.

. Confirm all seals are intact

o Lubricate seals with Jet Lube AP-S or equivalent. DO NOT use pipe dope orlubricant containing metal particles.

16) Run in the hole with the MLS tieback tool and spaceout to ensure that no casingcouplings are in the vicinity of the surface wellhead

17) Lower the tieback tool onto the MLS and apply 0.9 to 2.2MT weight down and mark thepipe at the rotary table


24

WIT.1000.0005.0024

coMMrssroN oF INQUTRYMONTARA \ryELL HEAD PLATFORM


18) Rotate the string to the r¡ght 9.5 to 10.5 turns maintaining constant weight down on thestring w¡th a torque of 3390 to 5424Nm (2500 - 4000 ftlbs). The string should havemoved 89mm down.

19) Hydrotest the tieback by filling the casing with water.

20) lnstall the casing slips (Aker P/N WB5859-133E4-2W). The slips are fully installedwhen the distance from the top of the slips to the top of the starter head is 216mm(8.52)

21) lnstall the cold cutter and cut the 340mm (,l3 3/8) casing 127mm (5') [+/- 3mm (0.12")]above the top surface of the starter head ensuring the outer edge has a bevel per AkerProcedures 6'1 -PH2059-70 (M 1 76).

22) Once the casing is cut recover the landing string to surface.

23) Change from casing elevators to drillpipe elevators and make-up the pack-off runningtool complete with the pack-off (P/N W85860-133A-2Q).

24) Whilst rigging-up to run the pack-off clean out the cavity above the slips in the starterhead in preparation to run the pack-off.

25) lnstall the pack-offperAker Procedures 61-PH2059-70 (M176).

26) Pressure test the pack-off to 1 0.9MPa (1 58a psi) - 70% of the collapse pressure of thecasing for 10 minutes

27) Once successfully pressure tested engage the pack-off

28) Recover the pack-off running tool

29) Change out the 340mm (13 3/8") pack-off running tool for the 244mm (9 5/8) pack-offrunning tool.

5.17 Tie-back 244lmm (9 5/8") casing - Montara H1 ST-1

30) Run in the hole with the corrosion cap running tool.

31) Make up the TDS before engaging the running tool onto the corrosion cap (this willallow for any pressure below the corrosion cap to be observed on the standpipe andthen bled-off through the choke manifold)

32') Engage the corrosion cap and check for any pressure below the corros¡on cap. Noteany pressure on the IADC and the DDR. Bleed-off any pressure via the chokemanifold.

33) Remove the corrosion cap by rotating clockwise for 8-9 turns with a torque ol 2034 -4745Nm (1500-3500 ftlbs) and recover same to surface.

34) Rig-up to ¡un 244mm (9 5/8") casing

35) Make-up the MLS tieback tool to the landing string.

. Confirm all seals are intact

o Lubricate seals with Jet Lube AP-S or equivalent. DO NOT use pipe dope orlubricant containing metal part¡cles.

25

WIT.1000.0005.0025



36) Run in the hole with the MLS tieback tool and space-out to ensure that no casingcouplings are in the vicinity of the surface wellhead

r lnstall a 340mm x 244mm (13 3/8' x 9 5/8') casing centalizer below the surfacewellhead as the 244mm casing will be cut without the casing slips in place.

37) Lower the tieback tool onto the MLS and apply 0.9 lo 2.2MT weight down and mark thepipe at the rotary table

38) Rotate the string to the r¡ght 9.5 to 10.5 turns maintain¡ng constant weight down on thestring with a torque of 3390 to 5424Nm (2500 - 4000 ftlbs). The string should havemoved 89mm down.

39) Hydrotest the tieback by filling the casing with water.

40) lnstall a water head bushing on the casing complete with a side entry sub and a TlW.

41, Pressure test the casing to 27.5MPa (4000psi) for 20 minutes to check the integrity ofthe MLS connection.

NOTE: This w¡ll pressure test the entire 244mm (9 5/8") casing string.

42) Nippledown from the casing pressure test

43) lnstall the cold cutter and cut the 244mm (9 5/8') casing 509mm (20.04) [+/- 3mm(0.12"[ above the top surface of the starter head ensuring the outer edge has a bevelper Aker Procedures 61-PH2059-70 (M176).

44) Recover the landing string

45) Change from casing elevators to drillpipe elevators (whilst installing the wellhead)

46) lnstall the unitized Aker Wellhead per the Aker procedure 61-PH2059-70 (M176).Orient the wellhead per the wellhead orientation procedure (Appendix 5)

471 Pressure test the neck seals against the 340mm (f 3 3/8) casing to l0.9MPa (1584 psi)

- 70% of the collapse pressure of the casing for 10 minutes.

48) Pressure test the cavity between the starter head and the unitized wellhead to 10.9MPa(1584 psi) - 70% of the collapse pressure of the casing for 5 minutes.

49) lnstall the 244mm (9 5/8") slip landing guide (Figure 30)

. The slip landing guide will consist of a cut-off joint ol 244mm (9 5/8) casing with3 guides welded to the inside base. The guide will be lowered through theunitized wellhead and mate-up with the already cut 244mm (9 5/8) casing. Theslip landing guide will allow the slips to be wrapped around the casing andlowered into the wellhead without snagging-up on the already cut cas¡ng.

50) lnstall the casing slips (Aker P/N W85716-0954-3W). The slips are fully installed whenthe distance from the top of the slips to the top of the unitized wellhead is 703mm(27.66')

Once the slips are installed remove the slip landing guide.

Make-up the pack-off running tool to drillpipe (a minimum of 3T weight is needed to setthe pack-off)

5r)

521

26

WIT.1000.0005.0026



53) lnstall the pack-off per Aker Procedures 61-PH2059-70 (M1 76).

54) Pressure test the pack-off to 22.96MPa (3330 psi) l70o/o oÍ the collapse rating of thecasingl for 10 minutes

55) Once successfully pressure tested engage the pack-off

56) Take 4.5T overpull to confìrm that the pack-off is engaged.

57') Recover the pack-off running tool

58) Skid to slot 13-WD-001 (Montara H4)

59) OFFLINE: lnstall the tree Jig (Figure 31) to allow construct¡on to take measurementsfor the flow lines. Once measurements have been taken nipple down the jig

60) OFFLINE: Remove one manual 52mm (2 1/16") side outlet valve and replace withtwo hydraulic actuated 52mm (2 1/'t6") side outlet valves for the 244mm (9 5/8")annulus gas injection manifold tie in. Confirm with Production/Construction crew oncorrect side of unitized wellhead for the Gas lnjection manifold tie in as well ashydraulic actuator orientation for hydraulic control line tie in.

61) OFFLINE: lnstall the 4.5m high pressure riser using a double drive lock adaptor to theunitized wellhead (Figure 32).

62) OFFLINE: lnstall the drive-lock adaptor (loose) and cross-over spool onto the riser inpreparation for the BOP's. When the rig is tying back the last well (H3) the BOP'sshould be able to skidded towards the H'l well and made-up to the drive-lock assembly

{€9lll ThesequenceofremovalofthecapswasnotdifferenttothatenvisagedbyDPlB.Thedifference '1

was that the 9 5/8" pressure containing corrosion cap was removed earlier than was planned. The

plan always had a period of time during which the baniers were planned to be the cemented casing

shoe and the hydrostatic head ofseawater.

l-l4l l2 Paragraph 5.17 of the DP lB shows that the 9 5/8" casing would be exposed to atmosphere when the

9 5/8" pressure containing corrosion cap was removed.

{{*l l3 As the DP I B planned a batch drilling program the 9 5/8" casing would be exposed to atmosphere for

approximately 3 days.

ll-21 14 Before the 9 5/8" pressure containing corrosion cap was removed a pressure check was done and no

pressure under the cap was identifìed. A visual inspection ofthe well was conducted when the 9

5/8" pressure containing corrosion cap was removed to check ifthere was any flow and no signs of

any flow were noted.


27

WIT.1000.0005.0027

coMMtssloN oF TNQUTRYMONTARA \ryELL HEAD PLATFORM


{}31 I 5 Given that it was believed that there was a cement casing shoe and a hydrostatic head of fluid

(unverified) in place, both ofwhich should have stopped any flow, it was not considered necessary

to reinstall the 9 5/8" pressure containing corrosion cap prior to skidding the denick to the next well.

+l4l l6 A Blow Out Preventer (BOP) which is a device forming part of the MODU is used to contain

pressure in the event that a pressure differential is noted in the well.

ll5l 17 During the intervention in the H I Well on20-21 August 2009 the l(est Allas BOPs were not set on

the Hl Well, because:

(a) DP I B does not require the setting of BOPs during the well operations that were in progress

at the time of the Uncontrolled Release;

(b) DP I B does not require the setting of BOPs until the existing casing and conductor strings

are tied back and the production wellhead installed;

(c) the Atlas Drilling Well Control Manual covers the requirement to have BOPs in place

during certain drilling operations and those drilling operations had not yet commenced at the

time of the Uncontrolled Release;

(d) the H I Well did not have a wellhead installed at this stage capable of accepting the BOPs;

and

(e) ifpressure had been detected below the 9 5/8" pressure containing corrosion cap then the l3

3/8" casing would have been tied back and the wellhead and BOPs installed. Before the

pressure containing corrosion caps were removed on 20 August 2009 there was a check for

pressure carried out and no pressure was observed.

tt6l l8 The Seadrill Well Control Manual allows for the BOPs not to be installed on a cased and cemented '1 - -

well once the cement has reached a specified comprehensive strength or after waiting on cement for

8 hours (Wait on Cement Section of the Seadrill Well Control Manual).

{-{41 19 This exposure to atmosphere is consistent with what I understand to be the convention on surface I

wellhead type operations where allowances are made for BOP removal after cement has set as

contemplated in the Seadrill Well Control Manual and I understand this is commonly practised I

within the industry.

The HI-ST Well Uncontrolled Release and the evacuation of the lltest Atlas


28

WIT.1000.0005.0028



il+I20 I was first notified of the Uncontrolled Release at approximately 6am WST in the morning on 2lAugust 2009.

ll9l2l Dan Dunne (PTTEPAA HSE Manager), who was the Emergency Response Group (ERG) Ieader at

the time of the incident, called me to advise that we had had a well blowout on the Montara WHp.

He said Montara Hl Well had let go and personnel were evacuating the rig.

1?0122 The ERG leader's role was to establish the ERG team, a standing panel of pTTEpAA personnel who

respond to emergencies, and make preliminary contacts with regulators and advise internally about

the incident. We rostered the role around the managers.

'l?t123 The immediate concern for the company was the safety of personnel. By the time I,d arrived in the

office:

'l

I

Fomatted! Bullets and


the ERG team was being mobilised in accordance with standing policies and procedures

within the PTTEPAA Emergency Response plan. Greg youd had come in and was taking

over as ERG leader;

the rig had been evacuated; and

the lifeboats were discharging personnel on to one ofthe support vessels and they were

moved to the Java constructor, after it had located itself a safe distance from the wHp.

4"L2124 The evacuation of the llest Atlas and WHP, including the use of the life boats onthe West Atlcts,is .-l -

an operation controlled by Atlas Drilling in accordance with the West Atlas Safety Case Revision.

The West Atlas Safety Case Revision contemplates that Atlas Drilling's SMS procedures for the rigevacuation interface with PTTEPAA's emergency response procedures. PTTEPAA coordinates withits contractors to carry out emergency response exercises, which assess and familiarise people withthe interface between the contractors' facility SMS evacuation procedures and the PTTEPAA

Emergency Response Plan. The point of interface between the contractors' facility SMS evacuation

procedures and the PTTEPAA Emergency Response Plan is the point at which the contractor

requests the use of PTTEPAA's contracted marine vessel and aviation resources for evacuation ofpersonnel from the field location to an onshore location. However, it is Atlas Drilling, not

PTTEPAA, as the operator of the lYesl Atlas facility that is the appropriate entity to be commenting

on whether any drills and practice runs of Atlas Drilling's Safety Case SMS procedures for actual rigevacuation had occurred.

l23l25Regularlifeboatmaintenanceanddrillswereconducted onthelkestAtlas.

(a)

(b)

(c)

29

WIT.1000.0005.0029

COMMISSION OF INQUIRYMONTARA WELL HEAD PLATFORM


l?ll26Drills were conducted weekly, normally at about 1030 hours on Sunday. The drill would commence

initially with a fìre drill with personnel mustering at the temporary safety refuge point. The fìre party

would tackle the fire scenario and if deemed to be out of control personnel would then muster at the

life boat stations. A head count would be performed and then personnel permitted to return to normal

operations. The lifeboats would not be lowered at all during the drills.

Æ127 Atlas Drilling maintenance personnel would conduct a maintenance check of the lifeboats each day;

and about once a month the lifeboats would be lowered and the deluge system tested - this would

take place while normal operations continued on the WHP and l¡l/est Atlas.

*261 28 The drills did not involve an actual evacuation of the llest Atlas as it has been determined that there

are safety concerns about putting people in lifeboats for the purpose ofdrills.

Failures in communication between PTTEPAA and Atlas Drilling

1L7129 The management systems applicable to the construction and suspension of the H I ST- I Well '1established organisational arrangements and communication methodologies that are intended to

facilitate the management, supervision and oversight of well operations canied out by the West Atlas.

l+8130 A copy of the Drilling Program which is the conversion of the well design into the operations that

need to be undertaken by the lltest Atlas is circulated to a variety of people which includes the

PTTEPAA Well Construction Personnel, the Rig Manager of the lilest Atlas, the OIM of the llest

Itlas, geologists, mud engineers, cementers, and also support vessels,.- Sgo that everybody involved

in the program is aware ofthe activities that are being undertaken.

{29131 AnychangestothedrillingprogramhadtogothroughthePTTEPAAmanagementofchange

process. The process for change ofmanagement comprises of identification of requirement for the

change andjustification, engineering the change and recording and disseminating the change. A

hazard analysis or risk mitigation must be carried out in accordance with the risk management

activity that is part of the well construction process. The proposal for change is formally prepared by

the Drilling Superintendent and then approved by the Well Construction Manager. Once approved itis communicated to Atlas Drilling via formal documentation being provided to the OIM and Rig

Manager.

130132 The West Atlas OIM is provided with the Forward Plans by the PTTEPAA Drilling Supervisors on

board the rig which he acknowledges and agrees with before those plans are implemented by

personnel on the rig.

Formatteds Eullets and

30

WIT.1000.0005.0030

coMMrssloN oF TNQUIRYMONTARA WELL HEAD PLATFORM


{3t133 Forward plans are developed by the Drilling Supervisors to communicate the work to be done on

each day. Forward Plans are a more detailed expansion of the Drilling Program that the Drilling

Supervisors put together for use by the personnel on l{est ,4tlas. they are also called 'instructions to

drillers' and they set out what the Atlas Drilling personnel, and personnel ofother well services

contractors, are required to do. The Drilling Supervisor will liaise with these persons to make sure

that they are aware of instructions and are comfortable. The OIM and the Tool Pusher of the l/es¡

Allas are also given copies to ensure that they approve the proposed work and that they then ensure

that the work is carried out in accordance with Seadrill's safety management system for the West

Atlas. 'lhe Forward Plans are therefore the second opportunity for the OIM and Tool Pusher to

assess whether the Drilling Program or the PTTEPAA risk assessed change to the Drilling Program

can be safely implemented by the MODU.

*}2134 What work has actually been done is reported on Seadrill IADC Report to permit the Drilling

Supervisor to report back to the Well Construction Department onshore what work had actually been

done by recording in the Daily Drilling Report.

{33135 The Well Construction Manager or Drilling Superintendent then adds financial information to the

Daily Drilling Report and circulates that more widely for information.

t31136 Following the Uncontrolled Release it was found that:

there had been a deficient application of requirements of the West Atlas Safety Case

Revision in particular Part l: Introduction, Site Description, FSA and SMS, as evidenced by

the failure by the rig to implement risk assessed changes to the Drilling Program. There

were two changes to the Drilling Program that were made under the Well Construction

Change Control Process Change Controls numbered D650054006 and D650054003. The

first change regarded the installation ofpressure containing conosion caps on the 9 5/8" and

the I 3 3/8" MLS. It was subsequently discovered on 20 August 2009 that the l3 3/8"

pressure containing corrosion cap was not installed as per the Change Control to the DP.

The second change control was regarding the amount of cement pumped into the annulus

around the 9 5/8" casing; that was not implemented conectly.

The change control section (4.3.7) of the MODU Safety Case Revision requires that changes

to the MODU or Safety Management System and operating procedures, including at the

request of PTTEPAA, shall be managed in accordance with the West Atlas SMS. It further

provides that changes to programs or drawings supplied by PTTEPAA will be controlled in

accordance with Well Construction Management System and its change control process -

(a)

3l

WIT.1000.0005.0031

coMMtsstoN oF INQUTRYMONTARA WELL HEAD PLATFORM


which it was - there was a failure by MODU personnel to implement the change on the rig

as required by the West Atlas Safety Case Revision.

(b) there was an instance of ineffective communication between PTTEPAA's Well Construction

Manager and Drilling Superintendent onshore and the PTTEPAA Drilling Supervisors on

the MODU facility and an instance of ineffective communication between PTTEPAA's

Drilling Supervisors and the personnel of the MODU facility operator.

There are two areas where it has now been established that communications were not as

effective as they should have been. The first is between personnel on the MODU and

onshore in relation to exactly what had occurred in relation to the cementing of the shoe

including the apparent failure to communicate the final cementing report received from

Halliburton (which is merely a factual statement of what occuned and does not itself draw

any conclusions about the integrity of the cement job). The second is between the MODU

personnel and the Drilling Supervisor who then reported information to personnel onshore

indicating that the I 3 3/8" cap had been installed. It has not been able to be discovered why

PTTEPAA personnel were not informed of the failure to install this cap.

Actions taken by PTTEPAA since the Uncontrolled Retease in order to prevent a similar incident

{35137 PTTEPAA has firstly undertaken a review of the suspension status of the other Montara development'-l - -I

wells at the WHP facility in order to assess whether there are any well hazards indicated by the

constructed condition ofthose wells that present a well control risk.

(a) H2 well remains with a mudline suspension covered with a 508mm (20") trash cap at Boat

Landing Level of the wHP facility. Below the trash cap the 340mm (13-3/s") pressure

containing anti-corrosion cap is in place. There is a cement plug set in the 9-518" casing

from I 60m back to I I 5m and a cemented shoe.

(b) H3 well remains with a mudline suspension covered with 20" trash cap at Boat Landing

Level of the WHP facility. Below the trash cap the l3 3/8" pressure containing anti-

corrosion cap is in place. There is a cement plug set in the 9 5/8" casing from I 60m back to

I I 5m and a cemented shoe.

(c) H4 well has had the 20" conductor tied back and cold cut approximately I m above the

Mezzanine Deck of the WHP facility. The l3 3/8" pressure containing corrosion cap is in

place. There is a cement plug set in the 9 5i8" casing from I ó0m back to I I 5m and a

cemented shoe.


32

WIT.1000.0005.0032



CI well has had the 20" conductor tied back wíth a24 inch section in it. Above the24"

section the 20" conductor has been cold cut 4.5m above the Helideck of the WHP facility.

Both a I 3 3/8" and a 9 5/8" pressure containing anti-corrosion cap and a cemented shoe in

the water les are in place.

{36138 Based on this review, PTTEPAA has assessed that the risk of a similar incident occurring when

MODU facility operations recommence at the WHP facility for intervention in the other Montara

development wells at the WHP facility is as low as reasonably practicable.

{3?139 Secondly, PTTEPAA has considered the deficiencies in communications between, and the level of

compliance with relevant standards and regulatory requirements by, people involved in the

suspension of the Hl ST-l Well:

During PTTEPAA's investigation of the incident a witness interviewed indicated that

corrosion ofthe l3 3/8" pressure containing corrosion cap was a factor that contributed to it

not being installed in the H I ST-l Well. PTTEPAA's further investieation on this point has

concluded that corrosion of the cap was not a factor that contributed to it not being installed

in the H l ST-l Well. PTTEPAA has been able to confirm there w

3/8" pressure containing caps available on the.YeJ¡ 44qs¡! LhS: li4rç=tLey=wste=rçqqiled., _ _

ig_ffis_not

in

@issüe

Whilst not a root or contributory cause of the Uncontrolled Release, PTTEPAA is concerned

by the deficient application of the requirements of the MODU Safety Case Revision (which

interfaces the PTTEPAA Well Construction Management System with the MODU facility's

SMS) by personnel on the MODU facility as evidenced by the failure to implement risk-

assessed changes made to the PTTEPAA Drilling Program in relation to the cementing of

the annulus that were directed as a result of the PTTEPAA Well Construction Change

Control process.

Whilst not alhç root cause of the Uncontrolled Release but as a contributo

Uncontrolled Release, PTTEPAA is concerned by the fact that the Drilling Superintendent

and Well Construction Manager were informed that the l3 3/8" pressure containing

corrosion cap had been installed as a suspension barrier in the H I ST-l Well in April 2009.

(d)

(a)


(b)

(c)

33

WIT.1000.0005.0033



This circumstance is indicative of a failure by the MODU facility operator's personnel to

implementi@issuedby@a¡¿+ppreve¿+y the OIM, as well as inefflective or incomplete communications about well

operations either between PTTEPAA Drilling Supervisors and the personnel of the MODU

facility operator or between PTTEPAA Drilling Supervisors offshore and PTTEPAA's Well

Construction supervisory personnel onshore, or both.

(d) In relation to the root causes ofthe Uncontrolled Release:

(i) the apparent deficiency in hydrostatic overpressure -just prior to the incident the

well must have become under balanced or the Uncontrolled Release could not have

occurred . PTTEPAA has made t

H I Well fluid was providing some additional pressure to prevent flow from the well

preventins flow prior to the occurrence ofthe Uncontrolled Release (at which point

there clearly was no longer a hydrostatic overbalance), This observation was

consistent with the view expressed b]¡ PTTEPAA's well construction personnel. and

the conclusion reached by PTTEPAA durins its investisations in to the

Uncontrolled Release. that this inhibited seawater was overbalanced to reservoir. In

making this observation. PTTEPAA was not stating that it relied on the inhibited

seawater as a venl¿rl ä¿rrier either at the time of the suspension or at the time of

removal of the 9 5/8" PCCC. PTTEPAA accepts that if the hydrostatic head of fluid

were to be used as a verified barrier then inhibited seawater would not have been

appropriate for a normally pressured reservoir such as the Montara reservoir as the

margin between the hydrostatic head it created and the reservoir pressure was

insufficient:

channel in cemented casing shoe - a post incident analysis indicates that the 9 5/8"

casing shoe did not form an adequate tested barrier however on the day with the

i n formation supplied to the Drilling Superintendent {unbekne+vnst-te*im

there+va€.ffe

reasenen+ne+a*-e+PTTEPAA onshore well construction management did not te

suspect that it was nelan inadequate barrier. The Well Construction Manager

interpreted the reports from the rig (i.e. that the cement integrity was "OK") as

meaning that the cemented casing shoe had been pressure tested after the failure of

the float valves.

(ii)

34

WIT.1000.0005.0034

COMMISSION OF TNQUIRYMONTARA WELL HEAD PLATFORM


140 Due to the failure ofthe cemented shoe and the failure to install thc l3 3/8" pressure

containing corrosion cap. PTTEPAA recognises the removal ofthe 9 5/8" pressure

containing corrosion cap (precipitated bv the absence ofthe l3 3/8" pressure containing

conosion cap) was an event which contributed to the Uncontrolled Release. Atlas Drilline

has also stated that the removal ofthe 9 5/8" pressure containing corrosion cap is one ofthe

orimary causes of the incident. PTTEPAA is concerned by the deficient application of the

requirements of the MODU Safety Case Revision (which interfaces the PTTEPAA Well

Construction Management System with the MODU facility's SMS) by personnel on the

MODU facility on 20 August 2009. Whilst PTTEPAA's supervisorv personnel on the

MODU facility at that time applied and relied unon their understandine that the H I Well

contained a competent barrier at the cemented shoe track. the risk assessment process they

ímplemented for the remediation of the conoded l3 3/8" MLS should have also taken in to

account the ability to ensure additional reasonably practicable well control measures were

implemented in relation to that remediation work (including ensuring that the 9 5/8" pressure

containine corrosion cap was re-installed followins the completion of the cleanine of the I 3

3/8" threads). At least the OIM and the Driller from Atlas Drilling and the Atlas Drilling

oersonnel who performed the removal were aware ofremoval ofthe 9 5/8" pressure

containing corrosion cap and permitted it to proceed and did not direct that it should be re-

installed. The identified deficiency in the risk assessment process applicable to the

remediation of the corroded l3 3/8" MLS also involves the Atlas Drilling personnel on the

MODU facility. This is because the West Atlas Safetv Case Revision interfaces the West

Atlas SMS with the PTTEPAA Well Construction Management System and requires an

integrated approach to risk assessment as between PTTEPAA (.as titleholder and WHP

facility operator) and Atlas Drilling (.as MODU facility operator).

{38141 Since the Uncontrolled Release PTTEPAA has identified potential improvements to its Well

Construction Management System and has adopted the actions listed in paragraphs 14839-15+3

below to further elevate this with a view to preventing a similar incident. Initiated a review of

PTTEPAA's WCS and development well Drilling Programs with the objective of assessing the

technical opportunities for improvements to the methodology of utilisation of MODU facility well

control equipment during intervention on suspended development wells and to make any appropriate

recommendations arising from the review to the MODU facility operator.

*39142 lnitiated a review of PTTEPAA's implementation of the PTTEPAA Well Construction Management

System with the objective ofassessing the adequacy ofthe check and review steps on Drilling

Formattedl Head¡ng I,MSD,Indent: Left: 0.75 cm,Hangingl 1.75 cm


35

WIT.1000.0005.0035



Program and Drilling Program Change Control implemented by the Well Construction Manager and

the Drilling Superintendent under the wcs. In particular, consider implementing:

(a) further check and review steps on Drilling Program and Drilling Program Change Control

implementation by:

(i) requiring sign-ofß by the Drilling Supervisor and the MODU facility OIM of the

implementation of safety critical steps in the Drilling program;

(ii) requiring Change Control documentation to be counter-signed by the Drilling

Supervisor and the MODU facility OIM evidencing implementation of the change;

(iii) adding an interface with the PTTEPAA HSE Department for auditing of the

implementation of the Change Control; and

(b) a requirement that all MODU facility operations, including off-line operations, are recorded

in the Daily Drilling Report.

{40143 PTTEPAA will revise its Management System documents to incorporate any improvements 'l - -

recommended by the review and make any appropriate recommendations to the MODU facility

operator regarding the MODU facility SMS that arise from the review.

*41144 Initiate a review of the MODU facility safety case Revision process to assess:

(a) the adequacy of the HAZID and Induction workshops as mechanisms for communicating the

requirement to interface the Titleholder's Drilling Program and Well Operations

Management Plan with the MODU facility,s operational and SMS; and

(b) the process of Drilling Supervisor and OIM supervision of the implementation of the

Drilling Program by the MODU facility personnel.

*4â145 Make any appropriate recommendations arising from the review to the MODU facility operator for:

(a) revising the methodology for MODU facility safety case revision preparation and content;

(b) titleholder haining on MODU facility safety case revision implementation in particular

during extended duration drilling campaigns where workforce turnover may be increased;

and

FoÌmatted: Bullets andNumber¡ng


36

WIT.1000.0005.0036

CoMMISSION OF TNQU|RYMONTARA WELL HEAD PLATFORM


MODU facility operator communication of safety case revision requirements to MODU

facility personnel.

{43146 Reviewing the communication processes that are currently operative in relation to MODU facility '-l -

operations for well construction to identify any improvements to those processes whether by

changing the current process or by training personnel in compliance with the current process, This

review is encompassing the communication processes applicable as between PTTEPAA's Well

Construction supervisory personnel onshore and PTTEPAA Drilling Supervisors on the MODU

facility and as between PTTEPAA Drilling Supervisors and the personnel of the MODU facility

operator. The Management System will be updated to incorporate any improvements identified by

the review and any appropriate recommendations made to the MODU facility operator regarding the

MODU facility SMS that arise from the review.

+44147 Aftanging for a third party independent audit of P'ITEPAA MODU-based supervisory personnel

(Drilling Supervisors) implementation of:

safety critical components of the well construction Management system such as change

Management; and

supervision of MODU facility operator's implementation of MODU facility safety case

revision requirements for interface with the PTTEPAA Drilling Program and Well

Operations Management Plan.

145148 Ensure that PTTEPAA management planning incorporates a regular process of both internal and 'lindependent third party auditing of the effectiveness of both the MODU facility operator's

implementation of the MODU facility's SMS (in particular integration with the Drilling Program)

and the Well Construction Department's implementation of the Well Construction Management

System.

146149 Develop an audit plan for PTTEPAA Drilling Operations that focuses on:

inquiry in to the effectiveness ofchecks in assessing the level ofcompliance with the

PTTEPAA Drilling Program and well operations Management plan on the MODU facility,

and

an SMS review of the MODU facility from the perspective of the quality of the

implementation of systems, processes and procedures in particular in relation to the

identification and treatment of well hazards.

(c)

(a)

(b)



(a)

(b)

37

WIT.1000.0005.0037



{4+150 Carry out a review of the selection of Employees and Contractors for PTTEPAA Well Construction '-l - -

activities to determine whether the assessment of the competency of Drilling Supervisors is

appropriate including identifying training pre-requisites for well operations risk management. This

review will encompass an assessment of the safety critical training mandated by the Well

Construction Management System to ensure that it incorporates all of the following items:

(a) Well Control;

(b) We¡l Integrity Hazard Management; and

(c) Safety Leadership.

{4Sl5l Initiate a review of the implementation of PTTEPAA Well Construction Management System's '-l - -

Procurement and Logistics Procedures to determine whether the quality assurance checks ofwell

equipment are appropriate and integrate with the procedures applied under the PTTEPAA Corporate

Procurement and Logistics function.

{491 52 Initiate a review of the implementation of the MODU facility's procedures for quality control check I

of equipment prior to utilisation in well operations.

.150153 Initiate a review of the WCS. Include an evaluation of whether requirements should be inserted in I

the WCS for:

(a) repeat pressure testing should be inserted in relation to cementing ofshoes when there is an

indication that there has been a flow back during a cementing process; and

(b) quantified minimum hydrostatic overpressure during well suspensions.

and identify whether any changes are required to clarify barrier requirements in relation to the

various types of well suspension operations.

t5ll54 Evaluate whether to insert "hold points" in the Drilling Program such that after certain steps have '1 - -

been performed a positive sign offis required from the rig operator and the Drilling Supervisors.

Formatteds Eullets andNumber¡ng


Formatted¡ Bullets andNumbering

38

WIT.1000.0005.0038

CoMMISSION OF INQUTRYMONTARA WELL HEAD PLATFORM


{53156 All of these reviews have been initiated and are still being worked on. PTTEPAA intends to

implement any required changes prior to undertaking any further well construction activities.

+54157 I consider that the reviews implemented by PfiEPAA are an appropriate response to all of the issues

that that have been identified by PTTEPAA as a result of its review of the causes and issues arising

from the Uncontrolled Release. PTTEPAA will review this position further followine receipt of the

Commission of Inquiry's report.

Stopping the Uncontrolled Release

{++158 A number of possible scenarios to stop the uncontrolled flow were being considered on 2l August '-l2009. We flew the Well Construction Manager down from Darwin on 22 August 2009 as he had

been on the rig at the time of the incident and was in the last lifeboat off the rig.

155159 We contacted a number of well control companies. The first comment from most of the well control I

companies was "are you able to deluge the platform". Deluging is putting high volume water pump

capacity units on the back of vessels in order to provide a water spray over the platform. The logic

was to prevent or minimise any impact if there was ignition of the well fluids coming out of the well.

We started to mobilise deluge equipment out of Singapore.

*56160 We selected Alert as the most suitable well control company due to their experience in this regard I

(they had successfully completed some 1,200 well control and related operations over the past 25

years), availability and being one of PTTEP's designated well control companies, with a contract

already in place with PTTEP in Thailand.

.lé7161 Initially, Alert's thoughts were on two options to bring the well under control, capping the well or I

drilling a reliefwell. A third sub-sea option was also considered.

Selecting an optìon

158162 InanumberofmeetingswiththeMinisterforandtheDepartmentof Resources,EnergyandTourism'-l --

it was confirmed that safety of personnel was the priority of both the Government and PTTEPAA.

Cøppíng the well

l59ló3 Capping the well would have involved going on board the WHP or the rig, installing basically a nOn''l - -

on top of the conductor casing, closing the BOP to stop the flow and being able to pump heavy mud

in from the surface to kill the well.

Fo¡matted: Bullets and



39

WIT.1000.0005.0039

coMMISSTON OF INQUTRYMONTARA WELL HEAD PLATFORM


*60164 Initial review of the capping operation was that if the equipment was availabte, and the attempt was

successful, then it may have stopped the flow I I days earlier than the relief well.

{étI65 The Capping Option had a number of issues with it:

(a) first of all, the equipment required is not the standard BOP that would be on the rig.

Equipment had to be mobilised out of Singapore and that takes a number of days to

consolidate the load. We started the work to mobilise equipment;

(b) potentially a heavy lift vessel such as a crane barge would have been required. These are

not freely available, and would have needed to be positioned very close to the WHP. This

position posed safety concerns as discussed in the other options;

(c) we did a review of the two options. The capping option was assessed internally by the Well

Construction group with Alert initially and PTTEPAA's HSE personnel. They had concerns

on the risk to loss of life and they were asked by me to present a review to the management

team of the company. The presentation covered what had to happen in order for a capping to

occur and how they assessed the risks involved. It was determined that there was a

significant likelihood of a fatality should the well fluids ignite whilst we \ryere trying to carry

out that operation and that operation in itself had the potential to produce the ignition

source. On that basis, the management team agreed that it was not an acceptable solution

from a safety perspective, at that time and would need further development; and

(d) subsequent events showed that obtaining acceptance ofa safety case revision to place a

vessel near the WHP prior to killing the well was unlikely to occur.

Subsea optíon

{6?1 66 The subsea option involved entry into the well wall between the sea surface and the sea bed; that is -lto attempt to kill the well by entering in the casing strings.

{.é}167 PTTEPAA engaged a local company to start looking at that option as well.

*81168 This option did not involve going on the platform, so personnel would not be so exposed. The plan

was to somehow remotely, with a Remote Operative Vehicle (ROV), drill into the casing strings and

introduce fluid that way.

{65169 This option was ruled out for the following reasons:


40

WIT.1000.0005.0040

coMMrssroN oF TNQUIRYMONTARA WELL HEAD PLATFORM


the technical issue ofgetting through both the 20" and the I 3 3/8" casing and into the 9 5/8

casing and establishing a seal so that mud could be injected into the well at pressure; and

a vessel would be required to operate a ROV. At the same time we were looking at this, we

were looking at the deluge option and we'd had a prohibition notice issued by National

offshore Petroleum Safety Authority (NoPSA) which had forbidden us to do any work at or

near the WHP, until we had been able to provide an acceptable Safety Case revision. We

were trying to get a safety case revision accepted by NOPSA to bring vessels into deluge the

platform but we were not successful. Given the sub-sea option also required vessels in the

area we knew based on the problems we were experiencing getting deluge acceptance, we

would have similar problems with this option. Even though the ROV would be unmanned, it

would be working from a support vessel that would have to be within a few hundred metres

of the WHP, similar distances to that required for deluge. This also ruled out any other

potential subsea options.

{66170 The prohibition notices issued by NOPSA did not stop PTTEPAA from reviewing all potential

options for stopping the Uncontrolled Release.

'lé+l7l PTTEPAA based on the information provided by the Alert personnel concluded that a successfut I

capping option could have been completed I I days earlier than the relief well. However, PTTEPAA

in its review ofthe risks associated with the capping option, deemed the risks created by that option

which included potential fatalities to be unacceptable. PTTEPAA continued to work on this option

to try and reduce the risks to an acceptable level. At this point, the first NOPSA prohibition notice

was issued. In trying to achieve an acceptable safety case revision for a vessel to approach the WHP

to deluge it became apparent that physically boarding the WHP was unlikely to be an acceptable

scenario. This was confirmed when NOPSA issued the second prohibition notice which required at

least one effective well control.

.lé8172 Water deluge would not have stopped the well. It would have been used to reduce the potential for a I

fire to occur.

Relief llell

169173 The relief well option involved drilling another well to intersect with Hl Well and then quelling the '1-flow with mud until the well could be secured. What has to occur is that the weight of mud in the

well is greater than the pressure coming from the reservoir through whatever hole the flow is coming

from so it hydrostatically holds the fluids in the reservoir.

(a)

(b)


Formatteds Bullets andNumbering

4t

WIT.1000.0005.0041



*70174 Ascertaining the most likely path through which the oil was flowing was relevant to the planning ofthe relief well as it determined where the point of intersection needed to be.

l4tl75 The Well Construction Department worked on identifying the likely source of the Uncontrolled

Release. After a review of the information at the time of suspension of the well in March where itwas noted that there had been a possible problem with the cement plug at the bottom of the well and

that it hadn't been re-pressure tested and factoring in the observations ofthe well prior to and after

the Uncontrolled Release, the Well Construction Department concluded that the flow was through

the 9 5/8 casing.

114176 ln this regard, it would have been expected that a flow from the l3 3/8" x 9 5/8" annulus would have

been drawing gas into the well. This was because an annular flow would be caused by a cement

channel on the outside ofthe 9 5/8" casing and the shallowest hydrocarbons in the well is gas above

the oil leg in the reservoir. The fìow characteristics ofgas would result in gas flowing in preference

to oil or water. As it was observed that there was oil, gas and water flowing, it was indicative ofentry via the 95l¡ shoe, which was in the oil zone between the gas and the water, so you would draw

in all three components. All three

components were noted with significant quantities of water and / or liquids. Channels would also

have to have been in all ofthe cemented levels which was considered unlikely as no problems had

been noted with the cementing of the l3 3/8 casing,

+7t177 All indications indicated strongly that source of flow was through the 9 5/8 casing which is why we

then targeted the reliefwell to intersect the 9 5/8 casing. ln addition, the hydraulic modelling done by

Add Energy, who were part of the response team, concluded that intersecting the well through the 9

5/8 casing was most likely to achieve success.

{+4178 As we had been unable to develop the other options successfully and it was anticipated a relief well

would be effective, we decided to drill a relief well, whilst continuing to look at other options.

operated the llest Atlas) was not under contract and could be made available to drill the Relief Well.

Given the availability of the llest Triton and the fact that it already had an accepted NOpSA safety

case in place, on 23 August 2009, PTTEPAA contracted the ll/est Triton. Personnel were

immediately dispatched to Batam via Singapore to prepare the llest Triton for the Relief Well

operation.

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WIT.1000.0005.0042

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lf6l80 While the llest Triton was being prepared, PTTEPAA continued to pursue and evaluate the other rig

options to see if another rig would be available earlier than the llest Triton. Three other rigs were

considered for use, two of these were working in hole at the time, which gives a degree ofuncertainty as to their potential release date:

a jack-up rig, the Ocean Shield, operated by Diamond Offshore, which was working for ENI

Australia (ENI) at the Black Tip fïeld in the Joseph Bonaparte Gulf in the Timor Sea at the

time of the Uncontrolled Release:

ENI was on a tight program to enable it to produce first gas and meet its contractual

arrangements to the Northern Tenitory Government, Power & Water Corporation.

The Ocean Shield was engaged in operations that would not allow for it to be made

available immediately. There would be a point in the future at which time it would

be possible to release the rig, but that would compromise ENI's ability to meet its

contractual commitments. Even in the event the rig was released at this future time,

it would have only allowed the rig to be at the relief well location within days of the

anticipated arrival ofthe ll/est Triton;

ENI discussed the requirement for indemnities to be provided by PTTEPAA for the

use of the Ocean Shield in light of ENI's contractual arrangements with the Power

& Water Corporation. PTTEPAA asked for ENI to come back with a proposal in

writing. When PTTEPAA followed up with ENI the Blacktip drilling programme

had reached a stage where the Ocean Shield was not able to be released for a

number of days which would put its forecast timeframe for arrival at the Montara

field beyond the forecast timeline îor the lltest Triton's anival at the Montara field;

consequently, investigations into using the Ocean SniU *"r"not further pursued.

a jack-up rig,the Ensco 104, operateÅ by Ensco, which was working for Conoco phillips at

Bayu-Undan in the Joint Petroleum Development Area (JPDA) at the time of the

Uncontrolled Release:

this rig could not be released due to the stage that the drilling programme had

reached. There would be a point in the future at which time it would be possible to

release the Ensco 104, but by that time, it would have only allowed the rig to be at

the relief well location within days of the anticipated arrival of the l{est Triton;

consequently, investigations into using Íhe Ensco 104 were not further pursued; and

(a)

(i)

(i i)

(b)

(iii)

(i)

(ii)

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WIT.1000.0005.0043

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(c) a semi-submersible rig, the Songa Mecur , which was contracted to TOTAL in Dampier and

due to start work for Woodside about a month later. It was decided the.Songa Mear was

not appropriate for the following reasons:

as it is a floating rig it required anchoring which is likely to have necessitated

anchor handling vessels being located close to the WHP within the gas plume;

critical magnetic ranging data is best gathered from a fixed platform (rather than a

floating platform) as each time the target is missed, several days are required to

make another attempt and there is greater propensity to miss from a floating

platform, and

(iii) once the Target casing was intercepted it would be necessary to rapidly pump a

large amount of mud into the Hl Well. Alert initially advised that approximately

2,700bbls of mud would be needed for the H I Well kill. While the Songa Mecur

had mud carrying capacity of 2,700bb1s, the amount of mud required for the H I

Well kill was revised up several times, with hydraulics modelling specialists, Add

Energy (who were experts assisting Alert), finally indicating that 3,400bbls of mud

would be needed to stop the flow.

{+7181 The lleslTriton leftSingaporeon2TAugust200g, lessthanaweekaftertheUncontrolledRelease *-l -

and arrived at the site on I I September 2009.

Æ182 I can unequivocally state that cost was not a factor relevant to PTTEPAA's engagement of the l|/est

Trilon rather than any other rig, nor was cost a factor relevant to any other aspect of PTTEPAA's

response to the Uncontrolled Release.

*791 83 Involved in the drilling of the relief well werq PTTEPAA, Alert, Seadrill, Schlumberger for the

directional drilling, Vector Magnetics lor the positioning of the Well, the mud company was Baker

Hughes Inteq (BHl) and cementing was Halliburton.

.lSO l 84 Throughout the reliefl well operations, the ERG monitored PTTEPAA's efforts to bring the

Uncontrolled Release under control and was used to coordinate vessels and aircraft to support the

drilling of the Relief Well.

++f 185 It was always anticipated there would be a number of attempts to intercept the well. The first pass

was approximately four and a half meters distant; the second pass was approximately 70 centimetres.

On the third attempt the drill bit ended up down the same hole as the second attempt. We then

(i)

(ii)


44

WIT.1000.0005.0044

coMMrssroN oF INQUIRYMONTARA WELL HEAD PLATFORM


decided to install a whip stock, which is a metal wedge that is shaped so that the drill bit comes down

and then is deflected off free of the side of the whip stock. The whip stock guides the drill bit so you

can get up to an eight degree bend over a 30m interval. The unit is inserted into the well at the

desired depth and orientation, it can then fit into the hole by expanding the packet and by using the

drill bit to come off at the side so that it gives you fine control on the angle at which you drill away

from the whip stock.

*8218ó As the third pass went down the second hole it was decided to use the whip stock to guide ourselves

in from the side. When we ran the whip stock in the well, it got stuck in the hole higher up than were

we wanted to set it.

+83187 PTTEPAA peer reviewed drilling operations at a meeting on 26 October 2009 attended by INPEX,

AGR, Schlumberger, Vermillion, Chevron, SPD, Seadrill, Boot & Coots, Woodside, Apache,

PTTEPAA, and PTTEP (via telephone) all ofwhom agreed based on the available evidence that the

best course of action would be to cement the whip stock unit in the hole, and came higher up in the

well and put a cement plug in and then side track out of the well from about 100 metres from the

target and steer down. At that point we successfully intercepted the well. This was a better result

that we had anticipated. We were expecting to have to do at least another pass.

{81188 We had several communications with the Government updating them on progress. We indicated that

it would take at least two to three attempts. We then had the problem with the whip stock and

advised them on the last run that whilst we were hopeful, we weren't expecting to actually hit it.

Mike Alcorn (Alert) advised the media in a press conference explaining the relief well option that a

number of intercept attempts were likely to be required.

*&5189 When the well was intersected, initially I .3 sg (specific gravity) mud was injected to smother the

flow. Mud of this density was selected based on modelling conducted by Add Energy, estimates ofthe flows that were occuning and therefore the weight of mud required to quell the flow without

damaging the well.

186190 We had approximately 4,000 barrels of I .3 sg mud or more on the rig. When we pumped that in, we

had a period where we had mud returns at the surface of the WHP. We significantly reduced the gas

flue from flowing, however we still had hydrocarbons flowing but we had basically just about

stopped the Well, at which point we started to run out of mud on the rig. So we started to use brine

as an altemative fluid but it was obvious we were not going to be able to contain the well, so we then

pumped sea water in and about I - 2 hours after that there was some ignition source and the WHP

caught on fire.

45

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C0MMISSION OF TNQUTRYMONTARA WELL HEAD PLATFORM


.l{?l9l We do not know what the ignition source was and can only speculate in that regard.

t&S I 92 In order to put the fire out, it was necessary to quell the flow from the well. We ultimately increased

the mud weight to I .6sg. The concern with l.6sg was because you get a much heavier mud, you get

a higher pressure. The concern was whether l.6sg would flow back into the reservoir rather than up

the H I Well, but Add Energy did the modelling and said that I .6sg would be okay.

+89193 If the mud had flowed back into the reservoir, you could lose the hydrostatic head retaining the well.

At some point the balance changes and then you can get the well flowing again.

Regulatory approvals for the Relief Well

{90194 A variety of approvals were required to allow the Relief Well operation to take place, We made the '1necessary applications and advised the Department of Resources and Tourism (DRET) of what we

were doing. My understanding is that DRET assisted in confirming to the relevant departments that

this was an emergency, and processing ofthese applications should be prioritised.

*91I 95 We needed EPBC Act approval or an exemption from the Minister (Peter Carrett).

19219ó We needed an environment plan approved by the DA. In this regard, we modified the existing plan.

++1197 A Well Operations Management Plan was approved by the DA.

.l4tl98 I have been asked by the Commissioner to provide my views about whether the WOMP for the relief

well was adequate in light of concerns expressed by Geoscience Australia and the Victorian

Department of Industry. I recall the technical questions and comments made by Geoscience

Australia and the Victorian Department of Industry in relation to the relief well drilling program.

These questions and comments were given to the Northern Territory Department of Regional

Development, Primary lndustry, Fisheries and Resources (NTDRDPIFR) in its role as the applicable

DA. At the request of the NTDRDPIFR, PTTEPAA provided NTDRDPIFR with a response to the

questions. I do not recall PTTEPAA addressing concerns expressed by Geoscience Australia and the

Victorian Department of lndustry about the WOMP in that response. We did not do so on the basis

that we understood those concerns to be addressed to the DA, as it was the DA which approved the

WOMP, and not to PTTEPAA. I cannot speak for Geoscience Australia or the Victorian Department

of Industry but surmise that their concems regarding the WOMP may arise from the fact that they are

not advocates of the 'Road Map' format of WOMP and they had not been provided with

PTTEPAA's Well Construction Management System documentation which the relief well WOMP

points to.


46

WIT.1000.0005.0046

coMMrssroN oF TNQUTRY

"."x$i¡äff"ii,""""ïåâiåiäiïål^,,t95199 Seadrill also required a Safety Case Revision for the operation of the l{est Triton. We assisted them

Iin this regard by providing the relevant information.

*96200 We also required Australian Quarantine and Inspection Service (AQIS) approval to bring the llest I

Triton and, in particular, the waste on it into the Australian territorial waters.

*97201 On l0 September 2009, AQIS outlined the conditions that had to be fulfilled for the l{est Triton to I

be cleared to arrive at the Montara WHP, being an Australian resource installation.

{48202 AQIS confirmed there would be no bio-fouling impediments to the l/es, Triton attaching to the I

seabed and requested that we submit an application pursuant to the Quarantine Act /,908 (Cth).The

application was submitted on 4 September 2009.

{99203 AQIS approved the arrival oîthe ltl/est Triton atthe Montara WHP, including issuing an approval, I

being a document entitled "Permission to Enter a Place Other Than A First Port of Entry".

Managing the environment and oil spill response

?00204 The National Plan to Combat Pollution of the Sea by Oil and Other Noxious and Hazardous 'l - -

Substances (National Plan) was activated in the evening of Friday, 2 I August 2009.

2et205 The initial notification to the Australian Maritime Safety Authority (AMSA) during the day was that

an incident had occurred and that we were assessing the situation.

?04206 PTTEPAA provided an estimate of the amount of oil that was flowing from the well. This was done

based on visual observations of the Uncontrolled Release. Aa more accurate estimate (in itself

difficult to make given the inability to measure the flow) was not provided as AMSA advised it was

not required as they intended to monitor the area ofthe oil slick by aerial surveillance and it was

considerd to be more important to prioritise stopping the Uncontrolled Release.

203207 AMSA daily surveillance flights on 7 and 8 September reported a drop in the amount of oil flowing

from the rig and within the 20Nm radius of the platform. This tends to indicate that there may have

been a slow down ofthe spill on 7 September 2009.

&20llCommunication with Australian Marine Oil Spill Centre (AMOSC) and AMSA continued

throughout the day. Both AMSA and AMOSC began mobilising equipment


47

WIT.1000.0005.0047

coMMtssroN oF TNQU|RYMONTARA WELL HEAD PLATFORM


N5209 we formally requested that AMSA take control of the oil spill response and refened the matter to the I

Designated Authority, being the Northern Territory of Australia, who then immediately handed

"combat control" over to AMSA, with PTTEpAA being responsible for all costs.

206210 On 22 August 2009, AMSA confirmed the transfer of control of the oil spill response to it using the

National Plan and assumed command of the oil spill response. On 29 June 2009, we provided

AMSA with a copy of our Oil Spill Contingency Plan (OSCP). On 23 August 2009, we refened

AMSA to our letter of 29 June 2009 and provided a second copy of the OSCp. Following on from

this, on 3 September 2009, we notified AMSA that:

we had been granted approval to drill and operate in the Montara development area for the

purpose ofoil production and that this Approved Action was subject to conditions including

that we must submit and adhere to an OSCP;

section I 34 ( I ) of the EPBC Act states that if another person (AMSA) is authorised to

undertake any part of the Approved Action on our behalf, then the authorising party must

ensure that the person undertaking the action is informed ofthe conditions attached to the

Approved Action ie adhering to the OSCP; and

as part of PTTEPAA's compliance under the EPBC Act it required AMSA to review the

OSCP sent to it previously.

*7211 One of the other organisations that we involved in the oil spill response was OSR from Singapore. '1 -

We mobilised equipment (including the Hercules aircraft) and personnel from them to assist in

dealing with oil spills. On 22 August 2009, ateleconference between us, AMSA and AMOSC was

held to review the situation and discuss response strategy options and dispersant application.

2e8212 AMSA conducted a net environmental benefit analysis, in accordance with industry best practice,

prior to making the decision to apply dispersants. This initial analysis was based on the best

information available at the time and documented within the Incident Action Plan. The net

environmental benefìt analysis was regularly reviewed and updated throughout the response.

20921 3 Following on from this, AMSA made the decision to use dispersants in order to hasten natural

dispersion processes.

2'l€214 AMSA also engaged, from this point to 3 December 2009, the date the response operation ceased, a

range ofoil recovery operations. The actual operations were under the control ofAMSA however

(a)

(b)

(c)

Formatted3 Eullets andNumbering

48

WIT.1000.0005.0048



significant resourccs (vessels / helicopters / etc) and coordination ofthese were provided by

PTTEPAA including:

both aerial surveillance (carried out by AMSA) and surface surveillance (by vessel) to

determine the extent ofthe oil sheen/slick, which including mapping ofthe oil and sheen

distribution For example, on 27 August 2009, observation flights passed over Ashmore

Reef, approximately 148 kilometres WNW of the Montara WHP, and no oit was sighted in

the area;

continued dispersant spraying operations by both aircraft and vessels;

fluorometry testing from vessels;

containment and recovery operations by vessels using a boom and skimming equipment.

Vessels first anived on site to carry out these operations on 3 September 2009 and

containment and recovery operations commenced on 5 September 2009 and continued until

3 December 2009. The operations involved two vessels working togetherjoined by a 300

metre containment boom held in a "J" configuration, with a skimmer operating in the boom

"pocket" to recover the oil. No recoverable oil was located after I 5 November 2009; and

utilisation of PTTEPAA's production unit Challis Venture to recover oil, allowing recovery

vessels to stay in field for longer and be more efficient in recovery.

2-l+2 I 5 PTTEPAA did not have dispersants on site at the Montara Development as it had established that '1 - -

logistical a¡rangements were in place to ensure dispersants could be brought to site within one or two

days and no modelling indicated that any significant impact would occur within one or two days.

2,13216 AMSA mobilised aircraft and dispersant so as to be on site on 22 August 2009 to begin aerial

spraying ofthe spill and dispersant spraying operations commenced on 23 August 2009. The fact

that dispersants reached siteby 22 August 2009 proves that the logistical arrangements for getting

dispersants to site were effective.

211217 As part of this process, we mobilised a specialist C-130 Hercules aircraft from Singapore on 2l

August 2009 at AMSA's request this anived in Darwin on 22 August 2009 and was used on 23 and

24 August 2009 in dispersant spraying operations.

?142 I 8 However, being a large aircraft, the C- I 30 Hercules proved diflicult to manoeuvre and align exactly

with the oil windrows. Following operational debriefs on 24 August 2009, it was considered that the

(a)

(b)

(c)

(d)

(e)


49

WIT.1000.0005.0049



smaller aircraft would be more effective for continued operations requiring accurate delivery of

dispersant onto relatively nanow patches ofoil.

2{5219 After we handed over control of the oil spill response to AMSA we provided logistical resources

support. ln this respect the ERG was used to coordinate vessels and aircraft to support AMSA's

response to the Uncontrolled Release. However, all issues regarding the application ofdispersants or

recovery were decided by AMSA.

2{€220 AMSA was responsible for conducting the operational monitoring during the oil spill response.

2*1221 We also arranged for fresh oil samples from the spill area to be collected, which were then

transferred to Darwin for analysis by AMSA. This was for the purpose of evaluating the

effectiveness of the dispersants. Crude oil samples were also provided by PTTEPAA to AMSA on

request by the Indonesian officials. A I litre sample was sent to Indonesia.

24&222 We worked in a proactive manner with AMSA, for example we arranged with Ivan Skibinski ofAMOSC to mobilise barrier equipment to Darwin prior to the final decision by AMSA to deploy '

barriers. Barriers were considered by AMSA and I advised AMOSC to mobilise the equipment so

that it was on its way and by the time the decision was made it would be on the way or already be in

Darwin ready to be deployed.

719223 Aspartoftheongoingoilspillresponseoutlinedabove,tworesponsevesselsenteredlndonesia's

Exclusive Economic Zone(EEZ) on 23 September 2009 to conduct containment and recovery

operations, using a boom and oil spill skimmer on heavier patches ofoil that had been sighted by

aircraft. On or about this date, the Department of Foreign Affairs (DFAT) obtained permission from

the Indonesian Covernment to conduct oil slick containment operations in Indonesian waters. These

operations were completed within several days and the vessels returned to Australia's exclusive

economic zone. Following this operation, regular over flights continued and indicated primarily

sheen within theEEZ, with occasional small patches of weathered oil. Regular updates were

provided to Indonesian authorities.

Æ224 Also on 23 September 2009, satellite imagery showed that small patches of weathered oil had

crossed into the Joint Petroleum Development Area established under the 2002 Timor Sea Treaty.

*225 On 4 November 2009, following the "kill" of the leaking well on 3 November 2009, AMSA stated

that:

(a) it would continue its clean-up operations despite the successful "kill" of the well;

50

WIT.1000.0005.0050

coMMrssroN oF INQU|RYMONTARA WELL HEAD PLATFORIVI


(b) while dispersant operations would cease with the cessation of fresh oil coming from the

WHP, containment and recovery operations would continue as necessary; and

(c) isolated patches ofoil remained a significant distance from the coast and marine parks.

Æ226 On 3 December 2009, the response operation ceased based on specified triggers being reached, 'l- -

including that:

(a) DEWHA advised that there were no recoverable tar balls, slicks, or sheens threatening

Ashmore Reef and Carticr Inlet;

(b) a strategy involving an extensive eight day aerial surveillance program (2 I November 2009

to 28 November 2009) confirmed no sighting of visible sheens or oil/wax patches

threatening the reef habitats;

(c) no significant patches of floating oil were sighted in the open water during this period;

(d) surface vessels maintaining surveillance within the area ofoperations did not sight oil

during this period;

(e) shoreline cleanup on the Islands was not instigated during the response as there was no

evidence ofoil on the Islands requiring any response actions, and

(0 dispersant spraying operations were not required from 3 November 2009.

*1227 PTÍEPAA is undertaking a review of its OSCP as a result of the incident, and witl utilise results '-l - -

from various studies to up date the plan.

DETyVHA's role as Incident's Environmental and Scientific Coordinator

?3y',228 DEWHA was appointed the incident's Environmental and Scientific Coordinator (ESC). In this role'-lit was responsible for providing advice on the likely environmental impacts of an oil spill, oil

wildlife response and advising AMSA in relation to environmental/species matters. Following the

appointment, DEWHA conducted wildlife response operations and it was agreed that PTTEPAA

would meet all associated costs. This included:

(a) on l8 September 2009, entering into an agreement with Western Australia's Department ofEnvironment and Conservation (DEC) to establish a joint wildlife response centre in

Broome;

Fomatted: Bullets andNumbering

Folmatted: Bullets and

Fonnatted! Bulleb and

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WIT.1000.0005.0051

coMMrssloN oF INQUIRYMONTARÂ WELL HEAD PLATFORM


(b) on 24 September 2009, DEWHA commissioned a rapid survey of the "mega fauna" (defìned

as cetaceans, birds and marine reptiles, being turtles and sea snakes) in the Montara oil spill

region. From 25 September 2009 to 4 October 2009, a wildlife survey, commissioned by

DEWHA, was conducted in the region of the oil spill. The survey formed part of the wildlife

response to the incident. The report was completed on 23 October 2009; and

(c) sending an offìcer to Ashmore reefeach week to check on any environmental impact that the

spill may have had on migratory birds currently breeding on the island. The officer would

collect any dead birds for analysis; and live birds covered in oil in order to clean them and

nurture them back to good health.

#229 On 29 September 2009, DEWHA also provided environrnental advice to AMSA on the Net '-l - -

Environmental Benefit analysis for the use of chemical dispersants, for consideration as a

response option.

Environmental Monitoring Plan and Scientific Monitoring Stud¡es

+26230 PTTEPAA did not carry out any base line environmental studies specifically for the Montara Rroject.'-l - -

The environmental information we submitted with the original EPBC Act referral would have been

based on pre-existing data from either Jabiru or Challis or from other operators in the region.

*7231 On 2l August 2009, I asked the HSE Manager, Dan Dunne, to investigate where we could get I

environmental assistance and expressed a view that we needed to identify somebody to assist the

company with managing the environmental impacts of the Uncontrolled Release.

Æ232 The HSE Manager approached Peter Collins and lan Baxter from URS, and had a meeting on 24 I

August 2009. At the meeting the incident was discussed and it became apparent URS did not have

anyone that was suitable available to assist at that time.

?99233 John Wardrop was recommended to PTTEPAA as being potentially suitable to assist by ASA I

Pacific. PTTEPAA was told that John Wardrop had been involved in oil spill and monitoring and

consulting to industry and government on previous oil spill incidents.

??8234 The HSE Manager approached John Wardrop and spoke to him about involving him in the oil spill I

response.

231235 After a review of John Wardrop's qualifications and experience and following Dan Dunne's I

discussion with him, PTTEPAA decided to engage him to assist us in both the oil spill response and

Formatted: BulleE and

Formatted3 Bullets andNumber¡ng

52

WIT.1000.0005.0052



to develop an environmental monitoring programme (Monitoring Plan) in relation to the

environmental effects of the Montara Hl Well release, which was both operational and scientifîc. On

23 August 2009, DE\ryHA had raised with us the need for a Monitoring Plan.

Æ236 Qur initial advice from John Wardrop was in relation to the Monitoring Plan.

83237 On 26 August 2009, there was a teleconference between DE\ryHA, AMSA and PTTEPAA to

discuss:

(a) the incident;

(b) the response to the incident;

(c) the Monitoring Plan; and

(d) cunent knowledge ofbaseline data.

234238 Also on 26 August 2009, there was a teleconference between PTTEPAA, Ivan from AMOSC and Mr''lWardrop to discuss the incident and the operational response.

2?5239 I spoke to Tania Rishniw (the ESC) on several occasions to advise her about the progress beine made I

with respect to the Monitoring Plan and DEWHA's involvement in the wildlife program.

236240 Qnor about 2 September 2009, we provided DEWHA with a draft of the Monitoring Plan. We I

requested that DEWHA and other interested departments enter into discussions to agree on the basis

on which we would enter into the plan.

Ð4241 lohn and I had a discussion on 7 September 2009 with representatives of DEWHA. This was to I

discuss what monitoring requirements would be required for both operational and scientific

monitoring. At the initial meeting we made it very clear that we would be providing the funding for

the monitoring programs.

?38242 Following that first meeting, John Wardrop developed a draft report proposing methodologies for I

conducting the Monitoring Plan.

89243 We understand that DEWHA had input into the plan from other agencies (being the DA; DEC; I

Western Australian Department of Fisheries (DoF); Northem Territory Department of Natural

Resources, Environment, the Arts and Sport and Northern Territory Parks and Wildlife

(NTDNRTEAS); DRET; AMSA; Australian Fisheries Management Authoriry (AFMA);


53

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Commonwealth Scientific and lndustrial Research Organisation (CSIRO) and Australian lnstitute ofMarine Science (AIMS)).

48244 Following DEWHA obtaining that input, John Wardrop, Eleanor Stoney (the pTTEp HSE Co-

ordinator) and I went to a meeting on l6 September 2009 with Tania Rishniw, Chantelle Simakov-

Ellen and Glen Ewers to discuss how the Monitoring Plan was going to operate, and to get

DEWHA's comments on the plan. DEWHA were mostly concerned about the fauna that were being

impacted.

244245 Immediately following this meeting, we met with AMSA to discuss the progress of the response.

Æ246 Belween 24 to 2ó September 2009, there was correspondence with DEWHA in relation to the

proposed Monitoring Plan and the basis on which this would be undertaken.

4t247 On 2 October 2009, we held a teleconference with DEWHA to discuss the draft Monitoring plan,

44248 On ó October 2009, Eleanor Stoney, John Wardrop ,Benita Ross a PTTEp Australasia Legal

Advisor and I met with DEWHA and AMSA in relation to the Monitoring Plan, including to finalise

the terms of the Monitoring Plan documents and to agree the memorandum of understanding

supporting the Monitoring Plan

M5249 the meetings we had in relation to developing the Monitoring Plan were with DEWHA. The only

other meeting we had was with the DoF, which DEWHA set up and came over for and we had

NTDRDPIFR on the phone on l4 October 2009. At that meeting DoF provided a presentation on

their fisheries, namely the Northern Demersal Scalefish Fishery. They discussed possible

monitoring, focussing on the work that DoF was already undertaking with particular emphasis on

recruitment.

46250 lt was DEWHA's recommendation that it would be appropriate to meet with the DoF in order to

clarify DoF's concems with regard to the monitoring program. Rather than DEWHA being the

interface it was decided it would be better to have that face to face meeting with them to discuss the

proposals about the Monitoring plan.

244251 Qther than that it was agreed that DEWHA would be the interface with the other authorities.

14&252 On 9 October 2009, and a Memorandum of Understanding was entered into with DEWHA,

incorporating the fìnalised Monitoring Plan and covering the operational and scientific monitoring

studies and the process for implementing such.

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249253 lt took us, DEWHA and AMSA approximately seven weeks to finalise the Monitoring plan as there

were extensive discussions as to the content of the plan, including as to key components to be

included in the plan, the studies to be conducted and key processes and triggers. DEWHA and other

government agencies (outlined below) were concerned with ensuring that the plan was rigorous but

proportionate' would withstand professional scrutiny and contains a clear reporting framework.

Many drafts of the Monitoring Plan, the Memorandum of Understanding for the Monitoring plan,

and of scientific monitoring study proposals passed between us and DEWHA as we worked through

these issues. However the operational monitoring was ongoing during this period under AMSA's

control, and this was required prior to the scientiñc monitoring being triggered.

#8254 ln addition, in developing the Monitoring Plan, independent expert advice in relation to the matters

outlined above was sought by the Australian Government from Commonwealth, State and Territory

agencies and organisations, including AIMS, CSIRO, AFMA, Northern Territory Department ofNatural Resources, Environment, the Arts and Sport, the NTDRDPIFR, Northern Tenitory parks and

Wildlife; western Australia Department of Fisheries and the DEC. This added to the time taken to

finalise the Monitoring Plan.

25+255 Both prior to and after the Monitoring Plan was finalised we engaged in regular and continuous

communications with DEWHA:

as to the content ofthe plan; and

as to developments and operations under the plan, including in relation to the triggers for the

scientific monitoring studies. In my view, there has been adequate communication between

us' DEWHA and AMSA in relation to this issue (and other issues related to the Monitoring

Plan)' Throughout the process, I believe scientific monitoring studies have been designed

and commissioned in a timely manner as required by section 2.4.2 of the Monitoring plan.

There has not been any negative impact on the design and commission ofstudies by us due

to inadequate communications between us, DEWHA and AMSA.

82256 ln summary, we have been in constant communication with DEWHA and AMSA in relation to all 'laspects of the Monitoring Plan since it was first proposed, for example:

(a) on l4 october 2009, we met in Perth with DEWHA and the DoF, to brief them on

developments and the Monitoring Plan;

(a)

(b)


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(b) on or about 13 November 2009, we gave a presentation to DEWHA in relation to the

Monitoring Plan, in relation to various studies, surveys or assessments that had been

conducted or would potentially be conducted;

(c) on l8 November 2009,26 November 2009 and 24 February 2010 we met with DEWHA to:

(i) update them in relation to the scientific monitoring;

(ii) discuss release offinal monitoring reports;

(iii) discussoperationalmonitoring;and

(iv) discusslndonesianmonitoring.

?f,É2j./--llnrelated to the Moniûoring Plan, on 7 September 2009, we notified DEWHA of the death of various''l - -

marine fauna in accordance with the Drilling Environment Plan, Jabiru Field Environment Plan, and

rhe EPBC Act.

æ4258 The following studies that comprise the Operational Monitoring Programme in accordance with the I

National Plan were required:

o Monitoring of Oil Distribution and Marine and Coastal Resources (Study Ol);

. Monitoring of Oil Character Fate and Effects (Study O2);

o Shoreline Assessmcnt Ground Surveys (Study O3);

o Monitoring of Dispersant EfÏiciency and fate of Dispersed Oil (Study O4); and

¡ Wildlife Impact Monitoring (Study O5).

85259 Operational Monitoring was under AMSA control. We agreed the operational monitoring proerams ''l - -

with DEWHA, with AMSA being made aware of what was being agreed. Basically it was AMSA's

role to conduct the operational monitoring.

?56260 Weaided AMSA in this regard. On 9 September 2009, we assured AMSA that all our facilities had I

been told ûo report any oiled, distressed, or dead animals and that we would not condone any failure

to report.


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Æ1261 In relation to key areas near the Uncontrolled Release that clearly had not been immediately

impacted, surveys were undertaken as part ofthe Monitoring Plan, being shoreline and ground

surveys and environmental assessments and sampling. These included:

shore line surveys on Ashmore Cartier Islands (carried out in October/November). A

shoreline assessment team arrived at Ashmore Reef on 22 Qctober 2009 to undertake

baseline surveys of the Ashmore Cartier Islands. DEWHA personnel and an expert from

Geoscience Australia participated in the assessment. No visual evidence of oil was found

during the shoreline and ground surveys of Ashmore Reef and Cartier and Hibernia Islands

following the spill. The team are to conduct a second shoreline survey as a result ofwax

being discovered on Ashmore after the fìrst survey was conducted'+he+eam+vas+ehedded

aU:t¡ty ef ævernm*

;

Browse Island Survey (canied out in December). In addition, prior to this date, on l4

November 2009, DEC officer Marissa Speirs and the crew of MV Sea Spnnl / conducted a

general survey of Browse Island and surrounding waters. The aim of the survey was to

assess whether Browse Island had been affected by the oil spill. Some dead animals were

located although their death did not appear to be as a result of coming into contact with oil.

also at approximately 20 sites on the Kimberley coastline between Darwin and Broome

(canied out in November); and

closeout shore line surveys on Ashmore Cartier and Browse Islands (canied out in February

2010). Personnel from Leeder Consulting, DEWHA and an expert from Ceoscience

Australia participated in the assessment.

25&262 Prior to I 7 October 2009, we engaged a consulting group to obtain and analyse samples of 'lsubstances thought to be foam, not oil, as part of the environmental monitoring of the effect of oil

spill.

?59263 Wax was reported in the Ashmore Island lagoon on one day, but it was not there the next day. Wax I

forms as a residual left from hydrocarbons after the other components have evaporated or disbursed.

The Montara oil has a high paraffin content and relatively low toxicity. Residual wax is largely a

visual rather than a biological problem.

42@Some monitoring was also carried out by DEWHA using resources provided by us for the wildlife

response.

(a)

(b)

(c)

(d)


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41265 ln addition, the ERG was used to coordinate vessels and aircraft to support all environmental

response activities.

#266 Theresults of the operational monitoring are considered by PTTEPAA and DEWHA to determine

whether triggers for the scientific monitoring have actually been achieved and whether or not we

should be undertaking scientific monitoring. It also feeds into how and where the scientific

monitoring should be conducted.

4t267 Thewildlife monitoring conducted identified that there were:

(a) Seabirds - 29 oil affected birds, 2l deceased;

(b) Sea snakes - 2 deceased sea snakeg,

these sea snakes died due to exposure to hydrocarbons; and

(c) Turtles - There were no visible signs ofexposure to oil or loss ofcondition from a turtle

carcass recovered from Ashmore Island.

of hydrocarbon exoosure.

2&268 Theagreed scientific monitoring programme comprises the following studies:

¡ Marine Megafauna Aerial Assessment Surveys (Study Sl);

o Shoreline Ecological Assessment Aerial Surveys (Study S2);

¡ Assessment ofFish Catch for the Presence ofOil (Study S3);

¡ Assessment of Current Effects on Timor Sea Fish and Fisheries (short term - Study S4A);

¡ Assessment of Long Term Effects on Timor Sea Fish and Fisheries (Study S4B);

o Offshore Banks Assessment Survey (Study S5);

¡ Shoreline Ecological Ground Surveys(Study 56); and

o Oil Fate and Effects Assessment (Study S7).

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%5269 We proposed the triggers for the scientific monitoring to DEWHA based on advice we received nom ''lJohn Wardrop and DEWHA agreed to them. How the triggers were established is set out in

PTTEPAA's submissions to the Commission on term of reference 7.

2é6270 the PTTEPAA HSE Co-ordinator is producing a regular update for the company about the progress

of the Monitoring Plan and based on that we will have individual discussions with her or John

Wardrop as are deemed fit.

*7271 ln relation to the process undertaken by us in calling for, assessing and approving scientifìc

monitoring proposals under the Monitoring Plan, all the scientific monitoring is contracted by us. We

contacted and liaised with various organisations with the necessary/required expertise, as agreed with

DEWHA, in relation to preparing proposals for the various studies. They would then provide us with

the proposals. Once we were comfortable that a particular proposal addressed the requirements for

the study, we would then provide it to DEWHA for approval, after completion of the study the final

report will rrhish+hey-+ver+lC become publicly available on the DEWHA website.

?é8.272 All experts engaged to conduct the environmental monitoring have been approved by DEWHA. In a

confidential appendix to the Memorandum of Understanding there is a list of parties agreed with

DEWHA with input from the various States and departments, which was not included in the publicly

released monitoring plan because PTTEPAA and DEWHA did not think doing so would be

beneficial.

W273 A very broad range of parties was agreed with DEWHA so that experts in many areas are available to

help design and implement operational and scientific monitoring studies, to interpret and comment

on results. Appropriate experts from this list were involved throughout the design, and

implementation of all studies.

?J4274 The List of Available Experts means that we know who DEWHA thinks is appropriate to carry out

the scientifìc studies that form part of the Monitoring Plan and it also means that it is a much quicker

and easier process for us to get the studies up and running,

*71275 ln some areas ofthe Monitoring Plan, we have provided the resources such as vessels and in other

areas we have just contracted with the expert and they are providing resources such as vessels and

helicopters; it depends on the particular organisation.

272276 The initial results of the monitoring will determine, or provide input into, decisions about the length

of monitoring and frequency of monitoring for certain items. Some of the monitoring programs are

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baseline surveys such that should there be an impact then we have a baseline condition. Others, such

as the fisheries studies, will probably take five to seven years to conclude.

L73277 we give a copy of the relevant study and Guidelines for Submission of study proposals to the Iexperts as a guide for preparing the proposal. The experts are then expected to detail the

methodology of the study and justify why that methodology is required based on their expertise.

?74278 The HSE Co-ordinator then reviews the proposals we receive with John Wardrop and discusses

which proposals are the most appropriate and requests any further information needed to decide who

is best qualified to conduct the study and asks for any required additional details on aspects of the

proposal.

775279 The selection ofthe best proposals is then finalised based on who can actually do the work in the

best manner, and prepare the required report.

?lé.280 lVe then send the finalised proposal to DEWHA for their review and approval. There is a panel ofother agencies which assist DEWHA with this review.

?9!,281 Once DEWHA has approved the proposal, we inform the successful expert and let the other

applicants know that their proposal was not successful.

77&282 The process of obtaining DEWHA's and the review panel's approval for each expert has been

designed to overcome any suggestion that PTTEPAA is selecting an expert because they have

connections with the company or because their proposal is less rigorous than other proposals.

179283 ln relation to the studies to be conducted under the Monitoring Plan, the following steps have been

taken to date in relation to each study:

Study Sl - Mørine Megafauna Aeríal Assessntent Surveys

28e284 This study has not been triggered.

Study 52 - Shorelíne Ecologícal Assessment Aeríal Surveys

284285 On 26 October 2009, PTTEPAA provided DEWHA with a proposal for scientific monitoring study .l -

52 and sought its approval of the proposal.

Æ286 On or shortly prior to 28 October 2009, study 52 was conditionally approved by DEWHA. The Imainland field work for Study 32 was completed by l g November 2009.

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283287 From 8 to I 8 November 2009, a baseline shoreline ecological assessment aerial survey was

conducted as part ofscientific monitoring study S2

284288 The 52 programme was conducted by Norm Duke from University of Queensland in December 2009.

æ5289 A preliminary report has been received and provided to DEWHA with the fìnal report expected in

mid March 2010. As of 29 March 2010 this reoort has not been received.

Study 53 - Assessment of Fìsh Catch þr the Presence of Oíl

46290 On l6 October 2009, PTTEPAA invited the DoF to submit proposals in relation to the collection of 'l - -

fish samples for Study 53.

N29l On 9 December 2009, PTTEPAA provided DEWHA with a proposal for scientific monitoring study

53 and sought its approval ofthe proposal.

*8292 Qn l0 December 2009, DEWHA approved our proposal for scientific monitoring study 53.

*9293 ln January 20 t 0, the 53 study was undertaken by the DoF. Specimens from various locations (non-

impacted and impacted) of key species were sampled and analysis is underway to determine the

hydrocarbon levels in the tissue and guts.

290294 Discussions are also underway with the DoF regarding the requirement for a taste/olfactory panel for

fïsh samples taken during field surveys for studies 53 and S4B.

Sttttly S4A - short tern Assessment of Efþcts on Tìmor Seø Físh and Fìsheries

Ð*295 On l5 October 2009, PTTEPAA provided DEWHA with a revised Scientific Monitoring Proeramme'-l - -

S4A proposal for its approval.

?94296 On l6 October 2009, PTTEPAA requested assistance from the DoF to identify an appropriate fishing

vessel from which study S4A could be canied out.

Ð?297 On 26 October 2009, DEWHA gave approval to us to undertake scientific monitoring program S4A

subject to incorporation ofa couple ofadditional items in the study.

Ð4298 O¡ 30 October 2009, PTTEPAA provided DEWHA with an updated programme for scientifìc

monitoring study 4A which incorporated the items contained in the 26 October 2009 approval.

Ð5299 From 6 to l9 November 2009, field work under scientific monitoring study S4A was conducted.



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UNCONTROLLED HVDROCARBON RELEASE

296300 The first sampling field trip was competed in December 2009 for study S4A. This programme was I

conducted by Associate Professor Monique Gagnon from Curtin University. A final report will be

finalised once analysis has been completed.

Ð7301 A second sampling field trip conducted by Associate Professor Monique Gagnon is scheduled to I

commence early March 2010.

298The final report from the first sampling trip is expected in mid-March 2010. As of 29 March 2010 this '1-report has not been received. I

I

Study S4B - long term Assessment ol EÍÍects on Tinor Seø Físh and Físheríes

Ð9302 On 12 October 2009, PTTEPAA met with various fisheries departments separately, and then had a 'l - -

joint meeting with the departments on I 3 October 2009, to discuss the S4B assessment of the long-

term effects of the oil spill on the Timor Sea fish and fisheries, including the justification for

monitoring proposals (such as determining the impact on plankton and bethnic communities) and the

methodology to be used.

300303 On l6 October 2009, PTTEPAA invited the DoF to submit proposals in relation to Study S4B under

the Monitoring Plan.

3e+304 PTTEPAA received a DoF proposal in relation to the study on 25 October 2009.

3e?305 PTTEPAA are in the process of speaking with other potential entities who may be suitable to

conduct this study.

Study 55 - Olfshore Banks Assessntent Survey

303306 Study 55 has not been triggered at this point oftime.

304307 PTTEPAA received an expression ofinterest in conducting this study from the Australian Institute

ofMarine Science on l3 October 2009,a first proposal on 20 October 2009 and a further proposal

on 27 October 2009.

Study 56 - Shorelíne Ecological Ground Surveys

3e5308 To date only the baseline for mainland, sea birds, sea snakes, turtles and corals (Ashmore and Cartier'-l

only) for this study has been triggered.



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306309 On 26 October 2009, PTTEPAA provided DEWHA with a proposal for scientific monitoring study

56 and sought their approval ofthe proposal.

3073 l0 On or shortly prior to 28 October 2009, study 56 was conditionally approved by DEWHA.

3e831 I PTTEPAA together with John Wardrop has reviewed the six tender submissions for Study 56 with

particular focus on sea birds, sea snakes, corals and turtles. These proposals were be submitted to

DEWHA for approval on I March 2010.

308-PTTEPAA is awaiting DEWHA approval for the studies. Subject to DEWHA approval being

granted it is estimated that field work on these studies will commence in late March 2010. As of 29

March 20 I 0 this report has not been received.

Study 57 - O¡l Fate and EÍÍects Assessment

3-l€3 l2 Three sub studies have been approved by the DEWHA under programme 57. These studies have '1been assigned to Asia Pacific ASA.

3{*3 l3 Study 7.1 - Trajectory Analysis, will integrate all the essential oil observation and modelling

information into a consistent overview of oil location and movement over time for use in the spill

impact damage assessment. A draft of a report for this study has just been received and is in the

process of being reviewed by PTTEPAA and its environmental consultant and will shortly be

provided to DEWHA.

3{43 l4 Study 7.2 - Modelling of Sediment Fall out Plume. Output from this study will determine the likely

area of deposition of sediments released during the well release. Output from this study will be used

to assess the need for sediment sampling programme and the distribution of sampling sites.

3t33 I 5 Study 7.3 - Modelling of Dispersed Oil Distribution and Effects , will determine the concentration

and movement of submerged oil in the Timor Sea to quantify possible environmental exposure to

sunounding habitats such as submerged shoals surrounding the WHP.

3{43 I 6 Contracts for each of these sub-studies have been finalised and work has commenced.

3153 I 7 Under study S7, there is further work being conducted by Leeder Consulting which analyses any

water/biological/sediment samples that have been taken under other programmes. For example, the

biological/water and sediment samples taken by Norm Duke are being analysed under S7 by Leeder

Consulting.


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Environmental Monitoring in Indonesia

3-1-63 l8 From9to 12November2009,DEWHA,DFAT,DRETandAMSAmetwithlndonesian '-l --

Govemment officials to provide a briefing on the oil spill, Australia's response efforts,

environmental monitoring and the mandate of Commission of Inquiry. AMSA also discussed with us

the refunding ofcosts incurred by the Australian Government in undertaking aerial surveillance and

shoreline assessments of Indonesian waters and coasts. During this period, information obtained by

us from the ongoing monitoring of and clean up of oil, in conjunction with the DFAT and AMSA,

indicated surface oil was located approximately 200 kms from the Indonesian coastline.

$173 I 9 Some monitoring of the potential environmental impact may be conducted in Indonesia. The I

Australian Government, primarily DEWHA with DFAT and AMSA has been attempting to co-

ordinate with the Indonesian government.

3t8320 On I September 2009, satellite imagery showed that small patches of weathered oil had crossed into I

Indonesia's EEZ and over flights were conducted which confirmed patches of weathered oil and

sheen within theEEZ, closing to some 5l nautical miles south east of the Indonesia island of Palau

Roti on 2l September 2009.

3-14321 Consequently, any sampling would be along the West Timor coastline and the island of Palau Roti to I

determine the potential impact to those areas. As at 24 November 2009, the lndonesian Government

and the Australian Embassy in Jakarta were discussing the carrying out of a shoreline survey of West

Timor and Roti, however to date there has been no response from Indonesia on this.

3æ322 A letter has been sent by DFAT via the Australian Embassy in Jakarta on the basis of that Australia I

was willing to carry out such a survey and I believe asking for details ofthe resources and costs of

the Indonesian parties. To date there has been no formal response from Indonesia to this letter.

34t323 Where the samples are to be tested is a detail to be agreed. Our preference is for the samples to be I

brought back to Australia. We met with DEWHA, DFAT and AMSA on 26 November 2009 who

suggested that they should work with AQIS to ensure that samples could be brought into the country

appropriately. The proposal is to test water, sediment, seaweed and fish.

92324 the purpose is really to identify whether or not there has been any Montara oil impact along that area I

that may trigger the need for any other Monitoring Plan studies.

39F325 ln this regard you can fìngerprint the oil to identify the constituents and identify if it is Montara oil as I

opposed to heavy fuel oil or something from a passing ship.

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Comment

3?y'326 PTTEPAA has involved all of the relevant government departments and has been advised by a highly'-l - -

qualified expert in developing the monitoring plan, as a result, t am ofthe opinion, that the

Monitoring Plan for Uncontrolled Release and the course of its development is entirely appropriate.

I understand that a person who intentionally makes a false statement in a statutory declaration is guilty ofan

offenceundersection lloftheStatuøryDeclarationsActlg5g(Cth),andlbelievethatthestatementsin

this declaration are true in every particular.

Andrew Charles Jacob

Declared at Peftheanbena the day of March 2010

Signature of person before whom the declaration is made

Full name, qualification and address ofperson before whom the declaration is made

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