WIT.1501.0001.0001
Commonwealth of Australia
Declaration under the Statutory Declarations Act 1959
I, David Leonard Gouldin, Operations Manager, 10 Hoe Chiang Road, 1811 Keppel Towers, Singapore
089315, make the following declaration under the Statutory Declarations Act 1959:
I,
I make this declaration in response to the request from the Montara Commission of Inquily
into the uncontrolled re lease of oi l and gas from the Montara Wellhead Platform (Montara
WHP) in the Timor Sea (the Commission) to provide ev idence in relation to specified areas
of interest relevant to the Commission's Terms of Reference. Attached hereto and marked
"DLGIA" is a copy of a document entitled "Schedule - Areas of Interest to the Inquily"
attac hed to the letter enclosing the witness summons served on me by the Commission .
2.
I am the Operations Manager, Asia-Pacific Business Unit for Seadri ll Limited and its
subs idiaries, based in Singapore.
3.
Seadrill Limited, of which Seadrill Management (S) Pte Ltd is a subsidiary, is an international
offshore drilling contractor providing services within drilling and well services. Unless
otherwise specified, in this declaration, a reference to "Seadrill" is a reference to the Seadrill
gro up of companies.
4.
Seadrill's fleet includes harsh-environment semi-submersibles, jack-ups, shallow and
deepwater tender rigs and deepwater drillships. In addition, Seadrill provides platform drilling,
well intervention and engineering services.
5.
Atlas Drilling (S) Pte Ltd (Atlas Drilling), a subsidiary of Sea drill Management (S) Pte Ltd, is
the registered owner and operator of the West Atlas MODU or "jack up".
6.
Atlas Drilling entered into a contract with PITEP Australasia (Ashmore Cartier) Pty Ltd
(PTTEPA) (forme rl y Coogee Resources Pty Ltd), the owner and operator of the Montara
WHP, to provide drilling and well services from the West Atlas jack up drilling rig (the West
Atlas).
Professional histol'Y and current responsibilities
7.
I have more than 30 years experience in the Oil and Gas industry special ising in offshore
drilling operations, primarily with mobile drilling units. I have worked in many jurisdictions
including the North Sea (UK and Norway), West Africa (Angola), South America (Brazil),
Mediterranean (Italy), Middle East (Saudi Arabia), Gulf of Mexico (US) and South East Asia
(China).
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8.
From I March 2009, I began to take over the role of Operations Manager for Seadrill in
Singapore. I was fully operational in that position from 21 March 2009. During the period I
to 21 March 2009, I was shadowing my predecessor in this role.
9.
Prior to I March 2009 I was based in Seadrill's head office in Norway. My experience prior to
that includes the following:
(a)
During 2005-2008, I acted as Operations Manager for Atlantis Deepwater, initially
in Norway and then in China.
(b)
Between 1995 and 2005 I worked for Smedvig ASA as a Rig Superintendent,
Operations Preparation Manager and Project Specialist.
(c)
Between 1993 and 1995 I was a Drilling Superintendent fiJr Nanhai West Drilling
Company.
(d)
Between 1989 and 1993 I was a Rig Superintendent for Smedvig ASA.
(e)
Between 1984 and 1989 I worked my way from Driller to Toolpusher to Offshore
Installation Manager for Dyvi Offshore on mobile drilling, units undertaking
offshore exploration drilling programmes Norwegian North Sea.
10.
As Operations Manager, [ am the line manager for each of the rig managers for Seadrill's jack
up drilling rigs in the Asia-Pacific Division of which there were 5, including the West Atlas
and the West Triton.
II.
My duties include coordinating the central supp0l1 function for rig managers as and when
required such as Health Safety and Environment (HSE), procurement, Human Resources,
technical and financial support. As line manager for the rig managers, [ become involved in
decisions concerning rig operations when those operations are out of the ordinary, where there
are safety issues or where there are prob lems with the relationship with the client operator to
whom the rigs are contracted. [ normally speak to each of the rig managers in my division on
a daily basis.
The well drilling and suspension operations conducted in relation to Moutara HI ST-I ou
or about 7 March 2009
12.
My knowledge of the operations conducted on the West Atlas and Montara WHP on 7 March
2009 is derived from a reading of the Seadrill Daily Operations 30 Hour Report for that day,
(attached and marked "DLG1"), discussions with and amongst various Seadrill personnel
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invol ved in the internal investigation into the uncontrolled release and is based on my own
experience in the offshore drilling industry.
13.
In March 2009, the West Atlas was follo wing the batch drilling program prepared by PTTEPA
for the drilling of 4 production and one gas injection wells at the Montara WHP (attached and
marked "DLGZ").
14.
On 7 March 2009 the operations concerned the setting of the cement casing shoe on the
244mm or 9 Yo" casing on well H I Cas detailed at point 5.23 205 of the batch drilling program page 38 to 39).
15.
The design and calculations for the cementing of the cas ing shoe on a well arc undertaken by
the client operator in conjunction with its specialist cementing contractor, in this case
I-Iall iburton.
16.
Facilitating the cementing activities requires Seadrill's personnel to n lll the 9 5/8" casing into
the well bore, following which they would set up the rig's circulation system at the top of the
casing, circulating the drilling fluid to keep the casing clean and clear. Once that has been
completed, the next action would be to set up the cementing contractor's circulation system.
17.
From this point onwards, Seadrill would not have any significant involvement in the
cementing process other than to comply with instructions in the cementing programme. The
actions taken by the cementing contractor are recorded in the rig's daily operations report for
information, but Seadrill does not record any of the detailed technical specifications.
18.
Where, as happened on this occasion, there was an apparent failure of the non-return valves,
the drilling supervisor and the cementing contractor on the rig would implement the
contingency plan in the drilling program or, where there was no such contingency pl an, consult
with one another to decide on the action that should be taken.
19.
Seadrill's Offshore Installation Manager (OIM) would ordinarily be inform ed of the decision
made by the drilling supervisor and the cementing contractor. The contingency plan would be
executed by the client operator and the cementing contractor.
Amendment to the Drilling Program to install Pressure Containing Corrosion Caps
(PCCC)
20.
My knowledge of the circumstances giving rise to the change in the drilling program to replace
the cement plug on H I with two pressure containing corrosion caps is derived from reading the
Well Construction Change Control Form dated II March 2009 Cattached and marked
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"DLG3"), discussions with the rig manager and from my own experience in the offshore
drilling industry.
21.
The formal requirements for controlling changes made to any drilling program typically
involve initiation of the change by the client's drilling superintendent "in town" (ie onshore)
based on information supplied by the client's drilling s upervisor who is on the platform.
22.
The proposed change is required to be approved by the client's Well Construction Manager
(also in town), following which it is circulated to a list of people concerned with the operations
of drilling the well. This typically includes the OIM on the rig and the Rig Manager in town
for the contractor drilling company, such as Seadrill.
23.
In practice that process, especially where it involves changes that carry additional risk, is more
consultative between client/operator and contractor drilling company.
24.
After the drilling supervisor and the drilling superintendent identify II proposed change, the
drilling supervisor would usually seek to discuss the change with the OIM and agree the best
way forward. The process would then be communicated to the Rig Manager and, if agreed, it
would be formally signed off by the Well Construction Manager and distributed. If the Rig
Manager has concerns about the change, then in my experience the Rig Manager will normally
involve the Operations Manager and a meeting would take place in town to work out the
problems. The intention behind this process is to explore all the options and make a decision
as to the best method to proceed.
25.
This procedure works in practice because the Rig Manager and the Drilling Superintendent
andl or Well Construction Manager meet on a daily basis and arc in frequent telephone or e­
mail contact.
26.
There are clearly circumstances in which agreement on the change is req uired urgently and in
such cases, discussions by telephone between the persons concerned may result in an agreed
change which is carried out while the formal documentation is completed subsequently.
27.
In my view, the informal consultative process can be the most effective as it a llows for a better
consideration of all the options available. It has been my experience that sometimes those
further removed from the action taking place on the ri g are able to take a wider look at what is
being proposed and come up with a more balanced option.
Bal'l'iel's at the point of snspension
28.
My knowledge of the barriers in place at the point of suspension of well HI ST-I is based on a
review of the batch drilling program (Rev 2) dated 6 January 2009 (attached and marked
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"DLG4") (January Program), the Well Construction Change Control Form dated II March
2009 (attached and marked "DLGS") (Change Control Form) and the information gathered
by the internal investigation into the uncontrolled release.
29.
The January Program suspension plan for H I called for a cement plug to be set in the 9 Yo"
casing in add ition to the cement casing shoe. Both of these barriers could be pressure tested.
In additi on, the cement plug would remain in the bore, regardless of the activities at the
surface, until a blowout preventer (BOP) was installed on the casing and the plug was drilled
out to make the well ready for production.
30.
In my view, the best practice on suspension would be to have a proven, pressure tested cement
casing shoe and at least one pressure tested cement plug inside the 9 Yo" casing.
3 I.
There is no reason to suggest that PCCCs would not work in thi s instance and, in fact , it would
appear to me that the PCCC on the 9 Yo" casing did what it was required to do and kept the
well in balance during the period of its suspension. However, the cap was never press ure
tested although the design allowed for such a possibility. Had such a test been undertaken, it is
possible the poor integrity at the casing shoe would have become apparent at that time.
19-21 August 2009
32.
My knowl edge of the operations conducted on between 19-2 I August 2009 is derived from a
read ing of the Seadrill Daily Operations 30 Hour Reports over that period (attached and
marked "DLG6", "DLG7", and "DLG8"), the PTTEPA forward plan (attached and marked
"DLG9 " ) and supplementary forward plan (attached "DLGIO") and repOlis from the internal
investi gation into the uncontrolled release.
33.
The events of 19 August 2009 were mainly concerned with the last part of the journey of West
Atlas back to the Montara WHP and preparations to commence the tie-back and completion
program. I consider that those activities are irrelevant to the uncontrolled release.
34.
On 20 August 2009, after the 20" trash cap was removed on well HI , it was discovered that the
13 Yo " PCCC was miss ing. In my view this discovery amounted to a deviation from the
drilling program which should have been reported to town (i.e. to the personnel on shore) by
both PTTEPA and Seadrill ri g personnel. Based on my discussions with Donald Millar, the
Rig Manager for the West Atlas, I believe that the miss ing cap was not reported to him when
the discovery was made or at any time before the uncontrolled release commenced.
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35.
The absence of the 13 Ys" PCCC had reportedly allowed the threads o n the 13 Ys" casing to
corrode in the 6 months since the well had been sus pended. I do not know the extent of the
corrosion as no photographs we re take n.
36 .
I believe, based on information I have received from the internal investigati on into the
uncontrolled release, that PTTEPA's Senior Drilling Supervisor, in discussion with PTTEPA's
Well Construction Manage r (who was a lso on the rig at the time), amended the daily work
instru ctions to allow the rem oval of the 9 lis" cap in order to clean the threads on the 13 3/8 "
casing with the appropriate brush tool. T he Seadrill crew complied with this instruction
apparently without question.
37 .
I can understand the logic of wanting to clean the threads on the 13 Ys" casing. If they had
waited until they were ready to tie back the 13 Ys" casing, they would have already tied back
the 20" casing.
38 .
However, the removal of the 9 lis" PCCC at this time amounted to a significant deviation from
the drilling program which resulted in a production well being cont ro lled by only an untested
cement casing shoe and the column of flui d in the bore.
39.
I refer to my description of the formal and in-practice management of change process out lined
at paragraphs 20 to 26 above. Donald Millar was not informed of the decision to remove the 9
lI," PCCC by either PTTEPA or Seadrill personnel before the supplementary forward program
was carried out.
40.
I understand from the statements that have been given by the personnel who were on board the
rig at the time that observations were taken and gas detector readings we re performed before
and after the cap was removed. The pressure under the cap was recorded through the drill
stand pipe before the cap was removed and there was no positive reading.
41.
I appreciate that it was necessary to remove the PCCC in order to run the brush. This would
have been the case at any point at which this wo rk was performed due to the nature of the
eq uipment. However, the drilling program called for the ri g to skid away to the next we ll after
the tie back of the 20". Given that the ri g would be engaged on the o ther wells carrying out tie
back of the 20" and 13 Ys" before it came back to well H I, I wou ld not have chosen to have the
PCCC come off and remain off afte r the ri g had skidded away.
42.
I consider that the supplementary fo rward plan should, as a minimum , have called for the
PCCC to be reinstalled after the brush was run. In my view, re-installing the cap after cleaning
the threads would have re-established control of the well and most likely have prevented the
uncontrolled release.
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Whether Seadrill voiced
43.
01'
raised concerns about drilling
01'
suspension operations
r would not norm ally expect Seadrill personnel to ques tion the operator or cementing
contractor as to whether they had carried out the cementation job co rrectly, pumped the ri g ht
amount of fluid back or whether their compressibility calculations were correct. Accordingly,
r do not necessaril y co nsider there to be anything wrong with the fact that there is no report of
Seadrill having raised concerns about this aspect of the suspension operations.
44.
According to the tie-back and completion program (attached and marked "DLG! !") (June
Program), the 13 lis" cap was supposed to have been installed off-line. By that I mean that the
rig would have sk idded away to the next well and these activities would be carried out away
from the critical path.
45.
No one at Seadrill r have spo ken to about the activities on the West Atlas on or about 7 March
2009 was aware that the 13 lis" PCCC had not been installed. There is, therefore, no record of
this having been a point of concern raised by Seadrill.
46.
There is no record of any concerns being raised by Seadrill personnel during the activities
conducted on the ri g between 19 and 2 r August 2009.
Failures of communicatiou between PTTEPA and Seadl'i11leading to the 13 %" PCCC not
being installed
47.
The Change Control Form was not prepared until after the point at which the PCCCs were or
should have been installed on well HI.
48.
There is no reference in the Change Control Form to the method by which the 13 lis" PCCC
should have been installed, but the June Program indicates that it was thought to have been
done as an offline activity.
49.
Offline activities are conducted away from the critical path. The rig is engaged in activities on
the critical path, so in the case of the offline installation of a PCCC, t his would take place after
the rig has skidded away to the next well.
50.
For tasks such as the installat ion of the cap, it is most likely that the physical labour would
have been provided by roughnecks (labour contractors to Seadrill) and s upervised by PTTEPA .
5 1.
Operators have to s ign their own reports, so invariably the drilling supervisors witness all
milestones such as the finin g ofa PCCc. Particularly in this case whe re they were working on
a production well, it would be very rare for anything to happen on a prod uction well without
the direct supervision of the operator.
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52.
UnfOltunately, I have not spoken to anyone who could tell me conclusively why the 13 lI,"
PCCC was not installed. Given that fact, it seems that there has been miscommunication of
some kind. Whether that led to the cap not being installed or not, I cannot say.
Failures in communication that led to the uncontrolled rcleasc - PTTEPA and Seadl'ill
53.
I think that it is fair to say that there were failures of communication that contributed to the
uncontrolled release:
(a)
The fact that the June Program indicated that the 13 Ys" PCCC had been installed
when that was not correct;
(b)
The fact that there was no detailed review of the problems experienced in
cementing the casing shoe on H I in the June Program;
(c)
The fact that there was no pre-spud meeting prior to the commencement of the tie­
back operations; and
(d)
The lack of communication to the Rig Manager about the missing 13 lI," PCCC and
the decision to remove the 9 lis" PCCC in order to clean the threads on the 13 lI,"
casing.
Failurcs in communication that led to the uncontrolled release - PTTEPA and Halliburton
54.
I have no knowledge of communications between PTTEPA and Hall ibUlton and as such cannot
comment as to whether there were any failures in communication between them that led to the
uncontrolled release.
Failures in comlllunication and/or supel"Vision/ovcrsight/quality conll'ol within PTTEPA
that conll'ibuted to the uncontrolled rclease
55.
In my view, the uncontrolled release would most likely have been avoided if the 9 lis" PCCC
had been put back on after the brush run to clean the threads on the 13 lI," casing. This step
was not included on the supplementary forward plan.
56.
With the benefit of hindsight, one possible explanation for that omission may be that the
normal lines of communication regarding changes to the drilling program were disconnected
due to the presence of the Well Construction Manager on the rig at the time.
57.
Normally, the Well Construction Manager would give the final approval to any changes.
However, as he was on the rig at the time, he was involved in the initial discuss ions about what
should be done. I think that disruption to the usual process might have resulted in the OIM
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being left out of the discuss ions, which in turn meant that the Rig Manager was not informed
of the change.
58.
In addition to the problems with the communication between PTTEPA and Seadrill, the OIM,
within Seadrill , should have checked with the Rig Manager that he had been consulted about
the proposed change to the forward plan. If the OIM was not on duty then the tool pusher or
whoever was in charge should have told the OIM who shou ld then have sought to confirm that
the Rig Manager had been made aware.
I understand that a person who intentionally makes a false statement in a statutory declaration is
guilty of an offence under section 11 of the Statutory Declaration s Act 1959, and I believe that
the statements in thi s declaration are true in every particular.
day of February 20 I O.
Before me:
Signatllrc of person before who
the declaration is
Maurice Oon
I
rl 2 0 09 /0 16 5
1 Apr 20\19 - 31 f,l,u 20 10
•
Full name, qualification and address of perSOil before
who m the declaration is made
MAURICE OON
NOTARY PUBLIC
20 MuxVlo il Road, #03.01F
MaxwoJ! House , Singapore 069 11 3
H P: 9696 0096
N o ta ry. co m .sg
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