OSHA Inspection: EOG RESOURCES, INC.

Issued

Oct 7, 2010

Abate by

Nov 10, 2010

Penalty

Initial $3,000 · Current $3,000

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
employer did not
furnish employment and a place of employment which were free from
recognized hazards that
were causing or likely to cause death or serious physical harm to
employees in that employees
were exposed to potential injuries resulting from fires or explosions from
the uncontrolled
release of potentially volatile natural gas and other associated fluids:
A.) Punxsutawney Hunting Club 36H Well, Clearfield County, PA - on or
about June 3, 2010,
an uncontrolled release of natural gas and geological fluids occurred when
CC Forbes employees
were operating a double derrick work-oversite service rig (#130) while
preparing to change out
a damaged stripper head rubber.  The employees attempted to raise up the
collar for better
positioning while stripping up through the BOP rams.  The BOP rams are
designed to remain
in place to prevent pressure from escaping the well, they are not designed
for equipment to be
pulled or "stripped" up through as this would jeopardize the integrity of
the
seal.  As the
employees were stripping up through the rams, the blowout occurred.
ABATEMENT NOTE:
Among other methods, one feasible and recognized method to prevent this
hazard identified in
Instance A.) is to ensure proper well control equipment is on site (a
snubbing unit, for example)
in accordance with the American Petroleum Institute Recommended Practice
54 Section
6.1.1, which states "Well control shall be maintained at all times.
Consideration shall be made
to ensure appropriate equipment and materials are on location and
operational before work
commences."
B.) Punxsutawney Hunting Club 36H Well, Clearfield County, PA - On or
about June 3, 2010,
and uncontrolled release of natural gas and geological fluids occurred
when employees were
operating a double derrick work-oversite service rig (#130).  The III
Model Number DR-25
Blowout Preventer in use at the time had not been tested to determine
serviceability.  The lack
of testing was evidenced by a lack of test result documentation.
ABATEMENT NOTE:
Among other methods, one feasible and recognized method to prevent this
hazard identified in
Instance B.) is to ensure compliance with American Petroleum Institute RP
54, Section 6.4.7,
which states "While in service, blowout prevention equipment should be
inspected daily and a
preventer actuation test should be performed on each round trip, but not
more than once per 24-
hour period.  Notation of actuation tests performed should be made on the
daily report.  Annular
blowout preventers should be tested in accordance with the manufacturer's
recommendations,"
and API RP 54 6.4.6, which states "Blowout preventer drills should be
conducted under a
variety of conditions."