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Letter to Admiral Allen, Lamar McKay on "Bullhead Kill" technique

The signed PDF version of the letter is also available HERE.

July 20, 2010

Admiral Thad W. Allen
National Incident Commander
United States Coast Guard
2100 Second Street, SW Stop 7101
Washington, DC 20593-7101

Mr. Lamar McKay
President and CEO
BP America, Inc.
501 Westlake Park Boulevard
Houston, Texas 77079

Dear Admiral Allen and Mr. McKay:

In recent weeks, BP and Coast Guard officials have maintained that the relief wells were the ultimate solution to kill the Deepwater Horizon/Macondo well. However, in recent days, BP’s Kent Wells said that the company is now considering an additional technique, known as a “bullhead kill.” This procedure has been described as similar to the “top kill” in which mud is introduced at the blowout preventer, but may benefit from the current static (no flow) condition and lower-than-expected pressure of the well. We all want a quick resolution to this disaster, but we must be assured that proposed solutions will not make the situation any worse.

At the same time, the low pressure that may make a bullhead kill a more viable procedure is also at the center of an ongoing scientific assessment regarding well integrity. While the well pressure has been building steadily since the integrity test was initiated, the current pressure (just over 6800 psi) remains lower than initially expected. Scientists and engineers continue to evaluate whether the low pressure is due to a lack of well integrity, depletion of oil and gas, or some combination of the two. It is critical that we understand the implications of a bullhead kill attempt under the various scenarios that may be operating in the well.

In addition, I remain concerned that we may not conduct a flow rate test. I hope that Unified Command is continuing to explore a method that could continue to prevent a significant amount of oil from spilling into the Gulf, while providing a more precise measurement of the flow rate of the spill. A more precise measurement of that flow rate, even done this long after the start of the spill, would provide greater understanding of the flow rate and depletion of the reservoir and the extent of environmental damage over the course of this catastrophe. Obtaining answers to these questions is important in assessing BP’s full legal liability for its actions.

In order to better understand this situation, I would ask you to respond to the following questions immediately:

  1. If the well integrity has been compromised, what are the potential implications of attempting a bullhead kill procedure?
  2. What additional risks are undertaken with the bullhead kill compared to the alternatives (i.e., a return to containment using production platforms at the sea surface or a continuation of the integrity test conditions)? 
  3. Under what conditions (e.g., pressure threshold) would the choke and kill lines used in the bullhead kill be at risk of damage?
  4. Could forcing the hydrocarbons back into the reservoir through the bullhead kill procedure cause damage that could make the bottom kill more challenging or exacerbate any seeps that may be present?
  5. If hydrocarbons are flowing in the annulus, will this decrease the chances of the success of the bullhead kill?
  6. Would a bullhead kill attempt slow progress on the bottom kill in preparation?
  7. Under what conditions and on what timeline will a bullhead kill be authorized by Unified Command and pursued by BP? Once initiated, how long is the bullhead kill anticipated to take?
  8. Would the bullhead kill also kill off any chance of conducting a 100 percent collection strategy?

Thank you very much for your attention to this important matter. Please provide your response immediately and if you cannot respond in writing within the next 24 hours, please have your staff contact the Subcommittee staff or my staff to arrange a date upon which a full and complete response to the Subcommittee’s inquiry will be provided.   

       Edward J. Markey 
Subcommittee on Energy and Environment
Committee on Energy and Commerce    

Cc:  Honorable Henry Waxman, Chairman,
Committee on Energy and Commerce

 Honorable Joe Barton, Ranking Member
 Committee on Energy and Commerce
Honorable Fred Upton, Ranking Member,
Subcommittee on Energy and Environment 

The signed PDF version of the letter is also available HERE.

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