Is Offshore Oil Drilling Truly Safe?

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In summary, an explosion at a drilling rig off the coast of Louisiana has created a large oil spill. It is still unclear how the spill will be stopped, and the safety of the workers is still a concern.
  • #666
BP is such a large corp I highly doubt anything bad will happen to them over this.
 
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  • #667
magpies said:
BP is such a large corp I highly doubt anything bad will happen to them over this.

It already is...stock is down 50%...public approval is near 0, likely to cost several billions of dollars for the cleanup/lawsuits/fines...

CS
 
  • #668
Geigerclick said:
Unless a single failure represents damage too great to be borne. I don't think that's the case here, but until the environmental fallout can be assessed, it's a (forgive the pun) platform like any other.

The methods and practices used by the industry are safe. If one company violates those practices then it is unsafe...not the industry.

CS
 
  • #669
Russ has basically answered everything that I would have, but I though I'd mention a few things...

Ivan Seeking said:
First and foremost, the victims of this spill, like you, should quit making excuses for a company that may have literally killed the entire gulf of Mexico.

I'm not making excuses for anybody, I'm simply trying to stay rational and away from the "regulate them to death!" mentality which wouldn't solve anything. As Russ has already pointed out it was the ENFORCEMENT of existing regulations that were the problem (much like the border situation we are faced with).

Ivan Seeking said:
So the deep-drillling ban should continue at least until a method to handle a disaster like this one, is clearly demonstrated. Next, put the Republicans and their deregulation hysteria to bed, once and for all.

I agree that we shouldn't think we are dependent on deep-water drilling, we have much better solutions available to us on land in the country! take for example, the Alaskan National Petroleum Reserve.

Ivan Seeking said:
It is more clear than ever that heavy regulation of this industry is required. Clearly, when BP signs a contract making promises, it means nothing.

It seems to me that the government's "promise" of enforcing existing regulation holds little more water than BP. The problem is we need regulation for the regulators! but then who will regulate the regulators of the regulators?

Ivan Seeking said:
When enviromentalists tell us a danger exists, instead of putting on the blinders and calling them tree huggers, instead of turning up the nose and accusing them of fear-mongering, shut up and listen. Then take the appropriate action.

The environmentalists have to prove that the danger actually exists first! You're saying we should just accept that the environmentalists are right, and act upon their fears (correct or not) without quesioning their validity first. This is a problem we're running into with "global warming" as well- taking action wihout definitive proof that the problem exists or that the proposed "fix" with actually fix it.

Ivan Seeking said:
A relief well drilled in parallel with the original well, as is required in Norway and Canada, could have prevented this nightmare.

Actually that's no guarantee since if both blowout preventers were in equal states of disrepair we'd have a leak that was twice as big as now. If we simply required the blowout preventer to function properly we wouldn't be in this mess right now... oh wait that's already required by regulation! And what would you say if both wells failed simultaneously? We should have seen it coming? More regulation requiring 3 wells to be drilled simultaneously? Where does it end, and at what point do you look at the tradeoffs and decide "that's safe enough?"

The difference between 99% safe and 100% safe is infinity when you're always only dividing the difference by two...
 
  • #670
Well imo I wouldn't trade a forest for a parking lot and that's basically what this comes down to. Do we want more parking lots and how many forests are we willing to give up for it.
 
  • #671
Oh I was more speaking to the point about how much risk can we afford. To me it isn't really about risk but more about how many wendy's and mcdonalds with fun play areas we want. As a race of course.

I mean look at what good a couple trees in a forest do for the Earth in total and compare that to what a mcdonalds does for the Earth in total. The trees protect the soil and make clean air while the mcdonalds does the opposite.
 
  • #672
Geigerclick said:
I am of the opinion that I've provided sufficient evidence,
Sufficient evidence for what? I.e., I'm suggesting your post will clearer if you state your thesis completely.
[...]
If the end result is a poor record for BP, that is what we are discussing.
'Poor' doesn't aid the discussion much unless it is done in context.
 
  • #673
Man I remember when this thread was only 4 pages in now its 44 wow...
 
  • #674
russ_watters said:
By now, most of the important facts of what led-up to the disaster are pretty well known. There were multiple failures at multiple levels by multiple companies, and if anyone of several failures hadn't happened, we wouldn't be in the mess we are in today. What that tells us in answer to the questions above:

1. Yes, the "prevent" instead of reacting after the fact approach is reasonable, but it requires that the "prevent" approach is being faithfully followed. This is where (2) regulation comes in.
2. It failed because employees of the companies involved cut corners and there was inadequate regulation (enforcement) in place to catch the corner-cutting.
I'm sorry, but if you built a LWR without the ability to kill the reaction, who would accept "we're learning as we go" as an excuse?
Invalid analogy, since what you are describing for a LWR is exactly the approach taken here. You want to prevent a meltdown, not deal with it after it has already happened, just like you want to prevent a blowout, not deal with it after it has already happened.
There are a lot of good points in this post, but I'll focus on the one's I quoted.

It's not clear to me who cut corners. I've only heard bits and pieces, sound bites, and contradictory testimony. I've heard that a BP manager over-ruled a Haliburton or Transocean engineer with respect to the plugging and drill string cover - I don't know who to believe.

Somebody made the decision to replace drilling mud with seawater - if what I heard is correct. That's negligence - IMO.

Apparently the methane clathrate formation was unexpected. Well then perhaps BP et al needs to do more research.

As for LWR technology, the industry now has about 40+ year experience, so we have a lot of lessons learned, e.g., don't use Inconel-600 for steam generator tubing!

In the 60's and 70's, it really was learn as you go!

The original plants were designed with plenty of margin, but some significant events (snafus), e.g., TMI-2, demonstrated that even plants with well designed margins can be severely damaged when people screw up.

As for the space shuttle, due to the complexity, it really did have a high potential failure rate ~ 1:100. But that doesn't necessarily mean that it is expected. It means that one better be d@mn careful - don't take chances! Well - several somebodies at NASA didn't heed the warnings, and they weren't careful with Challenger and then Columbia - and good people died as a result.


Once the well is capped and the leaking stopped, then it will be time for lessons learned.
 
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  • #675
Rule number 1: No system is failsafe.

Any reasonable risk evaluation requires the assumption that some risks have not been recognized. It is widely agreed [based on reports] that the only sure means of shutting down a runaway well, is to bottom fill the well, using relief well. No matter the level of confidence wrt failsafe equipment, I would demand that one, and perhaps even that two relief wells be drilled in parallel with any deep primary well.

If a successful means of controlling a runaway well is demonstrated, perhaps the requirement for relief wells could be waived. But first we would have to know for a fact that a situation like this, or worse, could be quickly controlled, with less than some maximum acceptable volume of oil escaping per unit time.

What makes me furious is that, imo, given the risk, any reasonable person would have demanded this up front. Deep-water drilling may be akin to rocket science, but demanding that we have a tested and effective means to control a catastrophic failure, is and always was a no-brainer; and even more so given that deep-water drilling is so complicated. It is terrifying that such incompetence occurred at this level - a world-class company and one that I used to admire. Whle BP may or may not be responsible for the rig failing, these sorts of things do happen. But it is a crime, imo, to put an entire region at risk, by assuming that any device or set of devices, won't fail.
 
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  • #676
Ivan Seeking said:
If a successful means of controlling a runaway well is demonstrated, perhaps the requirement for relief wells could be waived. But first we would have to know for a fact that a situation like this could be quickly controlled, with some maximum acceptable volume of oil escaping.

What makes me furious is that, imo, given the risk, any reasonable person would have demanded this up front. Deep-water drilling may be akin to rocket science, but demanding that we have a tested and effective means to control a catastrophic failure, is a no-brainer. And it always was. It is terrifying that such incompetence as allowed at this level. Whle BP may or may not be responsible for the rig failing, it is a crime to put an entire region at risk, by assuming that any device or set of devices, won't fail.
It seems that there are multiple failures in this "unprecedented, unforeseeable" incident, and the worst of them are in basic requirements.

Drill a relief well in parallel with every deep-water well.

Require that every block valve on a BOP fail to the closed position on a loss of signal from the surface. Not every valve may provide full blockage, but in real-life situations every valve that is at least partially closed provides a lower total pressure-differential that other valves farther along in the flow can attempt to overcome. Test the valves routinely and document that they are operable.

Require that in the case of a catastrophic failure, the BOP's pipe-shearing mechanism activate automatically.

Require that every single BOP's pipe-shear mechanism be tested and certified to successfully cut modern high-strength steel pipe before deployment. If the shear-mechanism cannot be certified, the BOP will not be deployed.

IMHO, deep-water drilling will not be "safe" unless we adopt these standards.
 
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  • #677
turbo-1 said:
Require that every block valve on a BOP fail to the closed position on a loss of signal from the surface. Not every valve may provide full blockage, but in real-life situations every valve that is at least partially closed provides a lower total pressure-differential that other valves farther along in the flow can attempt to overcome. Test the valves routinely and document that they are operable.

Require that in the case of a catastrophic failure, the BOP's pipe-shearing mechanism activate automatically.

Require that every single BOP's pipe-shear mechanism be tested and certified to successfully cut modern high-strength steel pipe before deployment. If the shear-mechanism cannot be certified, the BOP will not be deployed.

I agree with all of your proposed requirements for a BOP, they seem logical for certifying it's proper function. I'm curious though, which of those requirements are currently in place? Does the law simply require that a BOP be in place, or does it also state it must be able to meet [X] requirements?
 
  • #678
Ivan Seeking said:
Rule number 1: No system is failsafe.

Any reasonable risk evaluation requires the assumption that some risks have not been recognized. It is widely agreed [based on reports] that the only sure means of shutting down a runaway well, is to bottom fill the well, using relief well. No matter the level of confidence wrt failsafe equipment, I would demand that one, and perhaps even that two relief wells be drilled in parallel with any deep primary well.

If a successful means of controlling a runaway well is demonstrated, perhaps the requirement for relief wells could be waived. But first we would have to know for a fact that a situation like this, or worse, could be quickly controlled, with less than some maximum acceptable volume of oil escaping per unit time.

What makes me furious is that, imo, given the risk, any reasonable person would have demanded this up front. Deep-water drilling may be akin to rocket science, but demanding that we have a tested and effective means to control a catastrophic failure, is and always was a no-brainer; and even more so given that deep-water drilling is so complicated. It is terrifying that such incompetence occurred at this level - a world-class company and one that I used to admire. Whle BP may or may not be responsible for the rig failing, these sorts of things do happen. But it is a crime, imo, to put an entire region at risk, by assuming that any device or set of devices, won't fail.

Drilling a relief well simultaneously is no more of a sure of a way to contain it than is drilling the primary well. Either one could fail just as well as the other if the operator makes the same mistake or if the well control equipment fails to operate.

The moral of all of this is to just make damn sure none of the fundamental cannons of well control are ignored or violated.

CS
 
  • #679
turbo-1 said:
It seems that there are multiple failures in this "unprecedented, unforeseeable" incident, and the worst of them are in basic requirements.

Drill a relief well in parallel with every deep-water well.

Require that every block valve on a BOP fail to the closed position on a loss of signal from the surface. Not every valve may provide full blockage, but in real-life situations every valve that is at least partially closed provides a lower total pressure-differential that other valves farther along in the flow can attempt to overcome. Test the valves routinely and document that they are operable.

Require that in the case of a catastrophic failure, the BOP's pipe-shearing mechanism activate automatically.

Require that every single BOP's pipe-shear mechanism be tested and certified to successfully cut modern high-strength steel pipe before deployment. If the shear-mechanism cannot be certified, the BOP will not be deployed.

IMHO, deep-water drilling will not be "safe" unless we adopt these standards.

All of the choke and kill valves are fail safe close already.

In case of catastrophic failure, the BOP's blind shear ram does activate automatically already.

The entire BOP control system is fully function tested prior to drilling every new well and every two weeks there after while drilling. The stack (all of the BOP's) are also pressure tested every two weeks and prior to drilling any new well. This is currently required by MMS and to my knowledge never been violated on any of the 50+ offshore drilling vessels I've been on.

The shear rams are currently tested by the OEM to determine which grade of drill pipe and other tubulars they are capable of shearing. They perform actual shear tests and log the results. They also ensure that the empirical results match up with their theoretical shearing capacities. Prior to drilling any new well they are required to verify the capacity of the blind shearing rams.

As I stated before, the industry has the proper safeguards in place. However, as with any safeguard, they are only effective if used.

I would also caution everyone that we do not know of what exactly has occurred yet. Until then all of the recommendation by the DOI and others are subjective and most likely will be revised as the investigation unfolds.

CS
 
  • #680
Mech_Engineer said:
I agree with all of your proposed requirements for a BOP, they seem logical for certifying it's proper function. I'm curious though, which of those requirements are currently in place? Does the law simply require that a BOP be in place, or does it also state it must be able to meet [X] requirements?

Yes, all of those requirements are in place and required per MMS.

CS
 
  • #681
stewartcs said:
Yes, all of those requirements are in place and required per MMS.

CS
If the requirements were in place and required, why do we have this gusher a mile down? I think we'll find that inspections, testing, and certification were not up to the gold-standard of reasonable precautions and standards. If BP ever releases relevant records (faint hope) we might get some light on this.
 
  • #682
turbo-1 said:
If the requirements were in place and required, why do we have this gusher a mile down? I think we'll find that inspections, testing, and certification were not up to the gold-standard of reasonable precautions and standards. If BP ever releases relevant records (faint hope) we might get some light on this.

We have a gusher a mile down because a fundamental cannon of well control was violated by a human. That is, they allowed the well to become under-balanced and it blew out.

Apparently, something is in the wellbore of the stack that is not shearable by the blind shear rams. The blind shear rams are only capable of shear and sealing a limited size of tubular. If it is too large they will not shear and seal due to geometric limitations. Presumably, something was blown into the cavity that is unshearable - but that's just a guess until they retrieve the stack and open it up.

Remember though, if a human would not have allowed the well to become underbalanced, this would not have happened.

CS
 
  • #683
That human being the ceo of BP imo. That or obama.
 
  • #684
jreelawg said:
Anyways, my point remains. What is safe for Exxon isn't necessarily safe for BP, and so how do you work this out? The laws have to apply equally to all right. So maybe there should be a three strikes rule of some kind and BP should just be ousted. I think all of their assets should be seized as U.S. property and auctioned off to other companies, profits should go to those affected, cleanup, and restoration.

The takeover of GM aside, Obama doesn't have the legal authority.
 
  • #685
BP blew it. So let's the competition drill. "Drilll Baby Drill!"
 
  • #686
drankin said:
BP blew it. So let's the competition drill. "Drilll Baby Drill!"

Those who are incapable of learning from history are sure to doom us all.
 
  • #687
Finally, some progress. BP claims to be capturing about 30% of the flow, or 6000 barrels per day [their numbers].
 
  • #688
Ivan Seeking said:
Finally, some progress. BP claims to be capturing about 30% of the flow, or 6000 barrels per day [their numbers].

That's great news but it makes me wonder. Is that the percentage of before or after they cut the top off and increased the flow? Is the total being spilled now actually less than before they cut it? Hope that number gets to 90% or better.
 
  • #689
Borg said:
That's great news but it makes me wonder. Is that the percentage of before or after they cut the top off and increased the flow? Is the total being spilled now actually less than before they cut it? Hope that number gets to 90% or better.

Unfortunately, that's a good point! The flow was expected to increase by 20% when they cut the pipe. What worries me is that, just watching the video, most of the oil escaping seems to be coming from the seal, and not the vents.
 
  • #690
stewartcs said:
Apparently, something is in the wellbore of the stack that is not shearable by the blind shear rams.

CS
That may be the case (something in the stack), but my understanding per the press reports is that the ram mechanism failed to ever activate (not because it had insufficient sheer force). Reports are that crew members on the rig were about to engage the BOP moments before the surface explosion, and later ROVs were unable to activate the rams.
 
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  • #691
I saw it reported that they were only capturing about 10% this morning. Maybe the estimate has changed a bit as they close the vents.
 
  • #692
mheslep said:
That may be the case (something in the stack), but my understanding per the press reports is that the ram mechanism failed to ever activate (not because it had insufficient sheer force). Reports are that crew members on the rig were about to engage the BOP moments before the surface explosion, and later ROVs were unable to activate the rams.

There are other devices that can seal the well besides the shear rams. The annulars and pipe rams can seal if the drill pipe is in the hole (annulars can also close off completely on open hole). I'm almost certain they have an ROV function port for a pipe ram too. So this leads me to believe that something with too large of a diameter is in the bore.

It will be a lot easier to figure out what went wrong as soon as they release more information from their investigation.

CS
 
  • #693
If they are trying to fix the pipe where the oil is seeping out of instead of blowing it up or torpedoing it then that tells me only one thing, profits speak loudest.
Somebody attacks the US ie 911 you go to war.
Somebody creates one of the biggest manmade disasters in your waters and you want to let them take their time hmmmmmmm
That black gold speaks from the depths
Your President Obama has a lot on his shoulders but honestly he has portrayed his disgust at this situation and he is like the rest of the world and waiting for BP to get their...together. Waiting time over. Blow it up.
Send BP a bill reflective of the revenue LOST to businesses. I'd say $80BN would suffice.
Then send them a further bill for say... the worth of their profits globally. Seems fair to me for the cleanup.
 
  • #694
eruera said:
If they are trying to fix the pipe where the oil is seeping out of instead of blowing it up or torpedoing it then that tells me only one thing, profits speak loudest..

Uh...no it doesn't. If profits speak loudest, they would have stopped the leak as soon as they possibly could have. The cost of the clean up alone is 10 times more already than it would have been to just drill a new well. It's a lot easier to produce oil from a reservoir when the oil is actually in the reservoir instead floating in the GOM...

BP will most likely spend at least 3 or 4 billion on this mess. It costs on average about 100 million to drill a well at that depth. So there is no foundation for your statement. I know it's easy to fall into the media trap of a "big bad oil company" is screwing everyone and the environment so they can earn a profit, but that's just simply not true (other than screwing up the environment of course).

CS
 
  • #695
thedogged said:
BP should have done that long before
Silence of the arsholes!

Done what? Blown the well up?

CS
 
  • #696
eruera said:
If they are trying to fix the pipe where the oil is seeping out of instead of blowing it up or torpedoing it then that tells me only one thing, profits speak loudest.
Somebody attacks the US ie 911 you go to war.
Somebody creates one of the biggest manmade disasters in your waters and you want to let them take their time hmmmmmmm
That black gold speaks from the depths
Your President Obama has a lot on his shoulders but honestly he has portrayed his disgust at this situation and he is like the rest of the world and waiting for BP to get their...together. Waiting time over. Blow it up.
Send BP a bill reflective of the revenue LOST to businesses. I'd say $80BN would suffice.
Then send them a further bill for say... the worth of their profits globally. Seems fair to me for the cleanup.

When either YOU (or Obama) are named "Dictator of the World" then impose your solution...otherwise - we have a legal process to follow.
 
  • #697
Astronuc said:
It's not clear to me who cut corners. I've only heard bits and pieces, sound bites, and contradictory testimony. I've heard that a BP manager over-ruled a Haliburton or Transocean engineer with respect to the plugging and drill string cover - I don't know who to believe.
Clarification: Much of the picture I have comes from the Transocean electronics supt who was interviewed on 60 Minutes. Though I realize he has an inherrent conflict of interest and I realize it isn't exactly rational for a guy who prides himself on being rational, I tend to give the benefit of the doubt to guys who just had a staring contest with death and proved they have the stones to win.
 
  • #698
russ_watters said:
Clarification: Much of the picture I have comes from the Transocean electronics supt who was interviewed on 60 Minutes. Though I realize he has an inherrent conflict of interest and I realize it isn't exactly rational for a guy who prides himself on being rational, I tend to give the benefit of the doubt to guys who just had a staring contest with death and proved they have the stones to win.
I agree. I hadn't watched that program, but I'd heard to conflicting stories about a disagreement between BP and TO or Haliburton staff.

Somebody made the call to replace drilling mud with seawater. Ostensibly, that person had the authority (someone from BP?) to over-rule those who were more cautious/responsible.

Interesting perspective here:
http://www.ft.com/cms/s/0/f3e3e2e6-58a7-11df-a0c9-00144feab49a.html
. . . .
In an important sense, however, BP has not changed at all. It pioneered deep-water drilling in the North Sea and it regards itself as an explorer par excellence. Deep-water drilling is top of its priority list, with 11 of its 42 planned new projects up to 2015 in the Gulf of Mexico.

Extracting oil from beneath the US outer continental shelf takes enormous expertise. Last summer, the Deepwater Horizon rig drilled a well for BP in its Tiber field 35,000ft down in 10,000ft of water - in other words, 6,000ft deeper than Mount Everest is tall.
. . . .
I have to wonder, given that they've had experience, how could they have screwed up so badly. Perhaps it was because someone decided that they've done it before, so there is minimal (little or no risk).

I also heard that the Macondo well is probably more productive than they initially estimated, i.e., it was a great find, before it got out of control.
 
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  • #699
Ivan Seeking said:
Rule number 1: No system is failsafe.

Any reasonable risk evaluation requires the assumption that some risks have not been recognized. It is widely agreed [based on reports] that the only sure means of shutting down a runaway well, is to bottom fill the well, using relief well. [emphasis added]
So no system is failsafe except the failsafe one? Obviously, a contradiction.
No matter the level of confidence wrt failsafe equipment, I would demand that one, and perhaps even that two relief wells be drilled in parallel with any deep primary well. What makes me furious is that, imo, given the risk, any reasonable person would have demanded this up front.
Mech_E already discussed this:
Mech_E said:
Actually that's no guarantee since if both blowout preventers were in equal states of disrepair we'd have a leak that was twice as big as now. If we simply required the blowout preventer to function properly we wouldn't be in this mess right now... oh wait that's already required by regulation! And what would you say if both wells failed simultaneously? We should have seen it coming? More regulation requiring 3 wells to be drilled simultaneously? Where does it end, and at what point do you look at the tradeoffs and decide "that's safe enough?"

The difference between 99% safe and 100% safe is infinity when you're always only dividing the difference by two...
...but let me take a slightly different tack:

Why would we want to pay many tens of millions of dollars to do something that only halves the risk of failure when we could spend many tens of thousands of dollars on something that cuts it by multiple orders of magnitude?
If a successful means of controlling a runaway well is demonstrated, perhaps the requirement for relief wells could be waived. But first we would have to know for a fact that a situation like this, or worse, could be quickly controlled, with less than some maximum acceptable volume of oil escaping per unit time.
You've seen it in the movies, I'm sure, Ivan: blowouts used to be the norm, not the exception with oil wells. Some examples:
The Lucas Gusher at Spindletop in Beaumont, Texas in 1901 flowed at 100,000 barrels (16 000 m³) per day at its peak, but soon slowed and was capped within nine days. The well tripled U.S. oil production overnight and marked the start of the Texas oil industry.[6] Masjed Soleiman, Iran in 1908 marked the first major oil strike recorded in the Middle East.[7] The Lakeview Gusher on the Midway-Sunset Oil Field in Kern County, California of 1910 is believed to be the largest-ever U.S. gusher.

At its peak, more than 100,000 barrels (16 000 m³) of oil per day flowed out, reaching as high as 200 feet (60 m) in the air. It remained uncapped for 18 months, spilling over nine million barrels (378 million gallons/1.4 million m³) of oil, less than half of which was recovered.[2]
http://en.wikipedia.org/wiki/Blowout_(well_drilling )

Blowout preventers and other modern procesures *are* the "successful means" you are looking for!
 
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  • #700
russ_watters said:
So no system is failsafe except the failsafe one? Obviously, a contradiction.

The only means of killing any well is to bottom fill. I never said that any particular attempt to bottom fill was failsafe [that is why I even suggested that two relief wells might be required, but perhaps that was too obscure for some readers to catch], but it is the ONLY means of permanently plugging a well.

Mech_E already discussed this: ...but let me take a slightly different tack:

Why would we want to pay many tens of millions of dollars to do something that only halves the risk of failure when we could spend many tens of thousands of dollars on something that cuts it by multiple orders of magnitude? You've seen it in the movies, I'm sure, Ivan: blowouts used to be the norm, not the exception with oil wells. Some examples:
http://en.wikipedia.org/wiki/Blowout_(well_drilling )

Blowout preventers and other modern procesures *are* the "successful means" you are looking for!

While we watch tens of millions of gallons of oil flood the gulf, your solution is to continue with the same mentality that led to this disaster in the first place? Your argument could have been made before his all happened, and we would still be right where we are right now. So clearly your logic fails. We can see the result.

If you are saying that a relief well poses too much risk, and there is no hope of developing an effective system to capture the oil from a runaway well, then we should just ban deep drilling altogether. One thing is for sure, the attitudes found here strongly drive me in that direction. The solution to the biggest environmental disaster in US history is to continue with the same logic that caused it? That is just nuts.

One popular definition of insanity is to do the same thing over and over while expecting different results.
 
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