J. I. Roberts Drilling Co. v. Davis Oil Co.

260 So. 2d 735, 1972 La. App. LEXIS 5711
CourtLouisiana Court of Appeal
DecidedMarch 21, 1972
DocketNo. 4245
StatusPublished

This text of 260 So. 2d 735 (J. I. Roberts Drilling Co. v. Davis Oil Co.) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J. I. Roberts Drilling Co. v. Davis Oil Co., 260 So. 2d 735, 1972 La. App. LEXIS 5711 (La. Ct. App. 1972).

Opinion

REDMANN, Judge.

Plaintiff was drilling for defendant a 6,500 foot oil or gas well under a day-work contract when the well blew out and burned. Plaintiff sued for the price of its day-work; defendant reconvened (adding plaintiff’s insurer as a defendant-in-reconvention) for its losses. It was stipulated that, unless the loss was due to plaintiff’s negligence or breach of contract, plaintiff is entitled to judgment for $10,084.04; if the loss was attributable to plaintiff, defendant is entitled to judgment against plaintiff and its insurer for $23,356.33. From a trial court judgment in favor of plaintiff, defendant appeals. We affirm.

Under a day-work contract, the contractor provides the equipment and personnel, including a 24-hour superintendent (“tool pusher”), at a per diem cost to the operator for whom and according to whose instructions the well is to be drilled.

Natural gas at differing pressures may be encountered in drilling. One force that tends to prevent the escape of the gas is the pressure resulting from the sheer weight of the column of viscous drilling mud, with which the hole being drilled is ordinarily kept filled and which is ordinarily constantly circulated through the drilling pipe or stem, out the bit and back up to surface mud tanks. The mud’s hydrostatic pressure increases in proportion to the height of the column (and the density of the mud). As long as the mud’s pressure exceeds the gas pressure, no troublesome escape of gas can occur.

When the gas pressure does become higher than the mud’s it begins to displace mud, thus reducing the effective height of the mud column and therefore reducing the mud pressure even more.

The circulation of fresh mud down the drilling stem and out of the bit (ordinarily) at the bottom of the hole serves to maintain the mud column at a proper density and to prevent the accumulation of gas by forcing it up in smaller bubbles, “entrained” in the mud column and exhausted into the surface tanks. (Circulation also serves to remove the bit cuttings, a function not of concern here.)

If, however, gas pressure does exceed mud pressure in this self-accelerating fashion, the threatened blowout is ordinarily controlled by preventers, which serve to seal the “surface casing”. Ideally, the well hole is then a sealed tube into the underground, through which a second tube (the drilling pipe or stem) should be the only other opening (excepting possible emergency lines), and it is also sealable, apparently by different processes under differing circumstances.

The blowout preventers are fixed in series atop the surface casing, and the drilling pipe passes through them. The preventers actually used here were in a “space saver” containing both blind rams and pipe rams. The latter is made the same diameter as, and closes exactly over, the drilling pipe being used; the former closes only when there is no drilling pipe (or other obstacle) in its way. However, here a 6" diameter drill collar, larger in diameter than the drilling pipe, was in the preventers at the time of the blowout, making them unable to effectively seal the hole.

There is another type of preventer, described as a Hydrill, which seals effectively irrespective of the shape of the object within it. Use of such a preventer was not specified by the owner (plaintiff-in-reconvention) here. Had a Hydrill been in use, it could have closed upon the drill collar, although some space between collar and stem would have remained.

[737]*737Also, pertinent, at least in plaintiff’s view of this case, is that the ideal sealed tube effect (with preventer rams closed) may also be defeated if the surface casing is not adequately cemented as intended. This well began with 142 feet of 13$4" O. D. conductor casing being driven into the ground. Then, through it, an 11" hole was drilled to 832' and (about) 832' of 8Y%" 0. D. surface casing was introduced. At that point, between those coaxial pipes a ring of space over an inch wide on all sides existed, through which (if unfilled) gas could escape from the 832' depth to the surface. But cement is introduced through the surface casing to 832', with drilling mud supplying a subsequent pressure to force the cement outside of the surface casing and up, in an attempt to fill and seal that annular space between surface casing and the 11" hole, at least towards the bottom of the surface casing. However, the wall of the 11" hole may not have sufficient cohesiveness to remain only 11" wide, and is not an impermeable surface, but may have porous strata or even an occasional somewhat empty space. Some quantity of the cement may not be forced up the annular space but may be lost in the underground formations. Here, cement in an amount 100% in excess of the theoretical volume of the annular space was introduced, but did not in fact return to the surface between conductor and surface casings (as it would have done, in quantity, were the entire 832' hole exactly 11" wide and of an impermeable character).

The owner-operator (defendant and plaintiff-in-reconvention) charges that the blowout occurred because of plaintiff’s withdrawal of the drilling stem from the hole under circumstances hereafter described, it being the owner’s view that this withdrawal reduced the mud column pressure, facilitating a blowout while at the same time (because the larger-dimension drilling collar was brought up into the pre-venters) rendering the blowout preventers inoperable.

Plaintiff’s view is that its withdrawal was not negligence nor a breach of its contractual obligation of good workmanship, and, moreover, that the blowout occurred not through the surface casing but through the annular space between conductor and surface casings.

The circumstances at the time of withdrawal were that, with the hole at 2,175 feet, the rotary clutch required repair and (prudently) plaintiff lifted the bit up from the bottom of the hole into the lower end of the surface casing, from which point mud circulation was maintained. This step consumed some three hours. The bit stayed at this approximately 832' level some five hours, during which the entire mud column consisted of (apparently) a relatively un-circulated or static portion, below the 832' surface casing level, plus a circulating portion, from that point to the surface.

Because of the possibility that gas may have been accumulating in the uncirculat-ing mud in the lower portion of the hole in that five-hour period, defendant’s two experts opined it was negligence (one said “inexcusable”) on plaintiff’s part to elect to lift up the drill pipe (to determine whether the bit should be replaced) without first making a “short trip” to the bottom of the hole to circulate mud from the bottom and to leave a full supply of fresh heavy mud in the column. (They also opined that the drilling pipe withdrawal would pull some mud with it and slightly reduce the column’s hydrostatic pressure, despite circulation’s effect of replenishing the mud column.)

Yet, because of the absence of the rotary clutch, plaintiff’s expert opined it would have been negligence to make the short trip since the bit may have become stuck, causing the necessity of an expensive “fishing” operation. (One defense expert contradicted this by describing the chance of getting stuck as “awfully slim.”)

We may observe, however, that while this testimony suggests it may have been prudent not to make a short trip under the [738]*738circumstances, it does not of itself suggest that withdrawal without a short trip was prudent under the circumstances.

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Bluebook (online)
260 So. 2d 735, 1972 La. App. LEXIS 5711, Counsel Stack Legal Research, https://law.counselstack.com/opinion/j-i-roberts-drilling-co-v-davis-oil-co-lactapp-1972.