MONTARA COMMISSION OF INQUIRY · Q. Well, a cement bond log can determine the integrity of cement...

.14/4/10 (19)Transcript produced by Merrill Legal Solutions

2082

MONTARA COMMISSION OF INQUIRY

Held at Level 1, 51 Allara Street,Canberra, ACT

Before The Commissioner, Mr David Borthwick AO

On Wednesday, 14 April 2010 at 9.30am

(Day 19)

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647

.14/4/10 (19) D A MAROZZITranscript produced by Merrill Legal Solutions

2083

<DOMINIC ANTHONY MAROZZI, on former affirmation: [9.30am]

MR HOWE: Commissioner, before Mr Berger resumesquestioning of Mr Marozzi, I thought I would raise oneissue for the consideration of the parties. The practicedirection issued by the Commissioner, which was issued onthe basis that it was subject to change, contemplated thatafter the conclusion of the public hearings, counselassisting would prepare a set of submissions, which wouldbe then placed on the Inquiry's website, and the parties,through their representatives, would be afforded anopportunity to respond to those submissions and to put suchother submissions as they considered, with a view to theCommissioner then preparing his report and submitting it.

An alternative procedure does arise for consideration,which we would ask the parties to give some attention toand then get back to us. That would involve the provisionof a draft or preliminary report by the Commissioner to theparties only for their consideration, so it wouldn't bepublicly released, and it would be provided on the expressunderstanding that no concluded or final views had beenformed by the Commissioner; rather, they were theCommissioner's tentative or preliminary findings, subject,of course, to persuasion to the contrary in the light ofany submissions put to the Commissioner.

One virtue of that is that it might result in arefinement of the issues ultimately operating on the mindof the Commissioner and therefore enable the parties moresharply to say what they would want to say.

In any event, I think I have said enough about thealternative procedure, and if the parties could considerit, take such advice as they wish and then perhaps get backto us. If they wish to make any public statements aboutwhat I have raised, they can do so, but we would be happyto hear from them privately as well, and if there isa broad consensus or agreement, then we might well proceedin that fashion rather than as originally indicated. I amnot sure if anyone wants to say anything at this stageabout the option.

MR GRANT: I thank my friend for that, Mr Commissioner.We are able to respond to that now. We would be in favourof following the course that has just been outlined bycounsel assisting. Our experience has been in these

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647

.14/4/10 (19) D A MAROZZITranscript produced by Merrill Legal Solutions

2084

matters that it is all very well and good to get thesubmissions of counsel assisting, but that doesn'tnecessarily give the parties any insight into what it isthat the Commissioner is thinking in a preliminary sense,and there is the potential to pass like ships in the nightand miss the matters that are operating on theCommissioner's mind. For that reason, we would be infavour of that sort of proposal.

I would also observe that, in our experience, it isnot an unusual way of addressing the question ofsubmissions in the context of these sorts of inquiries.So, for what it is worth, Mr Commissioner, we can indicateour consent to that course now. Of course, I am sure thatcounsel assisting will liaise with the representatives ofAtlas and the other parties that are not here today.

MR HOWE: Yes, I think it is something that we would needto canvass with those parties who had been given leave toappear but who have ceased to continue to attend, so thatthey could have an opportunity to say what they want to sayabout the proposal as well.

THE COMMISSIONER: Another factor, Mr Howe, apart fromgiving parties a sharper view of my preliminary findings,is that I am very conscious of the deadline imposed on thisCommission, and I think that proceeding to a preliminaryreport stage not only might be helpful to you but may helpshorten the proceedings as well.

MR HOWE: It is possible that it would foreshorten thetime between now and the ultimate provision of the report,just because it cuts out one intermediate step.

In any event, it is a matter which I'm not expectingimmediate responses to. I understand that it will need tobe the subject of some consideration, and we will certainlylisten to what the parties have to say about the option.Then ultimately it will be for the Commissioner to rule howhe wishes to proceed. We would commend it, at least, tothe parties for their earnest consideration.

The other matter is that so far as the tracking of thepublic hearings is concerned, my understanding is that theNorthern Territory witnesses are likely to have theirevidence completed by close of business tomorrow, I think,which would leave Mr Peachey and Mr Storrie as the final

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647

.14/4/10 (19) D A MAROZZI (Mr Berger)Transcript produced by Merrill Legal Solutions

2085

witnesses on Friday, so there is some prospect, at least,depending on the length of time that any cross-examinationof them might take, for the public hearings to complete bythe end of this week, which would be, no doubt, somethingof value to the Commissioner but might also relieve theparties of the need to attend again next week, whichobviously has some merit or value from their point of view.

In any event, we can't be certain, but I think we canwork, at least, towards that as an objective.

<EXAMINATION BY MR BERGER CONTINUING:

MR BERGER: Q. Mr Marozzi, do you recall that when wefinished yesterday, we had started to discuss the dailydrilling report of 7 March 2009?A. Yes.

Q. There is one aspect of your statement dealing withthat that I want to clarify before we pursue that topicfurther. If the operator could please bring upWIT.4000.0002.0014 and scroll down to paragraph 51 ofMr Marozzi's statement. I think we established yesterdaythat in paragraphs 50 and 51, you were talking about yourunderstanding at the time, namely, on or around 8 Marchlast year; is that right?A. That's right.

Q. You also said that you wished to delete the words "andcement" in paragraph 51 of your statement.A. That's right.

Q. What I want to check is, is it your understanding nowthat the pressure test conducted wasn't going to establishthe integrity of the cement, or did you have thatunderstanding as of 8 March last year?A. No, in the course of our telephone conference, I hadrealised that the insertion of that word "cement" neglectedthe fact that the pressure was acting on the casing and ontop of the plugs.

Q. So that's an understanding you have come to recently;correct?A. Yes, during our telephone conference.

Q. But your understanding as of 8 March last year wasthat the pressure test conducted established the integrity

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2086

of the casing and the cement in the casing shoe; is thatright?A. No, the casing and on top of the plugs, because theplugs --

Q. What was your understanding as of 8 March last year,when you read the daily drilling report, about whether theintegrity of the cement in the casing shoe had beenestablished?A. I had no reason to believe that that cement wascontaminated. I had an understanding that it had not beenvalidated, but I understood that the pressure test was onlyacting on the casing and on top of the plugs, so it was noteffectively validating the cement.

I didn't go through that exact thought process on8 March, but I know I was pretty much aware of that,because, from my drilling background, I'm essentially awarethat when they drill out the shoe, in the next stage of theprogram, that's when they undertake their formationintegrity test or their leak-off test, and that's thevalidation of the cement job at that point. So eithersubconsciously or directly, I was mindful of that.

Q. But you say that as of 8 March, you didn't havea belief that the cement integrity had been established; isthat right?A. That's right - hadn't been validated.

Q. You mentioned again, Mr Marozzi, formation integritytesting and leak-off testing; is that right?A. Mmm.

Q. I suggest that formation integrity tests test thestrength of the formation; that's right, isn't it?A. That's right.

Q. And a leak-off test is to determine the fracturepressure of the formation; that's right, isn't it?A. That's right.

Q. So how do either of those tests establish theintegrity of the cement in a casing shoe?A. It depends on which one they are going to take, butbasically that test will confirm whether it holds thenominated pressure that they are seeking. So whether it isopen formation or cement, that test will be acting on both

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2087

at the base of the shoe, when they have drilled out. Soput them together and what they are trying to establish iswill they have the appropriate integrity that they require.

Q. Is it your understanding that a formation integritytest or a leak-off test is the conventional way ofestablishing the integrity of the cement in a casing shoe?A. It's the usual way in drilling operations, yes. Whenyou are drilling through and continuing on with thedrilling sequence, yes. It's one way, yes. There areother ways.

Q. I suggest, Mr Marozzi, that the usual way ofestablishing that is either tagging or annulus pressuretesting or cement bond logging; do you agree with that?A. They are other alternatives, yes, yes.

Q. Well, they are the conventional ways of establishingthe integrity of cement in a casing shoe, aren't they?A. No, they are limited. For example, for the cementbond log, it needs to get below the float to get the tooldown there, because the tool can only run down and hit theplugs. You actually have to drill out, anyway, to get thetool past, so it is limited. You would have to drill out,so it is still the same outcome as if they are drilling outto undertake a leak-off test or formation test.

Q. Well, a cement bond log can determine the integrity ofcement in the annulus without drilling out the shoe, can'tit?A. Yes, that's right, but it won't get below, at theshoe, at the critical point that you are needing. You haveto drill out to do that, anyway. But that is analternative.

Q. Did I understand you correctly, Mr Marozzi, to saythat in order to conduct a formation integrity test ora leak-off test, you need to drill through the casing shoe?A. That's right, and a bit of formation.

Q. So how would you establish the integrity of the cementof the casing shoe before you drilled through it?A. Say that again? Sorry?

Q. How would you establish the integrity of the cement inthe casing shoe before you drilled through the shoe?A. Before you drilled through the shoe?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2088

Q. Yes.A. If you knew that the plugs hadn't rebumped, you couldjust do a pressure test. You could just do a pressuretest. But if you know - in this situation, the plugshadn't rebumped, so they wouldn't have got a valid test ifthey redid that at that time.

Q. The conventional way of establishing the integrity ofthe cement in a casing shoe without drilling through it -so for the purposes of suspension, for example - would beto conduct a pressure test after the wait on cement; that'sright, isn't it?A. That's - yes - well, it's a bit difficult to use theterm "conventional way" here, because this batch drillingprocess I would not say is conventional. If you are usingthe word "conventional", that would be a conventional,one-well drilling program, and the conventional way therewould be to drill out and do your leak-off or formationintegrity test. But in this situation, for batch drilling,I don't think we can use the word "conventional". It haschanged the whole sequence all round, and --

THE COMMISSIONER: Q. Aren't we just talking abouta situation, Mr Marozzi, where we have a suspension of thewell, whether it was one well or five wells? It hasnothing to do with batch drilling, as far as I can see.A. Well, only to the extent that Mr Berger is using theword "conventional", and I'm just trying to point outthat --

THE COMMISSIONER: No, I think what you are trying to dois read in suppositions to what Mr Berger is saying. Justfocus on the questions in front of you, please.

MR BERGER: Q. Perhaps we will approach this by goingthrough the daily drilling report and what you understoodhappened in steps, Mr Marozzi. As of 8 March 2009, youunderstood, I take it, that cementing of the casing shoewas a primary barrier that operated against a blowout?A. Yes.

Q. And it was therefore a critical phase of wellactivity?A. Yes.

Q. In your experience, is this a phase of well activity

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2089

that the operator would move beyond if it had doubts aboutthe integrity of the casing shoe?A. Yes, possibly. Possibly.

Q. So in your experience, an operator who had concernsabout the integrity of the casing shoe might neverthelesscontinue on with drilling operations rather than try toremediate problems they perceived with the casing shoe; isthat right?A. They would try to remediate at a later stage, as longas they are aware that the integrity is questionable.

Q. At what stage might they try to remediate thoseconcerns, Mr Marozzi?A. We mentioned the leak-off test - at that point, theywould do that, and if that failed, they would do a squeezejob, so they would add additional cement down there toprovide integrity at that point.

In this situation, one way would be to do a pressuretest again, without drilling out, that is, if they weren'tdrilling out, if they had reason to question the competencyof the cement job.

Q. So we're talking there about steps to remediateconcerns about the cementing of the casing shoe; that'sright, isn't it?A. Sorry, can you repeat that?

Q. Your reference to "squeeze jobs" and other suchmatters are remediation actions that can be taken torectify perceived concerns about a cemented casing shoe;that's right, isn't it?A. Yes, more than perceived concerns. By then, you wouldknow that you have no integrity - limited integrity.

Q. In your experience, would an operator who had concernsabout the integrity of a casing shoe conduct such remedialaction, or would they just, in some circumstances, move onand think, "Oh, well, we will have to be really carefulwith our secondary barriers"?A. Yes, they may not do the remedial work immediately.So as long as they are very clear that they haven'tvalidated the cement job, but, more importantly, if theyhave reason to have doubts about the cement job - becauseif you just bump the plugs on target and there is no otherissue involved, more often than not you actually have no

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2090

reason to believe there is a questionable cement job. It'strue that it hasn't been validated, but there is no reasonto doubt that cement job if the plugs have bumped exactlyaccording to plan.

Now, they just need to be mindful, okay, at thatpoint, if the cement job went according to plan, the plugsbumped, but the shoe and the cement job have not beenvalidated yet, they just need to make a record of that andbe very much aware of that and then take it into accountwith their barriers and when they return.

Q. If there were problems with the cementing of thecasing shoe, such as that the plugs didn't bump or thefloats failed or a pressure test failed, in yourexperience, would an operator, faced with circumstancessuch as those, nevertheless move on with the next stages oftheir well activities without taking steps to remediate theintegrity of the casing shoe?A. Well, see, again, if the plugs don't bump, it is notreason for alarm - not yet. There is only reason for alarmwhen they do the validation test and it fails the test.They know now that they have to act on it. If the plugshaven't bumped on target and you just want to pump a littlebit more to see what happens, there is a very, verystandard rule of thumb that trainee drilling engineers aretaught: you do not displace past half the shoe track, sothen you ensure, with your procedures, that the cementremains inside the shoe track, at least half full. Sothere is no reason to assume - there is no basis that thecompetency of the cement job will be questionable. Ithasn't been validated yet, but it's not questionable yet.

Then, as long as the operator realises that, thedrilling crew, especially the drilling crew onshore, atthis point in time the shoe has not been validated, butthere are procedures there that demonstrate that there isno reason to accept that the cement job is in fact a badcement job.

Q. Mr Marozzi, will you listen carefully to the questionsI ask you.A. I'm sorry. Okay.

Q. The questions I'm asking you are not directed towhether or not an operator might have concerns aboutintegrity of a casing shoe; they are directed to your

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2091

experience where the operator does in fact have reason forconcern about the integrity of the casing shoe; do youunderstand that?A. Okay, yes.

Q. What I'm seeking to ascertain in relation to that isyour understanding, as at 8 March last year, about whetheran operator, faced with reasons for concern about theintegrity of the casing shoe, would take action toalleviate those concerns by remedial action or may, infact, just move on with the drilling program and seek totake extra precautions with secondary barriers, forexample, later down the track?A. Okay.

Q. Do you understand what I'm asking you?A. Yes. Yes. They may --

Q. Did you have any view, as of 8 March last year, as towhich of those possibilities was the most likely?A. Yes. They may continue on with their barriers, yes.

Q. So the fact that PTT continued on with their drillingprogram beyond the events of 7 March 2009 had no impact, inyour mind, about whether the casing shoe may or may nothave been a sound primary barrier operating againsta blowout; is that your evidence?A. No. It did concern me, but the following day, I sawthe morning update from Chris Wilson, pointing out thatthey may need to do a squeeze job, and was feelingcomfortable that, yes, he's on the ball. I can find thatemail for you.

Q. Are you referring to the morning email from Mr Wilsonthat you received at 6.06am on Sunday, 8 March?A. It could be that one. He had specifically mentionedleak-off test or squeeze job, squeeze cement job, in themorning update.

Q. If the operator could please bring upPTT.9006.0001.0003 and scroll down slightly. There isa redacted version of this. Could the version which endswith "_R" be brought up, please, instead. If we scrolldown, slightly, do you recognise this as the morning emailsent to you and others by Mr Wilson?A. Yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2092

Q. If we could go over to the next page, just above theentry "Sunday, 8 March", could you read the entries on thesecond page, Mr Marozzi, going down to 8 March, and theoperator will just need to scroll down slightly. Do yourecall receiving this email?A. Yes.

Q. Do you recognise that as the email that you receiveddescribing events relating to the cementing of the 9-5/8"casing shoe on the H1 well?A. Yes.

Q. Do you recall forming a view about what theinformation contained in this email meant, in your mind?A. Yes, yes.

Q. What view did you form?A. Essentially, that they had a slight problem with thefloats, then they held pressure, they had already pressuretested against the plugs, so they essentially had whatcould be expected as a competent shoe but not validated atthis point.

Q. Do you recall reading the phrase "Checked floats oncasing - OK"?A. Yes.

Q. What did that signify to you at the time?A. Just at that point, the floats held; they didn't geta flow-back.

Q. You mentioned some other email that referred toa squeeze job, or something like that; is that right?A. I think it was a day or two later - I think.

Q. The Inquiry has no record available, Mr Marozzi.Would you be able to make inquiries with your department tosee if any such email could be located?A. Yes.

Q. Do you have one with you there?A. I might have.

Q. If you would prefer to look for it at the morningadjournment, that's fine. If you can find it quickly,that's okay.A. Yes, I have it here. (Document shown to Mr Berger).

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2093

Q. Perhaps the email could be returned to you,Mr Marozzi. I think my learned friend Mr Grant would liketo have a look at it first. (Document shown to Mr Grant).While Mr Grant is having a look at it, Mr Marozzi --

MR ABBOTT: May I also look at it, please? (Document shownto Mr Abbott).

MR BERGER: Q. Do you have anything else interesting inyour folder, Mr Marozzi?A. I hope not.

Q. Whilst Mr Abbott is looking at that document, perhapsI could ask you this: do you recall forming a view, at thetime that you read the email that you have just provided tous, whether it related to the H1 well or one of the otherwells on the Montara development?A. No, forming the view that - on H1, you know, they hadthis slight problem with the floats, so I just wanted tomake sure that they had in their mind that the validationtest was programmed, and that gave me a warm feeling that,yes, they are on the ball.

Q. So the email that you have just provided to us, theone of 9 March, gave you some comfort that validation ofthe integrity of the casing shoe on the 9-5/8" casing forthe H1 well was going to occur, did it?A. Yes.

Q. And you have a clear recollection that that email gaveyou that comfort?A. Yes.

Q. Would you read the bottom of the first page of theemail and the bit that you have highlighted on the secondpage, Mr Marozzi?A. Sorry, can you repeat the question?

MR BERGER: Yes. It may be best if we bring this up onthe optical reader.

THE COMMISSIONER: I think it would be. Everyone has seenit except me.

MR BERGER: Q. Could the operator slowly scroll down thefirst page. Just pausing there, do you see the heading

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2094

under "Monday, 9 March", Mr Marozzi?A. Yes.

Q. That's dealing with the Montara H4 well; is thatright?A. Right, yes.

Q. Then if we keep going down to the bottom of the pageand over to the top of the next page, it rather suggeststhat the comments there about the formation integrity testrelate to the H4 well rather than the H1 well; do you agreewith that?A. Yes, I would agree with that, how it's written there -sorry, I would agree. It's in direct reference to H4.

Q. But your view at the time was that that highlightedpassage related to the H1 well; is that right?A. That's right.

THE COMMISSIONER: Q. Having regard to Chris Wilson'sdaily report the day before this one, there was nothing inthat that indicated to you that the cement had in fact beenoverdisplaced from the shoe, was there?A. I didn't pick up on that at all.

Q. No, and it wasn't said there, was it?A. No.

Q. So there was no reason, on the basis of that, whichyou received before the daily drilling report, to thinkthat there was a problem, and you mentioned yesterday thatyou relied on that daily drilling report for a bit of theflavour and the highlights of what had happened?A. Yes.

THE COMMISSIONER: Thank you very much.

MR BERGER: Q. Did you also give evidence yesterday,Mr Marozzi, that you read the daily drilling report in thecontext of your understanding of the activities based onthe morning email?A. As a supplement, because it came in second, yes, yes.

Q. So that if you had received information about anactivity in the morning email that you were satisfiedabout, you were less likely to carefully scrutiniseinformation relating to that subject in the daily drilling

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2095

report; is that the position?A. That's fair comment, yes.

Q. We will bring up the daily drilling report in questionnow, which is PTT.9001.0007.0346. Just before we go tothis document, the purple highlighting in the last emailthat we were dealing with - when did you highlight thatdocument?A. It was a few weeks ago, because I knew that I had readsomething during the time that I went back in the course ofeither my witness statement or around that time that causedme to dig that up to find reference to that integrity test.

Q. Do you recognise this daily drilling report,Mr Marozzi?A. Yes.

Q. It is the daily drilling report summarising activitiesthat took place on the H1-ST1 well on 7 March 2009;correct?A. Yes.

Q. Could you tell us what, if any, view you formed uponreading it on 8 March last year?A. Yes, I had already read the morning update, soessentially I did not have a major concern about the cementjob, other than just that the floats had failed and theyjust took the course of action there.

Essentially, with my background in drilling, I knowthat if they have a problem with their cement job, theywill persevere, so I'm essentially just looking at this DDRand glossing over or just skimming over, and I'm looking tosee that line "R/D cement head" - rig down cement head.I just know from my background in drilling that when yourig down your cement equipment, everyone on the rig iscontent; offshore people, from Chris Wilson's email, arecontent. So they progressed to the next phase of theoperation, which tells me that there is no problem, soI was satisfied.

Q. Well, I was asking you questions about that a shortwhile ago, Mr Marozzi, and I thought your evidence was thatpeople who may not be satisfied with the integrity of thecasing shoe might nevertheless move on to the next stage ofactivities. Did I misunderstand you?A. Yes - well, maybe, because, like I said, they won't

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2096

necessarily validate, anyway, at that point, but if theyhaven't validated, it doesn't suggest that they havea problem. They still could continue and validate later.

THE COMMISSIONER: Q. Mr Marozzi, in my own mind, thisis in the context of where they were suspending the welland not coming back for five or six months, so theywouldn't have had to have validated before they suspendedthe well, in your mind?A. It would have been a good practice, yes, if they haddoubts in the way it progressed, yes.

Q. You wouldn't want them to come back in August, havingleft the well there, because your expectation was thatthere was a tested and verified cement shoe and that therewas a 9-5/8" and a 13-3/8" cap in place, and, on thatbasis, you approved the suspension?A. Yes.

MR BERGER: Q. If the operator could scroll to thesecond page of the daily drilling report, please, and godown to the entries for 10.30. Do you see the entriesbetween 10:30 and 14:00, Mr Marozzi?A. Yes.

Q. I take it that you have reviewed those in the last fewweeks?A. I have read it again, do you mean, or just looked atit again?

Q. Yes.A. Yes.

Q. And you understand that what is stated in thoseentries shows that there is likely to have been a problemwith the float collar valve?A. Sorry, reflected in this report - yes, yes.

Q. It also shows that there was a sudden and significantflow from beneath the casing shoe at high pressure, doesn'tit?A. Yes.

Q. You understood, at the time you received this dailydrilling report, that float collar valves were designed toensure that cement goes where it is supposed to go whencementing a casing shoe; correct?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2097

A. Yes.

Q. And when the float collar valves malfunction, there isa real risk that the cement won't go where it is supposedto go; correct?A. There is a risk of that, yes.

Q. You also understood at the time, I take it, thatholding cement static while you are cementing the casingshoe is important in ensuring the integrity of that cement?A. Yes.

Q. You also understood, I take it, that avoidingcontamination of the cement slurry while it dries is animportant aspect of ensuring the integrity of cement?A. Yes.

Q. And you understood also at the time, I assume, thatchannels and wormholes can form if the integrity of thecement is compromised while it dries?A. That's a possibility, yes.

Q. Were you also aware, as at 8 March last year, thatwhen there is a flow from beneath the float collar, thatbrings a risk of the integrity of the cement beingcompromised?A. It can do, yes, yes.

Q. And that is because hydrocarbons or other fluids cancontaminate the cement while it dries; that's right, isn'tit?A. Yes.

Q. Did you also understand, as at 8 March last year, thatthe risk of contamination of the cement is greater whenfluid flows from beneath the float collar at a highpressure or rapidly?A. Yes, that's fair comment, yes.

Q. Did you also understand at the time that specialproblems can arise in cementing a casing shoe in ahorizontal wellbore?A. Yes, I had, yes, some - I have not ever been involveddirectly as a drilling engineer on a horizontal well, butI'm aware in general terms of what you just said, yes, thatit offers different challenges to cement a horizontal well,yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2098

Q. And you were aware that this was a horizontal well atthe 9-5/8" casing point, weren't you?A. Yes.

Q. You were also aware at the time, I assume, that whenthe casing shoe is in a reservoir, you have to beparticularly careful?A. Yes.

Q. Were you aware at the time that the 9-5/8" casing shoewas in the reservoir?A. Yes.

Q. Had you, in your time with BHP or as a regulator,encountered a situation where the casing shoe was in ahorizontal well in the reservoir?A. No.

Q. I suggest that this combination of circumstances meantthat you should have been particularly careful inscrutinising the information relevant to this activity; doyou agree?A. Yes, I agree.

Q. The daily drilling report suggests that no pressuretest was conducted after wait on cement, doesn't it?A. Yes.

Q. Do you agree that conducting a pressure test after thewait on cement is good oilfield practice?A. In this case, it would have been useful to do, yes,yes.

Q. That's particularly the case, I suggest, if there isan issue with the bumping of the plugs or a problem withthe initial pressure test; that's right, isn't it?A. Yes, yes, okay. Can you just repeat that, please?

Q. The importance of conducting a pressure test afterwait on cement is even greater, I suggest, where there hasbeen a problem, such as bumping of the plugs ora suggestion that the initial pressure test in forcing thetop plug down and holding it there signifies an issue hasarisen; do you agree with that?A. Yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2099

Q. Now, in this case, whilst the plugs initially bumped,you are aware that they subsequently debumped, if I can usethat phrase; is that right?A. I'm aware of that now, yes.

Q. Were you aware at the time?A. I don't believe - no, I would have been. I would havebeen, because I was aware the floats had failed, so, yes,I would have been.

Q. Your awareness that the floats had failed wasa significant issue in your mind at the time, wasn't it?A. Not really. Not really, because I had seen thata lot, as a drilling engineer, so I was aware of theprecautions that a cement operator and a drilling engineeror a drilling supervisor would take to hold that pressureand the steps they would take. So it didn't cause alarmbells, no.

Q. You had encountered float failure a number of timeswhilst working with BHP; is that right?A. A few times, yes.

Q. Can you tell the Commissioner approximately how manytimes you had encountered such a situation?A. It's going back 20 years.

THE COMMISSIONER: Q. Just approximately?A. It wasn't common, but it wasn't uncommon, either.Maybe three or four times.

MR BERGER: Q. Three or four times in seven years withBHP; is that right?A. Well, three or four times, no, in three years asa drilling engineer, because I changed from - but that'sa real guess. It's just a handful of times.

Q. About once a year, while you were a drilling engineer,is your best guess; is that right?A. Maybe, but I'm really stretching my memory there.

Q. Had you encountered floats failing while you wereacting as a regulator?A. In the three years in this job, I don't think I canrecall floats failing, in this role. I couldn't nameanother example than this.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2100

Q. I infer from answers you gave earlier that you hadnever encountered floats failing in a horizontal wellbore;is that right?A. That would be correct. Yes, that would be correct.

Q. Do you agree that all the daily drilling report showsis that the integrity of the casing itself had beeninitially tested?A. Yes, I agree.

Q. And do you agree that the integrity of the casing shoeas a barrier to prevent hydrocarbons entering the wellborehad not been verified or properly tested?A. I agree.

Q. Do you think that in assessing drilling programs inthe future, it would be --

THE COMMISSIONER: May I just interrupt there.

Q. Mr Marozzi, when you say that you agree withMr Berger's proposition that the integrity of the casingshoe as a barrier to prevent hydrocarbons entering thewellbore had not been verified or properly tested, is thatyour view now or was that your view back in March lastyear?A. It's certainly my view now.

Q. But what was your view in March? What was your viewon the day that you received this drilling report?A. That the cement had not been validated, that theintegrity had not been validated.

THE COMMISSIONER: That's what you said to Mr Berger.I was just wanting to make sure that that was yourconsidered answer. Thank you.

MR BERGER: Q. Did you take any steps to raise thisissue with PTT, Mr Marozzi?A. No, I didn't.

Q. Do you think, with hindsight, it would have been goodregulatory practice to have done so?A. In hindsight, absolutely.

Q. Is the reason why you didn't raise it with PTT becausethe morning email suggested, in your mind, that everything

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2101

was in hand and okay?A. That's essentially correct, yes, that's - yes.

Q. Did the morning email of 9 March have any impact onwhat steps you took or did not take at the time?A. Which email?

Q. The email with the purple highlighting that we havebeen discussing.A. That, I guess, yes, reinforced my comfort factor, ifyou like, that the issue of formation - even though it'sthe wrong well, I just realised that today, but the factthat formation integrity test was playing on their mind, itwas programmed on the part of PTT.

Q. Was your position, as of 9 March last year, that yourecognised from the daily drilling report that there hadbeen a significant issue in the cementing of the casingshoe, but a combination of the morning email of 8 March2009 and the email of 9 March 2009 gave you sufficientcomfort that you didn't feel the need to raise anything todo with that with PTT?A. Yes, that's essentially correct, yes, that's right.

Q. Do you accept now that any comfort you drew from theemail of 9 March 2009 is a misplaced comfort; is thatright?A. That's fair enough, yes.

Q. And that comfort is based upon a misreading of theemail?A. Yes.

THE COMMISSIONER: Q. Can I ask you a question,Mr Marozzi: yesterday, when Mr Berger took you to theissue of the secondary barriers, you agreed with him thatboth of those barriers needed to be verified and testedin situ to be regarded as a competent secondary barrier forsuspension purposes.A. Yes.

Q. Is it your testimony today that you do not regard theprimary barrier, the cement in the casing shoe, as havingto be tested and verified before the well is suspended?A. My answer is, no, it wouldn't have been at the time,but I believe my --

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2102

Q. When would it have had to have been - within a day orso or within five months, or when?A. No, soon after, soon after - a few days, a few days.I'm willing to accept that my judgment, perhaps, or myattention to detail was a bit clouded in terms ofrecognising that. From my background in drilling, youdrill through and then if --

Q. But that wasn't the situation pertaining here. Itwasn't a matter of drilling through; this was in thecontext of the suspension of a well --A. Yes.

Q. -- in which, according to what you had approved, therehad to be three verified and tested barriers. Focus yourmind on the situation that you were confronting in Marchand your state of knowledge in March and whether or not itwas reasonable for you to pay detailed attention to thisdrilling report. If you did, that's fine; I want to hearthe full story. But I'm just concerned a little bit, asa witness, you are reading things into situations. Do yourbest, please, Mr Marozzi?A. Yes. Well, the attention given to the reports -I probably did not give adequate compliance monitoringattention in terms of probably not realising, or failing torealise, at the time of this cement job that the rig infact was going to go away.

MR BERGER: Q. Mr Marozzi, a few days after you receivedthe daily drilling report on 8 March 2009, you received theapplication for stage 2 suspension of the H1 well, didn'tyou?A. Stage 2, yes.

Q. The application to suspend for stage 2 was based uponthe casing shoe as a barrier and then twopressure-containing corrosion caps as the other barriers;correct?A. Correct.

Q. At the time you assessed this application for stage 2suspension, you had an understanding that the casing shoewas not a verified primary barrier operating againsta blowout; is that right?A. Yes.

Q. There is no record in the memorandum that you sent to

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2103

Mr Whitfield dealing with the stage 2 suspensionapplication or anything else the Inquiry has come across tosuggest that this understanding on your part has beenreflected in considering the application for the stage 2suspension. Do you agree with that?A. Sorry, I just need you to repeat that, please?

Q. There is no document that the Inquiry has seen thatsuggests your understanding that the casing shoe had notbeen verified as a tested and adequate barrier operatingagainst a blowout --A. Yes, fair comment.

Q. You have given evidence in your statement, and againyesterday, that you required three barriers operatingagainst a blowout prior to being comfortable with a wellbeing suspended; that's right, isn't it?A. Yes.

Q. Yet, a few days after receiving information which youhave said created an awareness that there were doubts aboutthe integrity or the effectiveness of the primary barrier,you nevertheless recommended approval of the suspension ofthe well, didn't you?A. That's right.

Q. And you did so in circumstances in which there was nospecific information about when the third barrier - namely,the 13-3/8" pressure-containing corrosion cap - was goingto be installed on the well; that's right, isn't it?A. No, there was specific information --

Q. What specific information was there, Mr Marozzi?A. In the program.

Q. Did you have an opportunity to review overnight whatit was in the program that gave you that specificinformation?A. Yes.

Q. What do you say told you precisely when the 13-3/8"pressure-containing corrosion cap would be added to thewell to suspend it?A. According to this program, with my figures last night,it would be about between 10 and 13 days.

Q. After what?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2104

A. After the 9-5/8" PCC was installed, so that is --

Q. What is the basis of that calculation, Mr Marozzi?A. It's not explicitly stated in the program, but I canwalk you through it, if you wish.

Q. Perhaps if you could do that briefly, please.A. Yes. Like any drilling programs, time frames are notnormally documented, so it's not a criticism on the part ofthe operator.

Do you want me to give you reference pages first, andthen I can walk you through it, if you like?

Q. Perhaps we can bring up the document and we can gothrough that. If the operator could bring upPTT.9000.0005.0233. Do you recognise this document as therelevant drilling program, Mr Marozzi?A. Yes.

Q. Which part of that would you like to take us to?A. We could go straight to reference number 0276.

Q. That's page 44 of the drilling program?A. Yes, page 44.

THE COMMISSIONER: Q. Just as we are commencing goingthrough this document, what you are referring to in takingMr Berger through this is your understanding at the time,in March last year; it is not you looking at the documentsand coming to that understanding now?A. No. My understanding at the time, in March, was lessthan 10 days. Last night, I came up with a figure.

Q. I just want to make sure that we bring out what yourknowledge is now from reviewing the document, as distinctfrom what you thought was going to be the case in March.Could you make sure --A. Sure, I can walk you through all that.

MR BERGER: Q. Let's be clear about that at the start,Mr Marozzi. What was your understanding, when you assessedthe stage 2 suspension application, about how long it wouldbe between installation of the 9-5/8" PCCC and the 13-3/8"one?A. About two days.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2105

Q. Your understanding at the time was based on what?A. Based on the process I'm about to take you through.

Q. Did you go through that process at the time,Mr Marozzi?A. Yes.

Q. Your evidence to the Commissioner is that in assessingthe stage 2 suspension application, you went back to thedrilling program and went through the various steps; isthat right?A. Yes, very quickly, yes.

Q. In going back to the drilling program and goingthrough the steps you are going to take us to, you came toa view that it would be about two days between the secondbarrier being installed and the third one; is that right?A. Yes - then, yes.

Q. And you have subsequently, last night, gone back tothe drilling program and gone through it again; is thatright?A. That's right.

Q. In doing that, you now have the view that it was about10 to 13 days, in all likelihood, between the installationof the second barrier and the third barrier; is that right?A. The program does reflect that, as I read last night,yes.

Q. That rather suggests that you didn't properly considerthe drilling program in March last year, doesn't it,Mr Marozzi?A. Correct.

Q. It's a failure to consider that has an importantconsequence, I suggest; do you agree with me?A. I agree.

Q. The difference between about 2 days and about 10 to13 days, when you are talking about barriers to suspenda well, is not unimportant, is it?A. Agreed.

Q. That is particularly the case when there are someconcerns that have been raised about the integrity or thereliability of the primary barrier in the well to be

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2106

suspended; that's right, isn't it?A. Agreed.

Q. Could you take us, please, through the relevantaspects of the drilling program that suggested to you inMarch last year the 2 days and now suggest to you a periodof 10 to 13 days?A. It starts on page 39 - in the section 5.29, "Suspendwell - Montara H1".

Q. 5 point what, I'm sorry?A. 5.29. The heading is "Suspend well - Montara H1",step 270, "Recover the casing to surface on the spear".

Q. Yes. What does that signify?A. So at that point there - because this is with a cementplug, this is where they would install the 13-3/8" PCC, sothis is where we start the clock.

Q. Do you mean the 9-5/8" PCC?A. No.

Q. The 13-3/8". Well, you understand, Mr Marozzi, thatI'm asking you about your understanding at the time of thelength of time that would elapse between installation ofthe 9-5/8" PCC and the 13-3/8" PCC?A. Okay.

Q. Do you understand that?A. Yes, I'm with you now.

Q. So telling us when the 13-3/8" PCC is going to beinstalled and the clock is started doesn't really helpmuch, does it?A. No, that's right. I'm sorry, I have started you atthe wrong part. We need to start on page 39.

Q. What is the first entry of significance on page 39?A. 5.24, "Secure well - Montara H1".

Q. Just before we progress through this, Mr Marozzi, canI ask you this: this program is based on suspension usingcement plugs rather than PCCCs; correct?A. Yes, this program reflects that, yes.

Q. What, if any, assumptions did you make that the PCCCswould be installed at exactly the same time that the cement

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2107

plugs would be installed pursuant to the program, if it wasfollowed?A. Just my background in drilling, knowing that theywon't pick up drill pipe and run cement; they will pick upthe running tool and run the cap.

Q. So do I take it from that that you inferred that PCCswould be installed at exactly the same time as the cementplugs would be installed under the drilling program you'reabout to take us through?A. Essentially, yes, yes.

Q. That was a view that you had in March last year; isthat right?A. Yes, that's right.

Q. Is that still a view you have now, that you can safelyassume that pressure-containing corrosion caps would befitted at exactly the same point in the program as cementplugs would have been fitted?A. Yes, I believe so, yes.

Q. You are aware that PCCCs are barriers that can beinstalled offline, are you?A. Yes, I'm aware of that.

Q. So they can be installed by a crane, for example?A. Yes, I'm aware of that.

Q. And they can be installed manually, by a number of menusing a tool of some sort; is that right?A. Yes, yes.

Q. So, really, a PCC can be installed at any stage duringwell activities, can't it?A. It could be, yes.

Q. Subject to the casing being accessible and so on?A. Exactly, yes.

Q. That is certainly not the case with a cement plug, isit?A. There is more opportunity to - obviously, the casinghead has to be visible to install a cap. That's not thecase with cement, that's right. That's right.

Q. So you would have less opportunity to fit a cement

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2108

plug whenever you felt like it than a PCCC; that's right,isn't it?A. Sorry, can you repeat that?

Q. You would have less opportunity to install a cementplug whenever you felt like it than you would with a PCCC;that's right, isn't it?A. Once they have taken off the tie-back, yes, yes. Onceyou have taken off the tie-back, you can't run in withdrill pipe and set a cement plug. Before removing thetie-back, there is plenty of opportunity to run a cementplug.

Q. Well, it is a dangerous assumption to make,I suggest --A. I'm just answering --

Q. -- that in looking at a drilling program dealing withcement plugs, you can assume that pressure-containingcorrosion caps would be fitted at exactly the same stage inthe program; do you agree with that?A. Yes, fair comment.

Q. That was nevertheless an assumption you made as ofMarch last year in assessing the stage 2 suspension; isthat right?A. Yes, that's right.

Q. Bearing that in mind, could you take us through theprogram and tell us what you discerned from it as of Marchlast year and also where your views differ now?A. Okay. So at step 211, they would run in the drillpipe. They have recovered their landing string, sotherefore they are in a position to install the 9-5/8" PCC,just after step 210. So that's our starting point.

Then the next section here is 5.26, on the next page.Now, to estimate that drilling time there, I will need totake you to another reference, but I will walk you throughit first. We have to estimate that drill time, 5.26.

If we continue on to pages 42, 43 and 44, at page 44,where I previously started making an error, at the end ofstep 270 is where they have recovered the 13-3/8" tie-backand so now they are in a position to install the 13-3/8".

Q. So it is the period between about step 210 and

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2109

step 270 where the two barriers are fitted?A. That's correct.

Q. That's your understanding?A. Yes, that's right.

Q. In March last year, you estimated that those stepswould take approximately two days?A. That's right.

Q. And you now estimate that those steps would take about10 to 13 days?A. That's right. Do you want me to continue?

Q. If you wish, Mr Marozzi.A. So to estimate that drilling time I think is where anoversight on my part took place. We need to go toreference 0291, because they are drilling H4, a 12-1/4"section.

Q. You wish to take us to PTT.9000.0005.0291; is thatright?A. Yes. That's right. So if you go to the part therewhere it says, "Set 340mm casing and [nipple up] BOPs".Then just below there, it says "Drill 311mm hole". If wescroll down a bit, that section of drilling commences onday 7 and it finishes on day 19, so there are about 12 daysof drilling.

It is an offset well, and these are normally preparedconservatively. So even if they did really well inmatching the bit with the formation, they probably couldhave shaved three or four days off, but it would still beabout eight days, at least. If you look at thoseeight days, and the days outside that would be estimated atabout two, so I think what I have effectively done is thatI have somehow totally overlooked that the activityinvolved the drilling in between of H4. So that's anoversight on my part.

So if PTT, if Craig or Chris or any other members, hadbeen using a figure as programmed according to that 10, 11,13 days, then they would be absolutely correct.

Q. Have you finished with that page? If the operatorcould bring up PTT.9000.0005.0025 and if we scroll to thebottom part of that page, it is made very clear there, is

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2110

it not, that the stage 2 suspension would take place onlyafter H4 was suspended?A. Yes, that's what it says.

Q. If you had realised in March last year that the H1well was going to be left for a period of at least 8 to12 days, possibly longer, with only a 9-5/8"pressure-containing corrosion cap in place and the cementedcasing shoe, would you, in light of the issues that hadarisen with the cementing of the casing shoe, haverecommended approval of that stage 2 suspension withoutfurther steps being taken?A. No, I don't think I would have. I think I would havepicked up the phone and had a chat to Chris Wilson.

Q. And what do you think you might have said toMr Wilson?A. I'm speculating, but I hope I would have saidsomething along the lines of, "Two to three days is fine,but eight to nine is just getting a bit too wide forcomfort. Is there a way we could reduce that window?" Andif, for argument's sake, there wasn't a way to reduce thewindow, I believe I probably would have asked him toconsider that we had better validate that cement shoe.

Q. You would have been content, would you, to have reliedon the unverified cemented casing shoe and the 9-5/8"pressure-containing corrosion cap as the barriers operatingagainst a blowout for two to three days?A. No, that's not what I said. I wouldn't be contentwith that. I would have rung Chris Wilson or Craig Duncanand had a discussion along the lines that if we can'treduce that margin from ten days or so down to two orthree, then we either need to change the program, perhaps;if we can't do that, we would probably need to validate theintegrity of that 9-5/8" cement shoe.

THE COMMISSIONER: Q. That wasn't Mr Berger's question,Mr Marozzi. I just implore you to listen to his questions,please.A. Okay.

MR BERGER: Q. The question that I asked, Mr Marozzi,was, in light of your evidence that if you had hada conversation with Mr Wilson, you would have said words tothe effect of, "Two to three days is fine, but we need toreduce that window down from eight to ten days", the effect

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2111

of that evidence, I suggest, is that you would have beencontent to leave the well with the cemented casing shoe andthe 9-5/8" pressure-containing corrosion cap for two tothree days; that's right, isn't it?A. Yes, that's fair comment.

THE COMMISSIONER: Q. But is it also the case,Mr Marozzi, that assuming the two-day to three-day horizonapplied, you would have been content with the 9-5/8" beingin place, assuming it was tested and verified, and the13-3/8", assuming it had been tested and verified, butwithout the primary barrier being tested and verified fora period of six months?A. In hindsight, I wouldn't be happy with that, but atthe time.

Q. But that was your state of knowledge at the time, thatyou would have overlooked the fact that PTT was notcomplying with their own well construction standards or, byany stretch of the imagination, good oilfield practice?A. Well, no, I would have been aware that the - I didn'tget the well construction standards out and check them onthat, on 7 March.

Q. Not just having regard to the well constructionstandards; the importance of having a verified and testedprimary barrier before suspension, even if you didn't seethe well construction standards.A. I think I neglected that part about validating thatprimary barrier, given that the rig was going to leave.

Q. Yes. You forgot that part and you didn't reflect onit in your advice to the delegate to the DA, either?A. I'm sorry?

Q. You didn't make any mention to the delegate to the DAabout the situation that you were confronting in youradvice to him?A. That's correct.

MR BERGER: Q. Could the operator please bring upPTT.9000.0005.0026. Do you recognise that as a suspensiondiagram for stage 2 of the H1-ST1 well?A. Yes.

Q. If the operator could scroll down slightly, do you seethat there is a reference to casing pressure tested to

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2112

27.6 MPa and left with inhibited seawater?A. Yes.

Q. Did you have a view at the time about whether thatinhibited seawater could be considered a barrier operatingagainst a blowout?A. Yes, I don't regard that as a barrier.

Q. And the reason you didn't regard it as a barrier waswhat?A. I have just been taught that you don't regard thedrilling fluid as a permanent barrier. It adds hydrostaticweight, but it can't be relied upon.

Q. So the circumstance as at 13 March last year, whenapproval for stage 2 suspension was granted by Mr Whitfieldon the basis of your assessment and recommendation, wasthat we had a casing shoe which could not be considereda verified barrier against a blowout; correct?A. Correct.

Q. And it was a casing shoe where issues of a significantnature had recently arisen in relation to the cementingjob; correct?A. We didn't know overdisplacement had occurred, butfloats --

Q. But you knew that there had been problems with thefloat and a sudden flow from beneath the casing shoe, andso on, didn't you?A. I was aware of that, yes.

Q. And you were aware that there had been no remedialaction taken; is that right?A. That's right.

Q. And you may have formed a view, based on the email of9 March, that some remedial action might be taken; is thatright?A. That's right.

Q. But that was based on a misreading of the relevantinformation; correct?A. That's correct.

Q. You also, based on a misreading of relevantinformation, took the view that the third barrier would be

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2113

installed approximately two days later; is that right?A. That's correct.

Q. So do you accept that your failure to carefullyconsider the relevant information led to approval for thestage 2 suspension being given when it should not have beengiven?A. Agreed.

Q. In addition to those problems, we also have the factthat the second and third barriers, whenever they weregoing to be fitted, were not, to your knowledge, going tobe tested and verified in situ; that's right, isn't it?A. It's compliance monitoring, that I would have expectedthey are done, but I do agree with you.

Q. So we had the situation in which the H1 well wassuspended, on your assessment and recommendation, with nota single tested, verified barrier to prevent a blowout;that's right, isn't it?A. As it turns out, that's correct, yes.

Q. That's a significant failure to comply with goodregulatory practice, isn't it?A. Agreed.

THE COMMISSIONER: Q. Mr Marozzi, can you account forwhy none of this was brought out in your statement? Notone thing you have said of significance have you broughtout in your statement to this Commission.A. There are parts that I wasn't aware of during thewriting of the statement. For example --

Q. But what I have heard today is the state of yourknowledge in March.A. Yes.

Q. So you did have a state of knowledge as to thesituation, what you had approved and what recommendationsyou had made to Mr Whitfield?A. That's right.

Q. But it is not reflected in your statement?A. The delay of the two --

Q. No, the fact that you were authorising temporarysuspension without having a tested and verified primary

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2114

barrier, et cetera - it never occurred to you to bringthose to my attention in your statement?A. Well, not specifically in that way, not because I wastrying to hide information, but because most of this isabout compliance monitoring, and there is only a particularlevel I can take that to.

Q. I understand that, but your testimony today is thatyour state of knowledge was such that a person in yourposition should have applied themselves a lot morediligently than you seem to have done, and you haveconceded that point by the force of your testimony thismorning.A. Yes, I accept that.

MR BERGER: Q. Not only is there no reflection of thesematters in your statement, Mr Marozzi; there was noreflection of these matters in any way whatsoever in theadvice you provided to the delegate, was there?A. Not specific to this, that's correct.

Q. Do you accept that you did Mr Whitfield a disservicein providing assistance to him in fulfilling his importantrole as delegate of the designated authority?A. Yes, I accept that.

Q. You said a short while ago that you overlooked theneed for verification of the primary barrier - namely, thecemented casing shoe - given that the rig was going toleave; do you recall giving that evidence?A. Yes.

Q. Does that reflect your understanding at the time thatit is only if the rig is going to leave that you need tohave a verified primary barrier?A. It reflects my understanding that it is far moreimportant if the rig is going to leave, yes.

Q. I suggest that it is important even if the rig isgoing to remain in place that you verify the primarybarrier operating against a blowout; do you agree withthat?A. That's correct, yes.

Q. And it is important that you verify it as soon aspossible after wait on cement, not some days, weeks ormonths down the track; do you agree with that?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2115

A. Generally speaking, yes.

Q. Was that your understanding as of March last year,Mr Marozzi?A. No, not really, because, again, I believe that I -I didn't draw enough attention to it, given this batchdrilling sequencing and that then the rig was leaving.

Q. What does batch drilling have to do with that,Mr Marozzi?A. It just adds a whole level of complexity to it, asopposed to just one rig on one well.

Q. Well, even if you have one rig on one well, I suggestthat you should still verify the primary barrier operatingagainst a blowout as soon as practicable after wait oncement; do you disagree with that?A. No, I don't disagree.

Q. How does the fact that it is a batch drillingoperation change that basic principle of oilfield practice?A. It doesn't change those fundamentals; that's correct.

MR BERGER: Is that a convenient time, Commissioner?

THE COMMISSIONER: It is, thank you, Mr Berger.Thank you, Mr Marozzi. We will resume at 11.20.

SHORT ADJOURNMENT

MR BERGER: Q. Mr Marozzi, before asking you furtherquestions about the daily drilling report and relatedmatters, could I ask you to listen very carefully to theentire question that I ask you and then decide what answeryou wish to give. Do you understand what I'm asking you todo?A. I understand.

Q. When you assessed the stage 2 suspension application,what was your expectation at that time - that is, in March2009 - with respect to the time line for the verificationof the casing shoe? Do you understand what I'm asking you?A. No, if you could just repeat that?

Q. When you assessed the stage 2 suspension applicationin March last year, when did you think verification of thecasing shoe, by pressure testing or otherwise, was going to

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2116

occur?A. My understanding there was when they were going todrill through the shoe and do a leak-off test.

Q. Is that upon re-entering the well after suspension?A. That's right.

Q. You were content to recommend approval of suspensionof a well without a verified primary barrier; is thatright?A. Not content, but that failed to dawn on me like that.

Q. Well, the two answers you have just given, Mr Marozzi,I suggest are inconsistent. The first answer you gave, asI understood it, was that you had an understanding at thetime that verification would occur upon re-entry; is thatright?A. Yes.

Q. That was some months after the well had beensuspended; correct?A. That's right.

Q. The last answer that you gave suggested that thiswasn't something that dawned on you at the time; is thatright?A. Yes, that's right.

Q. So is it the case that you had a conscious awareness,in March last year, that the casing shoe wasn't going to beverified until re-entry, or was that something that youdidn't turn your mind to?A. I didn't really turn my mind to that and put two andtwo together.

Q. So the position is that you now accept thatverification of the casing shoe wasn't going to occur untilre-entry, but, at the time, that wasn't something that youturned your mind to and reached a view about; is that thecase?A. That's correct.

Q. And you would accept that that is something that youshould have turned your mind to at the time; is that right?A. I accept that.

Q. So when answering my questions, please try to listen

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2117

to them carefully and distinguish whether I'm asking youabout your understanding at a particular point in time oryour understanding as you sit there in the witness box now,perhaps making assumptions or having revisited information.Do you understand what I'm asking you to do?A. I understand.

Q. Could the operator please go to PTT.9001.0007.0346.We are returning to the daily drilling report. Do yourecognise that, Mr Marozzi?A. I do.

Q. If the operator could please go to page 2 of thereport and if you could again look at the entries between10:30 and 14:00 inclusive, Mr Marozzi.A. Yes.

Q. Do you understand now that what is signified in thoseentries represents actions that are likely to havecompounded the problems created by the failure of the floatvalves?A. As I understand it now?

Q. Yes.A. Yes.

Q. And do you understand now that the problems with thefailure of the float were compounded by an overdisplacementof the casing shoe; do you understand that?A. I understand.

Q. And do you understand now that these actions arelikely to have led to what is called a wet shoe; do youunderstand that?A. I understand that.

Q. Is that understanding based on an awareness that youhave come to have about the volume of the casing shoe trackin any part?A. No, that understanding has come about from whatevidence has been put forward in this Inquiry.

Q. So the first you became aware that there was likely tohave been a wet shoe was from evidence that has been givenin this Inquiry; is that correct?A. That's correct.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2118

Q. Can you pinpoint any particular aspect of thatevidence that has led to that view in your mind?A. I'm not exactly sure on the exact day, but it was whenit came out that the overdisplacement had occurred.

Q. Did that understanding that you now have arise fromreading transcript or a press report, or what?A. It probably was a transcript.

Q. And you read evidence where somebody conceded thatthere had been an overdisplacement of the casing shoe trackand therefore a wet shoe; is that right?A. That's right.

Q. Until you read that evidence, did you have anyunderstanding that that was what had happened to the casingshoe in the 9-5/8" casing of the H1-ST1 well?A. That's right, I had no understanding until then.

Q. Do you accept that, within the four corners of thedaily drilling report and specifically the entries I havedirected your attention to, there is enough information forsomeone with your skills and experience to pick up thatthere is likely to have been an overdisplacement of thecasing shoe, if they read the document very carefully?A. I accept that.

Q. Is there any explanation that you can give to theCommissioner about why you didn't pick it up at the timethat you read the daily drilling report?A. Do you want me to explain that again, with the morningupdate?

Q. Well, you give your best account of why you think youdid not pick it up at the time?A. I did not give it that level of detail - that level ofscrutiny, being - well, that's it. I did not give it thatlevel of scrutiny.

Q. So the position is that you didn't read the dailydrilling report carefully enough --A. That's correct.

Q. -- to recognise what it reflected; is that right?A. That's correct.

Q. And you didn't read it carefully enough in part

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2119

because of the morning email that you had received prior toreceiving the daily drilling report; is that your evidence?A. In part, that's right, yes.

Q. I would like to ask you some questions now,Mr Marozzi, about the approval of the 1B drilling programin July 2009. Do you understand what I'm referring to?A. Yes.

Q. Could the operator first go to WIT.4000.0002.0009,please. This will be the statement that you have given tothe Inquiry, Mr Marozzi. I would like you to readparagraphs 24 and 26, please. Do you agree that in theseparagraphs, you are dealing with the 1B drilling programof July 2009?A. Yes.

Q. You are specifically saying that in making theassessments you did to make the recommendation toMr Whitfield, you considered the requirements of theapplicable regulations; that's right, isn't it?A. Yes, that's right.

Q. By that, do you mean the management of welloperations?A. Sorry, can you repeat that?

Q. When you refer to your considering the requirements ofthe applicable regulations, do you mean the management ofwell operations regulations?A. Yes.

Q. And you also refer to having regard to soundengineering principles and practices; that's right, isn'tit? Paragraph 26(b).A. Could we just scroll down? Yes, right.

Q. By that, do you mean to refer, in part, to yourunderstanding of good oilfield practice?A. I'm sorry, what's the question?

Q. When you refer in paragraph 26(b) to makingassessments based, in part, upon sound engineeringprinciples and practices, do you intend to suggest therethat that included, in part, your understanding of whatconstituted good oilfield practice?A. That's fair comment, yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2120

Q. Did I understand your evidence yesterday correctly tosuggest that your understanding of good oilfield practicewas what industry generally accepts in relation toparticular well activities?A. Generally, yes, yes.

Q. If something was proposed that was not, to yourknowledge, something that industry generally accepts, is ityour practice to require some information or explanationabout why it is something that constitutes soundengineering principles or practice?A. That's a fair comment, yes.

Q. Could we go, please, to NTG.0001.0005.0032, and couldwe scroll down. Do you recognise this, Mr Marozzi, as yourmemorandum to Mr Whitfield, as delegate, dealing with the1B drilling application?A. Yes.

Q. If we could scroll down further, please, do you seeunder the heading "Time frame", you have said there:

Some additional information that wasrequested was received 7 July 2009.

A. Yes, I see that.

Q. Do you recall now what additional information yourequested, or somebody requested?A. I can't be sure. It might have been certificates ofinsurance. I'm not really sure.

Q. Do you agree it would have been helpful to have toldMr Whitfield what additional information was requested andwhat, if any, was received in response?A. It wouldn't have hurt, yes.

Q. If the operator could please go to PTT.9000.0002.0005and if we could scroll through from 0005 to 0008, whichshould be page 4. Could you look at this while it isoccurring, Mr Marozzi? Do you recognise that as thedrilling program in question?A. I do.

Q. If the operator could next go to PTT.9000.0002.0043and scroll through slowly to 0046, which will be page 42,

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2121

and if you could read this while that is occurring,Mr Marozzi?A. Are you asking me to read the whole thing?

Q. Just have a look at it and I will ask you what itrefers to in a minute.A. Yes.

Q. Do you recognise this as the part of the drillingprogram relating to steps leading up to the tying back ofthe casing?A. I do.

Q. And dealing with the tying back of the casings ona number of the wells?A. Yes.

Q. It is very clear from the documents that I have justreferred to that this is a batch drilling operation, isn'tit?A. That's right.

Q. You had an understanding, I take it, when you assessedthis application, that there were five wells?A. Yes.

Q. Namely, the H1, the H2, the H3, the H4 and the GIwells; is that right?A. That's right.

Q. That being the case, you would expect the derrick tobe over any given well approximately 20 per cent of thetime; is that the case?A. Yes, that's a fair comment, yes.

Q. Was there any information that you had to suggest thatthe derrick would be over one of the wells more than thatamount of time?A. I don't recall considering that.

Q. When you have a batch drilling operation in relationto five wells, the reasonable assumption is that thederrick would be over any given well approximately a fifthof the time; is that a reasonable assumption?A. Yes.

Q. And is that an assumption that you made in assessing

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2122

the drilling application in July last year?A. Yes, yes, generally.

Q. There is nothing in the drilling program, I suggest,to suggest that the pressure-containing corrosion capsreferred to in the program were going to be taken offthrough a blowout preventer or with a production tree inplace, was there?A. That's right.

Q. It is also very clear from the program, I suggest,that the 9-5/8" pressure-containing corrosion cap was goingto be removed from the H1 well after all other wells hadcompleted the tie-back of their 13-3/8" casing; do youagree with that?A. I'm sorry, can you just repeat the question aboutwhich cap was being removed?

Q. The removal of the 9-5/8" pressure-containingcorrosion cap from the H1 well was going to take placeafter all other wells had completed the 13-3/8" casingtie-back; do you agree with that?A. I agree.

Q. Do you need to go back to any other part of thedrilling program, or are you happy that that is the case?A. No, I believe that is the case, yes.

Q. Was it your understanding at the time - and I'mdirecting your attention to July last year when youassessed this program - that the program would leave the H1well with only one barrier for a period of time?A. Yes, I understood that.

Q. What was your understanding at the time - thatis, July last year - as to how long that period would be,where the well was left with one barrier?A. I estimated that to be between about 8 to 10 hours.

Q. And you have a clear recollection, as you sit theretoday, of having that view in July last year; is thatright?A. That's right, yes.

Q. Is that a view that you continue to have today, thatthat is likely to have been the period, if the program hadproceeded as planned, that the well was left with one

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2123

barrier?A. I believe so, yes.

Q. What is the understanding that you had then, and stillhave now, based upon?A. Just working through each of these phases of theoperation in the program and doing an estimate of whatI believe it would take, how long it would take, and thenmultiplying by four.

Q. Multiplying by four, did you say?A. When going through the order, the order of thetie-backs.

Q. Yes. Why would you need to multiply by four?A. Because when the first tie-back of H1 commences, the9-5/8" is removed. I'm sorry, I might have misunderstoodyour question.

Q. I'm asking what your understanding that the H1 wasgoing to be left for a period of 8 to 10 hours with onlyone barrier in place was based upon?A. Do you mean given the 9-5/8" PCC has been removed?Sorry.

Q. When you assessed the drilling application in Julylast year, is it the case that you understood that theprogram, if approved, would lead to the H1 well being leftwith only one barrier in place for a period of 8 to10 hours?A. Yes, that one barrier being the casing shoe.

Q. Correct.A. Yes.

Q. I'm asking you what that understanding is based upon?A. Yes. That understanding is --

Q. I am sorry, what that understanding was based upon?A. Yes, that understanding is based upon, at the time,going through the program here and nominating where the9-5/8" PCC is removed, until the time a BOP has beeninstalled.

Q. There is no need to multiply anything by four in doingthat, is there?A. It is just based on the assumption - well, going

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2124

through, they are very, very similar operations for each ofthe tie-backs, because you tie back from H1, then on to H4,then on to H2, H3, and then the BOPs are installed.

Q. Was this a calculation that you recall doing in Julylast year when you assessed the drilling program?A. No. Because the time frames here were not included,it was just an estimate, yes, a reasonably rough estimate,because it is very hard to get a real grip on exactly howlong things will take. It is a rough estimate of justgoing through what I believe of these little steps thatmake up the tie-back phase.

Q. But is this calculation or estimate, as you havereferred to it as, something that you did in July last yearwhen assessing the application, or is it something you havedone subsequently?A. I have checked it subsequently.

Q. But you did it at the time?A. Yes.

Q. Do you accept that things can take longer than youmight estimate, and therefore there is no guarantee that itwould have only been 8 to 10 hours that this state ofaffairs would have remained?A. I agree.

Q. If something had gone wrong, that period of 8 to10 hours could have blown out to some degree; do you acceptthat?A. That's right, yes.

Q. Did you have an understanding, at the time youassessed this program, where the derrick would be whilstthe H1 well was left with only one barrier, namely, thecemented casing shoe?A. No, I did not. I did not bring that intoconsideration.

Q. Does the drilling program provide for the verificationof the cemented casing shoe as a barrier?A. Yes, there is a pressure test in there. They have topressure test the entire casing string. That's shortlyafter they remove the 9-5/8" PCC. I can nominate that, ifyou like, or draw your attention to it.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2125

Q. But your understanding, at the time that you assessedthe drilling program, was that shortly after the 9-5/8"pressure-containing corrosion cap was going to be removed,the integrity of the primary barrier would be verified bya pressure test; is that right?A. Yes, I recall that in the program, yes.

Q. And that verification of the cemented casing shoe asa primary barrier was going to take place shortly after theremoval of the 9-5/8" pressure-containing corrosion cap; isthat right?A. According to the program, yes.

Q. Was that a factor that influenced your assessment ofthe drilling program in any way?A. Well, at the time, of course, I wasn't aware that -well, yes, there is some influence there, because they'reundertaking their pressure test, yes, to verify thatbarrier.

Q. If, for example, the verification of the cementedcasing shoe was going to take place many days after the9-5/8" pressure-containing corrosion cap was taken off,would your assessment of the program differ, in your view?A. It could have. It could have.

Q. Why is that?A. Well, that means, then, that that validation is nothappening so soon, before those BOPs are installed. I'mconcerned that the BOPs are not installed immediately, butthere is a fair gap there that is allowable.

Q. Is it the case that, in your view at the time, it wasone thing to have the well with only a cemented casing shoein place for 8 to 10 hours if that cemented casing shoe wasgoing to be verified shortly thereafter, if there were anydelays, but it was another thing if that verificationwasn't going to occur shortly after the 9-5/8"pressure-containing corrosion cap was removed?A. It would change things a bit. I would have to havea re-evaluation of it or a discussion with someone.

Q. Because your evidence is that when suspending thewell, you like to see three barriers; that's right, isn'tit?A. Yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2126

Q. You draw a distinction, I take it, between suspendinga well and other drilling activities, because when the wellis suspended, the rig leaves; is that right?A. That's right.

Q. Do you think that is a somewhat crude distinction todraw when you are dealing with batch drilling operationswhere the derrick is not going to be over a particular wellfor 80 per cent of the time or so?A. Possibly. It does require another consideration, yes.

Q. Is that something that you turned your mind to in Julylast year or not?A. No, not specifically where the derrick was going tobe, no.

Q. Do you accept, sitting there now, that that issomething that you should have turned your mind to,Mr Marozzi?A. Yes, I accept that.

Q. The rig was over the Montara development at the timeof the blowout last year, wasn't it?A. I'm sorry, say that again?

Q. The rig was present when the blowout occurred, wasn'tit?A. Yes, that's right.

Q. Are you aware of any steps that the rig was able totake to mitigate against the risk of a blowout or seek toprevent it happening before it occurred?A. If they were aware there was a problem happening?Sorry, can you --

Q. No, I'm asking you about your understanding of whatactually happened on the day of the blowout. Do you haveany understanding of what, if any, steps the rig was ableto take to stop a blowout?A. Yes, they could have moved the rig over and picked upan RTTS packer, a temporary packer, like an RTTS, andinstalled that.

Q. Well, they weren't able to do that, obviously, werethey, Mr Marozzi?A. With the rig away, no, that's right, they couldn't.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2127

Q. Well, the rig was present, but the derrick was overa different well; that was the problem, wasn't it?A. That's right.

Q. And it wasn't possible to bring the derrick back tothe H1 well in time to do anything to prevent the blowout,was it?A. Right, that's right.

Q. That rather signifies the danger of relying on thepresence of the rig in drawing a distinction between whatyou require in order to have well integrity when you aredealing with a batch drilling operation; do you agree withthat?A. I agree with that

Q. That's a very salutary lesson about the approach thatshould be taken in considering well integrity for a batchdrilling operation; do you agree with that?A. I agree with that.

Q. It rather suggests that when you are dealing witha batch drilling operation, the requirements that you havein relation to the suspension of a well should closelyreflect your requirements at the time of re-entry inconducting well activities after that point; do you agreewith that?A. Yes, I agree with that.

Q. When you are dealing with a batch drilling operation,where the derrick isn't going to be present over a well fora significant proportion of the time, it is not goodoilfield practice, I suggest, to leave that well with onlyone barrier for any period of time; do you agree with that?A. That's a fair comment, yes.

Q. That is particularly the case where that one barrierhasn't been verified or tested or proven as a likelyeffective barrier operating against a blowout; do you agreewith that?A. Yes, I agree.

Q. Do you agree, then, that with hindsight, it was notgood regulatory practice to have recommended approval ofthe 1B drilling program that was going to have theconsequence that the H1 well was open to atmosphere withonly one barrier in place for approximately 8 to 10 hours?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2128

A. That's a fair comment.

Q. I suggest one of the reasons for that is what iscontained in your statement, namely, that sound engineeringprinciples require redundancy, don't they?A. Can you just explain that question a bit better?

Q. Sound mechanical engineering principles require thatthere be some allowance for redundancy, namely, that therebe a second barrier; do you agree with that?A. Yes, I agree.

Q. For the same reason that aircraft don't fly with onlyone engine, in most instances, it is not a good practice tohave a well open to atmosphere with only one barrier forany period of time; do you agree?A. I agree with that.

THE COMMISSIONER: Lots of aircraft, Mr Berger, fly withone engine. In fact, if an aircraft has two or fourengines, maybe you are increasing your chances of an enginefailing.

MR BERGER: Maybe, Commissioner. We don't need to pursuethat too much further, hopefully.

Q. Do you agree with this, Mr Marozzi, that having twobarriers in place is infinitely safer than having onebarrier in place when we are dealing with a well?A. Absolutely.

Q. Are the matters we have just canvassed matters thatyou are going to reflect upon and adopt in assessingdrilling applications in the future?A. Correct.

Q. What lessons do you think you have learnt from theblowout in relation to appropriate well control and wellintegrity in relation to the barriers that should be inplace?A. Sorry, can you repeat the question?

Q. What lessons have you drawn from the subject matter ofthis Inquiry in terms of how you are going to go aboutassisting the delegate fulfil his functions in the future?A. Well, it's the lesson about the primary barrier beingverified. That's certainly a fundamental one, given that,

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2129

in this situation, the rig was leaving, and then we havea situation as you described, with one barrier left beforethe BOPs are installed. That one barrier has not beentested. That's probably the big one.

Q. Were you aware, in July last year, that problems withcementing of a casing shoe were not uncommon?A. Sorry, can you repeat that?

Q. Were you aware, in July last year, that problems withthe cementing of a casing shoe were not uncommon?A. Yes, I was aware.

Q. And were you aware, in July last year, that problemswith cementing of a casing shoe was one of the leadingcauses of blowouts in wells worldwide?A. I wasn't aware of that, but I accept that.

Q. Does it surprise you to hear that?A. Yes. I haven't seen that data, but I accept it, ifthat is the case.

Q. Did you have any understanding, in July last year, ofwhat was the primary cause of blowouts in wells across theworld?A. No, I can't say I have researched that.

Q. But you understood that a cemented casing shoe, beingthe primary barrier, was a fundamental component of wellintegrity, didn't you?A. Yes.

Q. The drilling report shows, if the operator couldplease go to page 0019 of this document, which was where weinitially were, two paragraphs up from the heading"Montara H2", that there were problems with the cementingof the casing shoe; that's right, isn't it?A. That's right.

Q. And specifically that the floats failed; correct?A. Yes.

Q. Do you recall reading this in assessing theapplication?A. I believe so, yes. Yes.

Q. Do you recall that prompting any recollection of what

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2130

you had learnt from the morning email of 8 March or thedaily drilling report that you received on that day?A. I can't be sure, but I believe so. I believe - yes,the floats failing wouldn't have been a surprise; thatwould have jogged a memory.

Q. Did that prompt you to go back and look at thedocuments from the time?A. Go back to the DDR? No.

Q. Do you think that should have, with hindsight, beensomething that you did prior to recommending approval ofthe 1B drilling program that would, for a period of time,have only the cemented casing shoe as a barrier operatingagainst a blowout?A. Yes, it might have helped me draw particular attentionto that DDR and then scrutinise it further. That'spossible, yes.

Q. I suggest, Mr Marozzi, that relying on only thecemented casing shoe as a barrier operating againsta blowout for any period of time is not good practice, butthat's particularly the case when there have been problemsidentified with the cementing of that casing shoe; do youagree with that?A. I agree.

Q. If we could go, please, to WIT.4000.0002.0015, inparagraph 52(b) of your statement, you say there that you"understood that there were the following barriers on theH1-ST1 well", and you list them there as the 9-5/8" casingcement shoe, the hydrostatic column of seawater, the 9-5/8"pressure-containing corrosion cap and the 13-3/8"pressure-containing corrosion cap; is that right?A. Yes.

Q. Is that something that you understood at the time thatyou were assessing the drilling program?A. Yes.

Q. What understanding did you have, at the time you wereassessing the drilling program, of the status of what youreferred to in paragraph 52(b) of your statement - thehydrostatic column of the seawater?A. That it adds hydrostatic column but is not regarded asa permanent barrier.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2131

Q. Is it a temporary barrier, Mr Marozzi?A. Perhaps, yes.

Q. What was your understanding of the status of thehydrostatic column of seawater in terms of whether it couldbe considered an effective barrier, at the time youassessed the drilling program in July last year?A. It's based on the understanding that the Montara -this well is not a new well; it is part of a development,so I would expect the operator to have the overbalancesorted out by now. So it is based on the understandingthat this is not a new well where they don't understand thereservoir pressure or the pore pressure. They have plentyof data on that.

Q. So was it an assumption you had, in assessing thedrilling program in July last year, that PTT would haveensured that there was an overbalance of the hydrostaticcolumn of seawater to pore pressure?A. Yes. That is something that I would expect theoperator to do, absolutely.

Q. But that was purely an assumption on your part, wasn'tit?A. An assumption or an expectation, yes, yes.

Q. Did you understand, at the time you assessed thedrilling program, that it was a verified temporary barrierthat would operate against a blowout?A. Say that again, sorry?

Q. Did you understand, at the time that you assessed thedrilling application, that the hydrostatic column ofseawater was a verified barrier of a temporary natureoperating against a blowout?A. I'm not really - no, not regarded as a permanentbarrier. I'm not really sure on how you are asking thequestion.

Q. I'm asking you about its status as a temporarybarrier, Mr Marozzi. Do you understand that?A. Yes. Okay.

Q. I understand that you don't consider it a permanentbarrier.A. Okay.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2132

Q. I'm asking you what your understanding is of itsstatus as a temporary barrier, how reliable it is. Do youunderstand what I'm asking you?A. I understand.

Q. So could you tell the Commissioner what yourunderstanding was in July last year, when you assessed thedrilling program, of the status of the hydrostatic columnof seawater as a temporary barrier?A. That it will provide a certain amount of overbalanceand is not regarded as permanent, but as a temporarybarrier, in which the properties could change, butbasically provides a hydrostatic column that adds to anoverbalance that can act as a barrier.

Q. Did you have any understanding of what the porepressure was at the time that you assessed the drillingapplication?A. No, I wouldn't have looked at that.

Q. And did you have any understanding of what thehydrostatic pressure of the seawater was at the time youassessed the drilling application?A. No, I don't do those sorts of calculations andduplicate the work of the operator, no, I didn't do that.

Q. So did you understand at the time that there wasa need for a significant margin of comfort in relation tothe overbalance of seawater to the pore or formationpressure?A. Yes, that is something I would expect the operator totake care of, yes.

Q. Again, you had no specific knowledge that there wassuch a significant margin of comfort; it was just somethingthat you assumed PTT would ensure was in place?A. Yes, for this situation, I would expect the operatorto know those figures and to install a particularoverbalance that they are comfortable with, yes.

Q. Why would you assume or expect that that's somethingthat PTT would do?A. Like I said, this is not the first well that wasdrilled in this field. There were a lot of other Montarawells preceding this operation, so the operator has a lotof data about pore pressures and reservoir pressure. Theyare not learning new data. They have that data. That data

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2133

goes back to when BHP drilled the first Montara well in thelate 1980s. They have access to all that data.

Q. Was it your view, when you assessed the applicationfor drilling, that having had this information in relationto formation pressure for a long period of time, PTT couldbe trusted to ensure that there was a significant margin ofcomfort in term of the overbalance of seawater to formationpressure?A. Yes.

Q. And that's something that you would expect a sensibleoilfield operator to do; is that right?A. Yes.

Q. Without seeing any information to show that that hadoccurred, it was something you were comfortable would havebeen in place; is that right?A. That's right, yes.

Q. Did you understand, at the time you assessed thedrilling application, that in order to constitute aneffective barrier against a blowout, fluid needs to bemonitored and maintained?A. That's fair comment, yes.

Q. Really, that means that the fluid needs to be hookedup to the circulation system, doesn't it?A. That's correct, yes.

Q. It is quite clear from the drilling program that thatwasn't the status of the fluid in the well at the relevanttime that we are talking about; that's right, isn't it?A. Sorry, can you repeat that?

Q. It is quite clear from the drilling program that thefluid in the well would not have been hooked up to thecirculation system at the time the well was left with onlythe casing shoe as the barrier; that's right, isn't it?A. That's right, yes.

Q. And, in fact, a well can't be hooked up to thecirculation system when it has caps on it; that's right,isn't it?A. That's right. They have to tie back, yes.

Q. At the time the well was going to be left with only

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2134

the casing shoe in place, it wouldn't be at that pointwhere you could have hooked it up to the circulationsystem; was that your understanding?A. I'm sorry, can you repeat that?

Q. At the time the drilling program envisaged the H1 wellbeing left with the primary barrier of the cemented casingshoe and no other barrier, was it your understanding thatthe fluid in the well would not be hooked up to thecirculation system?A. I did not take that into consideration. I didn'tscrutinise to that level. The operator is best placed todo that.

Q. If the operator could please go toSUBM.4000.0001.0001, page 14, and if you could direct yourattention, Mr Marozzi, to paragraph 45, do you recognisethis as the submission that the Northern Territory has madeto this Inquiry? We can scroll up or down if that wouldassist.A. No, for 45?

Q. Yes. First of all, do you recognise the document thatI am directing your attention to?A. I'm not sure. Is it our submission?

Q. Perhaps if the operator could scroll up - that's thefirst page of the document, Mr Marozzi. Do you recognisethat?A. Okay, yes.

Q. Then if you assume that paragraph 45 is containedwithin this document, do you agree that it is part of thesubmission that the Northern Territory has provided to theInquiry?A. I agree, yes.

Q. I understood your evidence to the Inquiry to have beenthat this part of the submission was something that youwere heavily involved in drafting; is that right?A. Which term of reference, though, is this?

Q. It's in relation to term of reference 2.A. Yes, I provided information and assisted in writingmost of these parts, yes. Not all but most, yes.

Q. Specifically, is paragraph 45 something that you

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2135

recognise as the result of input from yourself?A. It's not something I believe I would have written.I don't really recognise that as something I would havewritten.

Q. But something you have clearly read and not disagreedwith; is that right?A. That's right, yes.

Q. Because your evidence was that if there was anythingin the submission that you disagreed with, you would drawit to the attention of the relevant people?A. Yes.

Q. And that's not something that you did in relation tothis paragraph; correct?A. Correct.

Q. As you sit there now, do you consider thatparagraph 45 is accurate, namely, that the drilling programmet the requirements of the Act, the regulations and theapplicable guidelines and was consistent with good oilfieldpractice?A. In particular, which - sorry, okay, can you ask thequestion again?

Q. I want to suggest to you, Mr Marozzi, that leaving theH1-ST1 well open to atmosphere with only the cementedcasing shoe in place operating as a barrier againsta blowout for a period of time in situations where therehad been an issue arising with the cementing of the casingshoe and there had been no verification of that barrier wasnot good oilfield practice; do you agree with that?A. Yes, I agree.

Q. I am therefore suggesting to you that what is said inparagraph 45 of the Northern Territory's submission is notcorrect; do you agree with that?A. It is not totally correct, that's right, yes.

Q. Is it the case that you are no longer satisfied thatthe 1B drilling program was consistent with good oilfieldpractice?A. That's a fair comment.

Q. Do you agree, as you sit there today, thatrecommending approval of the 1B drilling program was an

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2136

error on your part?A. Yes, I accept that.

Q. If the operator could please go to DMP.9001.0001.0001,you will see, Mr Marozzi, that this is a submission fromthe Western Australian Department of Mines and Petroleum;do you see that?A. I do.

Q. I think you have agreed previously that that is theWestern Australian equivalent of the Northern TerritoryDepartment of Resources; that's right, isn't it?A. Yes.

Q. If the operator could please go to DMP.9001.0002.0001,do you see there, Mr Marozzi, that the Western AustralianDepartment of Mines and Petroleum is providing informationto the Inquiry in relation to good oilfield practice inrelation to casing cementation?A. I see that.

Q. Could the operator please go to DMP.9001.0001.0001 andscroll down slowly. Do you see, Mr Marozzi, that theWestern Australian regulator is telling the Inquiry thatthey would not permit an undepleted live well to be openwith only one primary barrier and a hydrostatic head ofwellbore fluid in place and would not approve anintervention or re-entry based on such a proposal?A. Yes, I see that.

Q. Do you see that they are saying there that the amountof time for which that is going to occur is not relevant,because it is not negotiable to have only one primarybarrier in place?A. Yes, I see that.

Q. And that, in their view, that position is based onnormal industry practice and generally accepted goodoilfield practice; do you see that?A. I see that.

Q. And they go on to say:

However, a risk based approach might takea different view on this aspect.

Do you see that?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2137

A. Yes, I see that.

Q. In assessing the 1B drilling program, was there anyrisk assessment that you conducted in relation to whetherit was acceptable to leave the H1 well in the state ofhaving only one barrier for a period of time?A. No, it was not something that I would do, asa regulator, and I didn't seek it from the operator.

Q. Could we next go to DPI.0002.0001.0001. Do you see,Mr Marozzi, that this is a letter to the Inquiry from theVictorian Department of Primary Industries?A. I see that.

Q. That is the Victorian regulator that is equivalent toyour department; that's right, isn't it?A. Yes.

Q. Do you see there, if the operator scrolls down, thatthey are providing their views in relation to whether it isacceptable to leave a well open to atmosphere with only onebarrier in place?A. Yes, I see that.

Q. If the operator could scroll down slowly, please, andjust pause there, do you see that they say that thatsituation might occur under the following scenarios, andthey list two scenarios there?A. Yes, I see that.

Q. Neither of those scenarios was present in relation tothe H1 well pursuant to the drilling program we are talkingabout; that's right, isn't it?A. Yes, that's right.

Q. Then if the operator continues over to the next page,please, do you see in the third paragraph there, theregulator has said that it might be permissible if the rigwas on location --A. Sorry, where is that written?

Q. The regulator says:

If this [situation] was for a temporarysuspension - with the rig on location butnot over the well and with little abilityto monitor the well and no mitigation in

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2138

place to stop well flow in the event itkicked, then [they] would be unlikely toapprove such a scenario.

It is the third paragraph, Mr Marozzi.A. Yes, I see that.

Q. Do you see in the next paragraph, they say that ifthey were to consider this temporary suspension:

... it would require the company to providejustification by conducting a riskassessment and to implement mitigationmeasures to stop the well from flowing ifit kicked.

Do you see that?A. Yes.

Q. Again, no such risk assessment occurred, did it?A. That's correct.

Q. And there was nothing in place in terms of mitigationmeasures to stop the well from flowing if it kicked, inrelation to the H1-ST1, pursuant to the drilling program inquestion, was there?A. That's correct.

Q. If the operator goes to the bottom of the page, wouldyou read the first paragraph under "Answer to question b."Do you agree that what the regulator says there about thehydrostatic head as a barrier for well suspension - namely,the requirement for kill mud - was not something that wasenvisaged by the 1B drilling program?A. I'm sorry, I thought you said "v"; I was reading "v".

Q. Sorry, "b", Mr Marozzi.A. Okay. Yes, I'm sorry, what was the question again?

Q. Do you agree that what the Victorian regulator saysthere about hydrostatic head operating as a barrier -namely, that it needs to be kill mud - was not somethingenvisaged by the 1B drilling program?A. Correct.

Q. Could the operator next go to DPI.0001.0002.0001. Doyou see that that is a submission to the Inquiry from,

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2139

again, the Victorian Department of Primary Industries?A. Yes.

Q. If we could go to page 3 of this document, I would askyou to read what is on that page, Mr Marozzi.A. Yes, I see that.

Q. You will agree that the Victorian regulator is sayingthat it is not good practice to rely on a cemented casingshoe as the only barrier operating against a blowout, evenwhere the integrity of the cemented casing shoe has beenconfirmed by appropriate testing.A. Agreed.

Q. So you would agree that they would certainly considerit very poor practice to rely on that as the only barrierwhere no such verification had occurred; do you agree withthat?A. Agreed.

Q. If I provide you with a copy of this letter overlunch, Mr Marozzi, I will ask you to read everything in itand then I will ask you some questions about it afterlunch. For the moment, do you accept that, having regardto the information provided to the Inquiry by the Victorianand Western Australian regulators, it is unlikely that theywould have approved the 1B drilling program, if presentedwith it last year?A. Agreed.

Q. I suggest to you that it is not a good thing thatdifferent regulators would take a different approach inrelation to the same drilling program. Do you havea comment on that?A. Provided that the consistency is at an elevatedstandard, yes, I agree with that.

Q. What do you mean by that answer, Mr Marozzi?A. Well, the consistency could be at a low standard or itcould be at a high standard, so it would be obviouslybeneficial if it was at a high standard.

Q. But my question was directed to the inconsistency thatis apparent from the practices of the Northern Territoryregulator and the apparent views of the Western Australianand Victorian regulators; do you understand what I'm askingyou about?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2140

A. Not really, no.

Q. The Northern Territory regulator approved the1B drilling program, didn't it?A. Yes.

Q. And the information that the Inquiry has receivedsuggests that the Western Australian wouldn't have approvedthat program, doesn't it?A. Yes, it would indicate that.

Q. And it suggests that the Victorian regulator wouldn'thave approved that program, either, doesn't it?A. Yes.

Q. Because both of them think that it is not goodpractice to rely on only one barrier for any period oftime, whatever the circumstances, unless there had beena proper risk assessment; that's the view they havereflected to the Inquiry, isn't it?A. Yes.

Q. So the conclusion from that is that there has been adifferent approach between one regulator in Australia fromthe approach that other regulators are likely to have takenin relation to exactly the same application; that's right,isn't it?A. Yes.

Q. I'm suggesting that it is not a good thing thatdifferent regulators could take different approaches toexactly the same proposal from an operator, such as PTT; doyou agree with that?A. I agree.

THE COMMISSIONER: Mr Marozzi, I'm looking at the lastline of the second-last paragraph of the Victorian letter,where it says:

These documents are usually listed in theaccepted WOMP and can be easily audited bythe DA.

I don't want you to comment on that; I just want you torecall that. Thank you.

MR BERGER: Q. I would like to ask you now about PTT's

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2141

discovery that the 13-3/8" PCC was missing; do youunderstand what I'm directing your attention to?A. Yes.

Q. Could we return, please, to PTT.9000.0005.0026. Doyou recognise this suspension diagram?A. Yes.

Q. The suspension diagram clearly shows that the 13-3/8"pressure-containing corrosion cap was going to be installedto suspend the H1-ST1 well, doesn't it?A. Yes.

Q. Now, at the time you assessed this suspensionapplication, which included the diagram, what expectationdid you have that the well would be suspended in the way itwas represented in this diagram?A. I don't understand the question.

Q. Well, you received this suspension diagram and anapplication for approval to suspend; that's right, isn'tit?A. That's right, yes.

Q. In assessing that application to suspend, did youassume that the well would be suspended in the mannerdepicted in this diagram?A. Yes.

Q. Had you ever come across a situation in whicha diagram had been provided by an operator depictingsuspension or barriers in place in a wellbore and what wasdepicted in the diagram was not ultimately followed by theoperator?A. I can't think of an example, no.

Q. Could we go, please, to GEO.0003.0001.1100. Do yourecognise this as the daily drilling report relating to theMontara H2 well of 16 April 2009?A. Yes.

Q. If the operator could scroll down, please, do you seeunder the column "Comments and Lessons Learned", it saysthere:

Corrosion caps fitted to 340mm MLS andtrash caps fitted to 508mm conductors on H1

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2142

and H3-ST1.

A. I see that.

Q. Does that signify to you the installation of the340mm, or the 13-3/8", pressure-containing corrosion cap onthe H1 well?A. Okay, sorry, can you ask that question again?

Q. Do you see the entry:

Corrosion caps fitted to 340mm MLS andtrash caps fitted to 508mm conductors onH1 ...

A. Yes.

Q. Does that signify to you that PTT are advising whoeverreads the DDR that the 13-3/8" pressure-containingcorrosion cap was fitted to the H1 well?A. It would seem to suggest that, yes.

Q. Is this something that you recall reading and takingnotice of at the time?A. No, I have not read that part before.

Q. We know now that the 13-3/8" pressure-containingcorrosion cap was in fact not fitted to the H1 well,contrary to what is indicated by the daily drilling report;do you understand that?A. Yes.

Q. What views do you have about the daily drilling reportsuggesting that had been done, when in fact it hadn't beendone?A. Well, it shouldn't be reported that way if it hadn'tbeen done.

Q. Is that the extent of your views about that,Mr Marozzi?A. Yes, it is just that I haven't read this before, thisline, so I'm just having a bit of trouble in trying tofigure out which size cap refers to H1 or H3.

Q. It seems to refer to both of them, doesn't it,Mr Marozzi?A. Yes, perhaps. It's --

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2143

Q. I'm not suggesting that it is a deliberate misleadingof the regulator, but what is in this daily drilling reportconstitutes a misleading of the regulator, doesn't it?A. Given that the cap did not go on?

Q. Yes.A. It could be interpreted that way, yes, possibly.

THE COMMISSIONER: Q. Is there any other way ofinterpreting it?A. It's just that I'm not really certain which cap ismeant to be referring to which well, but - okay, itsuggests both, yes. It would suggest both wells, yes, thatthe cap has been installed on.

MR BERGER: Q. Advising a regulator that a barrier hasbeen fitted to a well, when in fact it hadn't, isa significant oversight; do you agree with that?A. I agree.

Q. Are you aware that PTT realised, upon re-entry to theH1 well, that, contrary to what was signified in thesuspension diagram and contrary to what is suggested inthis daily drilling report, the 13-3/8" pressure-containingcorrosion cap had not in fact been installed on theH1 well?A. I understand that.

Q. Do you think that, upon becoming aware of that, thatis something that they should have notified the DA about?A. Yes.

Q. Why is that?A. Well, it is non-compliance. It constitutesnon-compliance with their approved program. They shouldhave notified the regulator that it hadn't been done.

Q. Your view is that any non-compliance with an approvedprogram is something that requires notification to theregulator; is that right?A. Well, it's not specifically stated in that way in theregulations, but I would expect that, yes.

Q. I just want to ask you your views about that point,Mr Marozzi. Could the operator please go toINQ.0001.0001.1537. Do you recognise this, Mr Marozzi, as

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2144

regulation 25 of the management of well operations that wehave spoken about previously?A. Yes, I do.

Q. Do you see that it states:

A titleholder must not commence a wellactivity if:...(i) a well integrity hazard has beenidentified in relation to the well; or(ii) there has been a significant increasein an existing risk in relation to thewell; and... [that has not been controlled].

A. Yes.

Q. Do you see that it also provides that a titleholdermust not continue a well activity if such hazards have beenidentified but not controlled?A. Yes.

Q. Is it your view that realisation that the 13-3/8"pressure-containing corrosion cap had not, contrary to whatwas suggested and approved, been fitted is something thatfalls within this regulation?A. Yes.

Q. Are you also aware that not only was the 13-3/8"pressure-containing corrosion cap not installed but, uponre-entry, the 9-5/8" pressure-containing corrosion cap wasremoved prior to the time envisaged by the drilling programthat had been approved?A. Yes.

Q. Are you aware that, after its removal, it was notreinstalled?A. Yes, I understand that.

Q. Were you aware, at the time of re-entry - namely,20 August 2009 or thereabouts - of either of these things?A. No, I was on annual leave at the time, on 20 August,so I wasn't aware.

Q. Is there any record that you have seen since theblowout to suggest that these matters were drawn to the

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2145

attention of the Northern Territory regulator by PTT?A. No, I have not seen records to that nature.

Q. I would like to show you a number of comments thathave been made about this event and see if you agree withthem. Do you follow what I'm about to do?A. Yes.

Q. Could we turn, firstly, please, to WIT.1000.0001.0156.If you could assume, Mr Marozzi, that this is a statementgiven to the Inquiry by Mr O'Shea, who was on board the rigon behalf of PTT at the relevant time - you understandthat?A. He was on the rig at the time of the blowout?

Q. Yes.A. Okay.

Q. If you could look at paragraph 156 of his statement,he says there that the removal of the 9-5/8" PCC wasa slight change in the sequence of the well constructionoperations, but he did not consider that required anyformal change to the 1B program. Do you see that?A. I see that.

Q. Do you have any understanding now of how long the9-5/8" pressure-containing cap was taken off and not putback on before it was scheduled for removal pursuant to theprogram?A. I'm sorry, you'll have to repeat that.

Q. Do you have any understanding now of how much earlierit was that the 9-5/8" pressure-containing corrosion capwas taken off, as opposed to when it was scheduled forremoval under the program?A. I understand it was removed earlier than the programcalled for.

Q. Do you understand how much earlier?A. I don't have that figure available.

Q. Could you assume for the moment, Mr Marozzi, inanswering the questions that I am going to ask you, that itwas taken off approximately four to five days earlier thanscheduled for under the 1B drilling program. Do youunderstand what I am asking you to assume?A. I understand.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2146

Q. Bearing that assumption in mind, if we could next goto WIT.1000.0001.0237 and if you could read paragraphs 50to 53 of this document, Mr Marozzi. As you do, if youcould assume that it is a statement of Chris Wilson thathas been provided to this Inquiry.A. Okay. Paragraphs 50 to 53, did you say?

Q. Yes. Have you read that?A. Yes.

Q. You know Mr Wilson, don't you?A. I do.

Q. You have had frequent dealings with Mr Wilson?A. I have.

Q. Do you understand that what he is telling the Inquiryin these paragraphs of his statutory declaration is that heconsidered the earlier removal of the PCC as a matter ofinsignificance?A. I understand that, yes.

Q. If we could go next, please, to page 0280 in thatdocument, paragraph 269(d) of Mr Wilson's statement, do yousee that he is saying that he considered this a change ofsequence, not a change of substance?A. Where are you reading that?

Q. Paragraph 269(d), Mr Marozzi, at the very bottom ofthe page.A. Yes, okay.

Q. If we could next go, please, to transcript page 1347line 24. While that is occurring, you knowMr Craig Duncan, don't you, Mr Marozzi?A. I do.

Q. He is someone from PTT with whom you had significantdealings in assisting the delegate?A. Correct.

Q. Do you see there that Mr Duncan was asked by Mr Howe:

And you didn't understand that you wereactually bringing forward the time byseveral days, because you thought it was

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2147

a lesser period; that's right, isn't it?

Mr Duncan said:

Yes, but bear in mind that as soon as wehad finished installing the conductors andwe started installing the 13-3/8" casingstrings, we would have got a pressure test,anyhow.

And he went on to deal with that.A. Yes, I see that.

Q. If the operator could scroll down, please, do you seeat the top of the next page, he was asked:

Did you give any thought whatsoever on20 August to informing the NorthernTerritory, as the regulator, of, firstly,the non-installation of the 13-3/8" PCC,secondly, the decision to remove the 9-5/8"PCC, and, thirdly, the decision you tooknot to insist on the reinstallation of the9-5/8" PCC?

Do you see that?A. I see that.

Q. Mr Duncan said "No", and he was asked:

Do you accept that you should have done?

He responded:

At the time, I still thought it was aninsignificant change, and had I thought itwas a significant change, we would havecontacted the NT Government.

A. I see that.

Q. Do you see that in the next question and answer, heconcedes that he was sure that the Northern Territory hadexpected those barriers to be in place?A. Yes, I see that.

Q. Next, if we could go, please, to WIT.1000.0004.0027.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2148

While that is occurring, you know who Mr Jacob is, don'tyou, Mr Marozzi?A. I do.

Q. He is someone from PTT with whom you had significantdealings; correct?A. Correct.

Q. If you could assume that this is his statement to theInquiry, and if you could look at paragraph 110, please, heis suggesting that the removal of the 9-5/8" cap was nota difference in the sequence of removal and that:

The plan --

I suggest that means the drilling program --

always had a period of time during whichthe barriers were planned to be thecemented casing shoe and the hydrostatichead of seawater.

THE COMMISSIONER: Mr Berger, is this the part of thestatement that Mr Jacob subsequently amended with respectto the reference to the hydrostatic head of seawater?

MR BERGER: I don't think so, Commissioner. I willdouble-check that. This is the revised statement.

THE COMMISSIONER: Thank you. I'm sorry for interrupting.

MR BERGER: Q. Finally, Mr Marozzi, if I could directyour attention to transcript page 43 at line 46. Whilethat is occurring, if I could ask you to assume that thisis the evidence given by Atlas/Seadrill's operationsmanager, Mr Gouldin?A. Okay. Sorry, which line?

Q. At line 46, and if we could continue over the page,please. Could we scroll down a little bit further, please.Do you see at line 22 that he was asked about the discoveryin August of the fact that a PCC hadn't been installed, andhis attention was directed to his statement that thatdiscovery amounted to a deviation from the drillingprogram, which should have been reported to town; do yousee that?A. Yes, I see that.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2149

Q. He suggested, I would ask you to assume, Mr Marozzi -I will find the reference in a moment - that the removal ofthe 9-5/8" pressure-containing corrosion cap and itsnon-immediate reinstallation was a significant event whichimpacted on wellbore security. Could you assume that?A. I am sorry, you will have to repeat the question. I'mhaving trouble hearing you, too.

Q. I'm asking you to assume that Mr Gouldin, theoperations manager from the rig, gave evidence that theearlier removal of the 9-5/8" pressure-containing corrosioncap and the failure to reinstall it was a significant eventwhich impacted on wellbore security. Do you understandthat assumption that I am asking you to make?A. Okay, yes.

Q. Could the operator bring up, please, transcriptpage 47 at line 35. Would you read the transcript fromline 35 over to the top of the next page, Mr Marozzi. Doyou see that at the bottom of page 47, Mr Gouldin wasasked:

You're aware that PTT say that itwasn't ...

A. Sorry, I just haven't finished reading it. Yes.Okay.

Q. If the operator could scroll down a bit on the top ofpage 48. If the operator could scroll down a little bitfurther, please, and if we could go to the top of the nextpage. Would you read there Mr Gouldin's evidence on thescreen, Mr Marozzi.A. Yes, I have read that.

Q. Do you agree that a summary of the evidence thatI have directed your attention to is that the PTT witnesseswere suggesting that the earlier removal of the 9-5/8" PCCand its non-reinstallation was a change of sequence anda change of insignificance? Is that a fair summary, inyour mind, of the evidence that I have directed yourattention to?A. Yes.

Q. And is it a fair summary of the evidence that I havedirected you to, in your mind, that Mr Gouldin has said,

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2150

no, it is a change of substance and consequence rather thanone of insignificance or timing?A. Yes.

Q. The question I want to ask you is what is your view onthose two alternative positions about the removal of the9-5/8" PCC and its non-reinstallation, as a person involvedin regulation: do you consider it a matter ofinsignificance and timing or a matter of significance andconsequence that should have been notified to theregulator?A. Yes, in hindsight, it should have been notified. Itis a change of program, so it should have been notified.

Q. So it is a change of program, but do you consider ita change of consequence or one of insignificance?A. They are not terms I would normally use myself, butI will go with what you are putting to me.

Q. Which of those two terms is closest to your view?A. Well, in hindsight, definitely consequence, yes.

Q. Why do you say that?A. Well, because of the outcome.

Q. You don't need hindsight in relation to that,I suggest, Mr Marozzi, do you?A. Hindsight to do what?

Q. Removing the 9-5/8" pressure-containing corrosion capsome four to five days earlier than was envisaged by theprogram and thereby leaving the well open to atmospherewith only cemented casing shoe as a barrier for a period offive or so days rather than perhaps 8 or 10 hours - do youagree that that is a change of consequence and a change ofsignificance and a change that should have been notified tothe regulator?A. Yes, I agree.

Q. Could you tell the Commissioner why you think leavingthe well in this situation for some five or more daysrather than 8 or 10 hours is a change of significance?A. In this situation - I'm sorry, I'm not really sureexactly what you are trying to get me to explain.

Q. I understood you to say that of the alternativepositions advanced by the PTT witnesses that I directed

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2151

your attention to and the evidence of Mr Gouldin, youpreferred the evidence of Mr Gouldin, and your own view wascloser to that of Mr Gouldin; is that right?A. Yes, I guess so, yes.

Q. Is it the case, therefore, that you consider thatremoving the 9-5/8" pressure-containing corrosion cap somefour to five days earlier than was envisaged in the programthat you recommended for approval, and leaving it off, wasnot a change of insignificance that PTT didn't need tobother informing the regulator about?A. I'm not sure if I'm answering your question: they hadapproval for the program, but it led to a change ofapproval, so they should have notified the regulator ofthat change.

Q. So you say that regardless of any impact the situationmight have had on well integrity, the mere fact that itconstituted a change in the program, without more, requiredPTT to notify the Northern Territory?A. Well, it is generally what the company does do quitewell. They will be aware that they have approval fora program, and they will submit a change control and notifyus of a change. They have a good track record of doingthat, and, in this case, they probably should have done thesame thing.

Q. So because it is a change in program, it is somethingthat should have been notified. Is there an additionalaspect that leaving the well in this situation for somefour or five or more days is a different proposition interms of well integrity than leaving it in this positionfor 8 or 10 hours or so? Do you have a view about that?A. Well, it extended that exposure time, but - see, fromthe evidence that I can recall, they removed the cap andthere was no pressure there, so there are just extenuatingcircumstances there. I don't pretend to understand myselfhow --

Q. You don't have an understanding of the impact thischange in program might have had on well integrity in aprecise way, but you have the view that it constituteda change in program, and therefore, regardless of anyimpact on well integrity, it is something that PTT neededto tell the DA about; is that right?A. That's fair comment, yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2152

MR BERGER: Is that a convenient time, Commissioner?

THE COMMISSIONER: Thank you, Mr Berger, Mr Marozzi. Wewill resume at 2 o'clock, thank you.

LUNCHEON ADJOURNMENT

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2153

UPON RESUMPTION:

MR BERGER: Q. Mr Marozzi, do you recall that yesterdayI asked you some questions and you gave some evidence aboutyour meetings with PTT officers in the Department ofResources offices in Darwin prior to the blowout?A. That's right.

Q. And by "prior to the blowout" - I don't meanimmediately prior to the blowout, but some time last yearbefore the blowout occurred. Do you remember that?A. Yes, yes.

Q. The note I have of your answer is that if the meetingwas of an operational nature, you might have taken notes.Do you remember saying that?A. Yes, yes.

Q. Does that reflect your understanding of your practiceof last year?A. Yes.

Q. You agreed, I recorded, that some of the meetingsbetween you and PTT might have been what you could callcourtesy calls or general chats. Do you recall givingevidence to that effect?A. Yes.

Q. I asked you whether, if you didn't make any formalrecord of such a meeting, that would suggest that importantissues relating to drilling operations weren't discussed.Do you recall my asking you that?A. Yes.

Q. I recorded you as saying, "That's right, that'sright." Does that reflect your understanding of yourpractices?A. I think so, yes.

Q. In a nutshell, if there is a record of your meetingswith PTT, then it's likely they were important meetingswhere formal matters relating to operations were discussed;but if there was no record, it's likely to have been aninformal chat or a meeting where formal operational mattersweren't discussed? Is that the correct summation of yourevidence yesterday?A. That's a fair generalisation, yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2154

Q. Then, do you recall I asked you to see if you couldfind out if there were any formal records of your meetingswith PTT prior to the blowout last year?A. Yes.

Q. Have you requested that those searches be undertaken?A. Yes, I have.

Q. Have they led to any formal records of meetings ordiscussions with PTT being uncovered?A. They haven't got back to us. They're currentlychasing that information in Darwin.

Q. To this point, nothing has been found that recordsformal discussions or meetings with PTT?A. That's correct.

Q. If any such records are located, will you provide themto the Inquiry?A. Yes.

MR GRANT: Mr Commissioner, I can assist here. It'sa matter that Mr Marozzi is not aware of, because he hasbeen incommunicado in giving evidence. My instructors havereceived advice from Darwin that a search has beenundertaken of his diary records, and there are no recordsrecording any particular meetings with PTT personnel overthe course of 2009.

THE COMMISSIONER: Thank you, Mr Grant.

MR BERGER: I thank my learned friend theSolicitor-General for that, Mr Commissioner.

Q. Having heard that, does that indicate to you that anymeetings or discussions that you had with PTT in the courseof 2009 prior to the blowout were of an informal courtesycall or general chat type of nature?A. That's correct.

Q. So is it the case, then, that your engagement with PTTas an operator was limited, during the course of 2009, atleast, to your receipt of applications that they submittedfor approval and the daily drilling reports and emailcorrespondence they provided by way of daily updates?A. A reflection of communication, did you say?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2155

Q. Yes, your engagement with PTT and communications withthem; is that the net sum of it?A. What you just said, plus emails with particularindividuals, officers within PTT, and phone calls.

Q. Those emails and phone calls typically occurred in thecourse of assessing either an application for suspension oran application for drilling approval; is that right?A. Yes, or environment - all those applications, yes.

Q. Those communications were in the course of assessingan application rather than monitoring PTT's compliance withwhat had been already approved; is that right?A. Yes, about assessment, yes, generally.

Q. And there were certainly no steps that you took inassisting the delegate to fulfil his role to ensure that,throughout the course of 2009, PTT were complying withtheir well operations management plan; is that right?A. Other than me doing the level of scrutiny I could doon the DDR, no. Other than that, no.

Q. Did you have a chance over lunchtime to have a look atthe letter from the Department of Primary Industries of15 March that was provided to you?A. I did, yes.

Q. For the purposes of the transcript, this is documentDPI.0001.0002.0001. Is there anything in that letter thatprovokes a disagreement on your part, Mr Marozzi?A. No.

Q. You would agree with and endorse the comments of theVictorian Department of Primary Industries offered in thatletter?A. Yes.

Q. That being the case, you would accept that there weresome failings to fulfil good regulatory practice inrelation to the approval of the suspension of the MontaraH1 well in March 2009; correct?A. Yes, correct.

Q. And you would also agree that there were some failuresto follow good regulatory practice in recommending approvalof the 1B drilling program in July 2009?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2156

A. Correct.

Q. If the operator could please bring upWIT.4000.0002.0016, and if you could have a look atparagraphs 58 and 59, Mr Marozzi. Do you see that you arethere dealing with the fact that PTT did not make anyapplication for approval to vary the drilling program inorder to remove the 9-5/8" pressure-containing corrosioncap before completing the 13-3/8" tie-back of the otherMontara wells?A. Yes.

Q. You say in paragraph 59:

If PTTEP had made such an application, thenI may have recommended that approval begiven to such an application. Whether ornot I made such a recommendation would havedepended on the information contained inthe application and any further informationregarding the necessity or justificationfor the variation.


Q. I just want to explore the statement made inparagraph 59, and if the operator could please bring upPTT.9002.0010.0038. Have you seen a document like thisbefore, Mr Marozzi?A. I don't believe I have, no. It doesn't look familiarat all.

Q. Perhaps it could be reduced in size so that we can seeacross the page. We can get rid of Wednesday, 19 August,but we need to see the rest of the page, if possible.Could you assume, Mr Marozzi, that this is, as the titlesuggests, the seven-day operational forecast prepared byPTT in relation to their work on the Montara platform uponre-entry on 19 August 2009; do you understand what I'msuggesting?A. Mmm-hmm.

Q. Could you assume that what's in the operationalforecast reflects what they were intending to do in theweek following re-entry - are you with me?A. Yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2157

Q. If you look at Monday, 24 August, at 16:00, do you seethe entry there:

Recover 9-5/8" corrosion cap.

A. Yes. Does it say which well? Oh, okay, above.

Q. If you look above, you'll see it's after the derrickhas skidded to the H1-ST1 well at 4 o'clock in the morning?A. Yes, yes.

Q. Do you agree that that suggests that the forecastsuggested that the 9-5/8" corrosion cap was going to beremoved at 4 o'clock in the afternoon on 24 August?A. Yes, that's what it says, yes.

Q. Could you have a look at the entries that follow that,going down to 19:00.A. Yes.

Q. If that forecast was followed, would it not be thecase that a pressure test in relation to the 9-5/8" casingshoe would be conducted shortly after the 9-5/8" corrosioncap was removed?A. Three hours later, yes.

Q. I'm sorry, it's a pressure test of the casing, not thecasing shoe. Do you agree with that?A. Yes, agreed.

Q. Could you assume, Mr Marozzi, that the 9-5/8"pressure-containing corrosion cap was actually removedaround midday on 20 August rather than 4 o'clock in theafternoon on 24 August - do you understand what I'msuggesting?A. Yes.

Q. So having regard to that information, are you able tooffer the Commission a view as to whether you would haveapproved a program that provided for the 9-5/8"pressure-containing corrosion cap being removed aroundmidday on 20 August and being left off, as opposed to whatwas forecast in this document and in the drilling program?A. Well, given that I haven't seen this document - but,like I said in my statement, I would just need moreinformation behind the justification for doing so, if that

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2158

was put to me.

Q. If you assume that this document is consistent withwhat was in the approved program; do you follow me?A. Assuming it's in the approved program, okay.

Q. The seven-day operational forecast reflects what wasin the 1B program that had been approved, so the approvedprogram provided for the 9-5/8" pressure-containingcorrosion cap to be removed at 4 o'clock in the afternoonon the 24th, and then a pressure test of the casing to beconducted shortly after that.A. Under what you've described, I would struggle tojustify approving it, because given that the casing shoe isnot validated, it would bypass - it would bring the removalof the cap a way forward.

Q. What's the difference, cutting to the chase, betweenremoving the 9-5/8" pressure-containing corrosion cap atmidday on 20 August and removing it at 4 o'clock in theafternoon on 24 August, apart from the obvious timedifference? What is the significance, if any, of thatpassage of time, in light of the steps before and afterthose events?A. The significance is that they've opened the well up toatmosphere with only - with two - well, do I assume we knowthat the 13-3/8" wasn't there? So that's removed. The9-5/8" is now removed, and the BOP or another barrier hasnot been installed. And I'm assuming they haven'tundertaken the pressure test.

Q. What I'm directing my question to, Mr Marozzi, is thedifference between the program that was approved - do youunderstand? Let's assume that the 13-3/8"pressure-containing cap was installed consistently withthat program but then removed consistently with theprogram.A. Right.

Q. What I want to ask you about is the difference, ifany, between the 9-5/8" PCC being removed at midday on20 August and it being removed at 4 o'clock in theafternoon on 24 August.A. Just a change of sequence.

Q. That's all it signifies to you, is it, Mr Marozzi?A. In that context, yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2159

Q. So do I take it from that answer that if PTT hadsought your approval to remove the 9-5/8"pressure-containing corrosion cap at midday on 20 August,without any pressure test of the casing until the eveningof 24 August, that's something that you might have agreedto, leaving the well with only the cemented casing shoe butno pressure test for that period of time? Is that theposition?A. Depending on what other information they provided tojustify the change.

Q. What other information would you need to see,Mr Marozzi?A. The reason for it. Why. I'd be asking, "Why are youchanging the program?"

Q. If they came back to you and said, "There are rustedthreads on the 13-3/8" MLS and we need to clean them, andin order to clean them, we need to remove the 9-5/8"pressure-containing corrosion cap", would that have madea difference?A. Perhaps. Perhaps.

Q. Would you, do you think, have insisted that the 9-5/8"pressure-containing corrosion cap be reinstalled afterthose threads had been cleaned, if that were the case?A. Possibly, that could have been an outcome ora suggestion, yes.

Q. Mr Marozzi, the blowout was a very significant eventin terms of your career?A. Yes.

Q. Would that be a fair comment?A. Fair comment.

Q. And it was a very significant event within theDepartment of Resources at the end of last year; is thatright?A. Yes, yes.

Q. To use the vernacular, it was one of the worstoffshore disasters in Australian history; would that bea fair comment?A. Yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2160

Q. It happened on your watch, so to speak, didn't it?A. So to speak, yes.

Q. That being the case, I assume that you were keen tofigure out what had happened and why; is that right?A. Sure.

Q. Is that a view that was shared by others in yourdepartment?A. Absolutely.

Q. Is that a view, to your knowledge, that was shared byMr Whitfield and other people involved in the assessing ofdrilling activities in the area?A. I believe so. Mr Holland was more directly involvedat the time, but yes.

Q. Could you tell the Commissioner what steps you or yourdepartment took, to your knowledge, to figure out what hadhappened and why?A. On the morning of the 24th, that's when I returned tothe office after being on leave, and I had gatheredsomething on the news about what had happened. Weimmediately contacted PTT and I spoke to Andy Jacob, and weasked Mr Jacob what he believed was - no, firstly, we askedhim to provide as-built status of the well schematics foreach of the Montara wells and also if he could provide anyinformation he knew that led to the uncontrolled release,et cetera. At the time, we knew very little.

Q. What, if any, other steps did you or your departmenttake to learn what had happened?A. Then I believe Alan Holland started communicatingdirectly with the Department of RET, with Martin Squire,and they were in full consultation, I believe, right upuntil the interception of the well. I can't quote exactlythe intensity of that communication, et cetera.

Q. Yes. Was there anything else?A. Nothing else specifically comes to mind.

Q. Did you not go back over the documents that you hadbeen involved in assessing relating to the H1 well andcheck what was in them?A. Yes, I did, in preparation for --

Q. In preparation for giving evidence to the Inquiry; is

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2161

that what you were going to say?A. No, even before. Even before, in trying to figure outwhat - we got the response from Mr Jacob, and then that wassufficient to get started, I guess, to try to figure outwhat could have happened.

Q. That got you started. What did you do to continuethat process, if anything?A. Well, then, we had a well out of control and thenI was pretty much tied up with that operation, the approvaloperation of the relief well.

Q. Until when, Mr Marozzi?A. Until we successfully - until PTT successfullyintercepted and killed the well.

Q. It was a period of approximately 10 weeks; is thatright?A. That was Melbourne Cup day, yes.

Q. Early November last year?A. That's right.

Q. That's quite some time ago now, isn't it?A. Yes.

Q. So what, if anything, have you done since November tofamiliarise yourself with what had happened and perhapslearn what had gone wrong?A. Then we got notice of the Inquiry shortly after, soI can recall going directly from the assessment ofoperations of the relief well to then collectinginformation for this Inquiry.

Q. In the course of collecting information for thisInquiry, did you go back and review daily drilling reports?A. I did some, yes.

Q. Did you go back and review applications for suspensionin March last year that we've spoken about today?A. Yes, I went back and dug some of that stuff up, yes,yes.

Q. Did you have a look at the suspension diagrams thatwe have covered in the course of your evidence?A. I did.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2162

Q. And did you have a look at the 1B drilling program?A. I did.

Q. Did you have a look at PTT's well constructionstandards?A. No, I didn't.

Q. Did you have a look at PTT's WOMP?A. Which one, though?

Q. The WOMP that was in force at the time of the blowout.A. They submitted a WOMP for both the relief well --

Q. Not for the relief well. The one that was in force atthe time of the blowout.A. Yes, I would have looked at that.

Q. Did you note from that that one of the main thingsthey offered in terms of how they would conduct theiroperations in accordance with good oilfield practice wastheir well construction standards?A. Yes, I would have noted that, yes.

Q. And you still didn't feel any inclination to go backand see what was in those and if they had been compliedwith, in all likelihood?A. No, not really, not at the time.

Q. Did you come to understand that the blowout occurredbecause there was not a single effective barrier in placeto stop that happening?A. I'm not sure when I came to understand that, butI obviously did. I'm not really sure exactly when I cameto understand that.

Q. The mere fact of the uncontrolled release suggests,does it not, that there was nothing in place to stop it?A. That's right.

Q. And the possible barriers that could have been inplace to stop it were the cemented casing shoe, the 9-5/8"pressure-containing corrosion cap and the 13-3/8"pressure-containing corrosion cap; is that yourunderstanding?A. Yes.

Q. You came to an understanding that the cemented casing

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2163

shoe was not going to be an effective barrier, because ofan overdisplacement of the casing shoe track at some point;is that right?A. At some point, yes.

Q. What point was that?A. I believe that was reading the transcripts of thisInquiry.

Q. You came to an understanding at some point that the13-3/8" pressure-containing corrosion cap had never beeninstalled; is that right?A. Yes, yes.

Q. When did you come to that understanding?A. That was reflected in Andy Jacob's response to thatrequest on 24 August. The information he provided showedthat the 13-3/8" was not there.

Q. You came to an understanding that the 9-5/8"pressure-containing corrosion cap had been taken off and,at the time of the blowout, had not been put back on; isthat right?A. That's right.

Q. When did you come to that understanding?A. That same response from Andy Jacob.

Q. If the operator could please bring upPTT.9001.0018.0043. Is this the response you were justspeaking of, Mr Marozzi?A. Yes.

Q. If the operator could scroll down slowly and perhapsif you could stop us, Mr Marozzi, when you get to the pointwhere you say it became clear that the 13-3/8" PCC had notbeen installed?A. Does this copy here show the as-built diagrams thatwere provided?

Q. There was a suspension diagram as-built that wasattached to the letter, Mr Marozzi. Do you want thatbrought up?A. We got them for each of the wells, yes.

Q. Well, how did that assist in your understanding of --A. Because it was in contrast to what had been approved.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2164

Q. If the operator could bring up PTT.9003.0070.0321, iswhat you're saying there, Mr Marozzi, that this suspensiondiagram shows that there was no 13-3/8" pressure-containingcorrosion cap, so that's the basis of your understanding?A. That's right.

Q. But the suspension diagram as-built shows the 9-5/8"pressure-containing corrosion cap, doesn't it?A. That's right. This copy does show that.

Q. So can you recall specifically what led to yourunderstanding that that had been removed and hadn't beenreinstalled prior to the blowout?A. Yes, I believe there's something back in the text thattells us that there was a change of order, or gave theinformation that there was a change of order, of sequence,other than the approved phase 1B program.

Q. So as of 26 August 2009, you had an understanding thatthe pressure-containing corrosion caps weren't in place atthe time of the blowout; is that right?A. I'm sorry, as of when, sorry?

Q. When you received this information from Mr Jacob.A. I'm sorry, I'll have to ask you to repeat thequestion.

Q. When you received the information from Mr Jacob - theletter and the suspension diagram as-built - did that leadto an understanding on your part that, at the time of theblowout, neither the 9-5/8" nor the 13-3/8"pressure-containing corrosion cap were in place on theH1-ST1 well?A. No. I'm not really sure of that, what you said.I was convinced that the way the H1-ST1 was suspended hadnot included the 13-3/8", the absence of that. And I'djust have to check the text, but I believe the text onlytold me there was a change of sequence, I believe.

Q. If the operator could return, please, toPTT.9001.0018.0043 and could scroll down and stop at thestart of point 2. Is this the information you're referringto, Mr Marozzi?A. Yes.

Q. Specifically, are you referring to the statement in

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2165

the second sentence:

The last rig operation involving theMontara H1 ST1 well occurred from 19 to20th August 2009 and involved the removalof the trash cap and then the 244mmcorrosion cap ...

A. Yes.

Q. The fact that there was no reference to reinstallingthe 9-5/8" pressure-containing corrosion cap made it clear,did it, that it was off at the time of the blowout?A. It was a fair indication of that, yes.

Q. So upon reading this letter of 26 August 2009, you hadan understanding that there were no pressure-containingcorrosion caps in place at the time of the blowout;correct?A. Yes.

Q. So the only barrier operating potentially to preventa blowout was the casing shoe, in your mind, as of26 August 2009; is that right?A. Upon reading this, yes.

Q. Armed with that information, very little endeavour wasrequired, I suggest, to come to the view that that couldn'thave been an effective barrier against a blowout, either;is that right?A. Well, the well was already blowing out by then, yes.

Q. So, by definition, the cemented casing shoe couldn'thave been an effective barrier to prevent that?A. That it had failed, yes.

Q. Yes.A. Yes.

Q. I suggest that all you needed to do to figure out whythat was the case was to go back to the daily drillingreport of 7 March 2009; do you agree with me?A. Yes, yes.

Q. I think you previously agreed that within the fourcorners of that document was everything you needed to knowto work out that problems with the cementing had been

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2166

compounded by what was done after that and, in alllikelihood, led to a wet shoe and therefore an ineffectivebarrier against a blowout?A. Yes.

Q. So that being the case, Mr Marozzi, I have somedifficulty with the following statements in the NorthernTerritory's submission that I hope you could explain to me.If the operator could please go to SUBM.4000.0001.0001, doyou recognise this as the submission that the NorthernTerritory submitted to the Inquiry?A. Yes.

Q. If the operator could first go to paragraph 11, do yousee there that the submission made to this Inquiry is:

The audit of the relevant documentationconfirmed that all approvals met therequirements under the relevantlegislation.

Pausing there, do you agree that that is not a correctstatement?A. Fair comment, yes.

Q. The submission then goes on to say:

The material available to the Territorydoes not disclose the cause(s) of theUncontrolled Release.

A. At that point, we didn't understand the root cause.

Q. Did you write that paragraph, Mr Marozzi?A. I can't be certain if I specifically penned thatparagraph, but I had read it.

Q. It's a paragraph you would have read and, if itprovoked a disagreement on your part, you would have raisedit with the relevant people; is that right?A. If it provoked disagreement, yes.

Q. Do you recall when you first read this paragraph, if,indeed, you didn't write it?A. I can't be certain when. I can't be certain whenI read that.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2167

Q. It would have been well after 26 August 2009, wouldn'tit?A. It would have been, yes.

Q. If we could go, please, to paragraphs 16 and 17 of thesubmission, do you see that those paragraphs suggest thatthe daily drilling report of 7 March 2009 provideda sufficient indication of the integrity and security ofthe well casing?A. Yes.

Q. That's not the complete story, is it, Mr Marozzi?A. In hindsight, no.

Q. If we could then go, please, to SUBM.4000.0001.0001and go to paragraphs 28 to 30 on page 10, do you see inparagraph 28, Mr Marozzi, the Northern Territory hadsubmitted to the Inquiry that:

On the material presently to hand, it isnot possible for the Territory to concludethat either the failure of the casing shoefloat valve or the integrity of theconcrete holding the well casing in placewas a contributing factor to theUncontrolled Release.

A. Yes, I see that.

Q. Is that something you wrote?A. I assisted in the writing of that, or I would havewritten it, yes.

Q. Then do you see in paragraph 29 it said:

The Territory assumes on the basis of thePTTEP response dated 26 August 2009 ...

Just pausing there, that's the response we've just gone to;correct?A. Correct.

Q. The submission continues:

... that the removal of the ... 9-5/8"Pressure Containing Corrosion Cap followeddirectly on the removal of the

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2168

508mm ... Trash Cap (Corrosion Cap). Onthe material presently to hand, it is notpossible for the Territory to conclude thatthe departure from the approved Drillingand Completion Program ... wasa contributing factor to the UncontrolledRelease.

I've missed some words there, but do you see what I'mreferring to?A. Yes.

Q. Each and every one of those statements is notaccurate; that's right, isn't it?A. That's right, yes.

Q. Then in paragraph 30, you'll see that the NorthernTerritory has submitted to the Inquiry, at the bottom ofthat paragraph:

On the material presently to hand, it isnot possible for the Territory to concludethat the failure to include the340mm ... Pressure Containing Corrosion Capin the plugging configuration during thecourse of the suspension operations wasa contributing factor to the UncontrolledRelease.

Do you see that?A. I see that.

Q. Is that something you wrote?A. Yes.

Q. I suggest that's a fairly damning indictment on yourlevel of understanding, Mr Marozzi, having made thosestatements, in light of the evidence that I have taken youto. What do you say about that?A. At the time, that was my level of understanding, so,yes, my understanding was limited, I agree.

Q. At the time you wrote those very words, you knew thatneither the 9-5/8" pressure-containing corrosion cap northe 13-3/8" pressure-containing corrosion cap had been inplace, didn't you?A. But I didn't know the circumstances surrounding that.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2169

Q. And you knew at the time that the blowout was thoughtto have come from the 9-5/8" casing, didn't you?A. I knew that. I had a fair idea of that, yes.

Q. Well, that was what PTT was saying, wasn't it?A. Mmm-hmm.

Q. I suggest that it's not rocket science, Mr Marozzi, toput those two pieces of information together and come tothe view that it's very likely that those things were thecontributing cause of the blowout; do you agree?A. Fair enough, yes.

Q. I again suggest that it would have taken very littleeffort to have confirmed that the primary barrier againsta blowout was not an effective one, and that's where thehydrocarbons had, in all likelihood, entered the wellbore;do you agree with that?A. Fair comment.

Q. It would have taken less than a couple of minutes tohave established that on a careful analysis of theinformation that was available to you; that's right, isn'tit?A. Possibly, yes.

Q. Yet when this submission was provided to the Inquiry,the position, in your mind, was still that you weren'taware what had caused the blowout?A. Yes, wasn't aware exactly what led to the uncontrolledrelease, that's right.

Q. More than that; the Northern Territory pointed, in itssubmission, without any gainsay from you, to the DDR as notgiving any awareness of the likely root causes of theblowout. That's right, isn't it?A. That's correct.

Q. And do you accept, sitting there today, that thosematters betray a profound lack of understanding on the partof the regulator?A. It betrays a closer scrutiny of that DDR, yes.

Q. Well, do you accept that it does more than that,Mr Marozzi: it suggests that the Northern Territory, atthe time it provided its submission to the Inquiry, did not

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2170

have an understanding of what you now accept is a verybasic matter to have understood?A. Agreed.

Q. If we could then go to WIT.4000.0002.0019 and if theoperator could scroll to the start of paragraph 67, do yourecognise this as the conclusion of your statement,Mr Marozzi?A. I do.

Q. It is the very last piece of evidence that you wishedto leave the Inquiry with in providing your statutorydeclaration; that's right, isn't it?A. I'm sorry, what about --

Q. It's the very last piece of evidence you wished toleave the Inquiry with in preparing your statutorydeclaration; that's right, isn't it?A. I'm sorry, can you please repeat that?

Q. This is the very end of your statutory declaration,isn't it?A. Yes.

Q. Therefore, it's the last thing you wished to say tothe Inquiry in completing your statutory declaration?A. Yes.

Q. The last thing you wished to leave the Inquiry with,in signing your statutory declaration, is that theinformation provided to you prior to your assessment ofPTT's application was sufficient to enable an informeddecision to be made about approval of those applications,subject to the exceptions stated there about the 340mm PCCand the 9-5/8" PCC. Do you see that?A. Yes.

Q. Then the last sentence of your statutory declarationis:

... in my view neither of the above matterswas, or led to, the direct cause of theUncontrolled Release.

A. That's what it says, yes.

Q. Do you accept that that's a completely and utterly

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2171

false statement that you have made in paragraph 68 - andI'm not suggesting you deliberately made it falsely, butit's just not right, is it?A. Correct, it's not right.

Q. And it's just not right at the most basic of levels,I suggest to you?A. Fair comment.

Q. Do you have any explanation to the Commissioner aboutwhy that was something you wished to end your statutorydeclaration with?A. Well, it reflects my understanding of the situation,that I could not put the different pieces of the jigsawtogether about why did the cement fail, why the change oforder, why a cap wasn't there. We didn't have thoseanswers at the time.

Q. Did I understand your last answer to be, Mr Marozzi,that at the time you provided your statement to theCommission - namely, on 2 March this year, a little overa month ago - you still hadn't put the pieces of the jigsawtogether in your mind about what caused the blowout; isthat right?A. I couldn't see how they affected each other, yes,that's correct.

Q. Do you accept that that betrays a fundamental lack ofknowledge and understanding on your part in relation towell integrity matters, Mr Marozzi?A. It betrayed a lack of understanding of what reallyhappened here.

Q. And that lack of understanding about what had happenedsuggests a lack of understanding of basic well controlprinciples; do you agree?A. It can be argued that way, yes.

Q. And it betrays a basic lack of understanding ofinformation that was provided to the DA in order to fulfilits functions; do you agree?A. Perhaps. I wouldn't quite word it that way. I wouldfocus on a lack of careful scrutiny of all the data we had,but, okay, I take your point.

Q. Do you say there was too much information to properlysift through and come to a proper understanding; is that

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2172

right?A. No, not too much information, no.

Q. Really, you needed to look no further than the dailydrilling report for 7 March and Mr Jacob's letter of26 August; that's right, isn't it?A. Yes, in hindsight, that's fair comment, yes.

Q. Three or four pages of information was all you neededto join the dots together; is that right?A. Correct.

Q. And you say that at 2 March, you didn't have anunderstanding of how those dots joined together?A. That is true, yes.

Q. It can't have been the case, can it, Mr Marozzi, thatthose dots hadn't been joined because no-one had gone backto the daily drilling report for 7 March; that's right,isn't it? The reason I suggest that, if it helps,Mr Marozzi, is because the daily drilling report is invokedin the submission provided by the Northern Territory as oneof the reasons it still didn't shed any light on things?A. Yes, that's correct, I still did not put two and twotogether and get the calculator out and scrutinise thosefigures.

Q. And Mr Jacob's letter of 26 August 2009 is alsoreferred to in the submission, isn't it?A. It is, yes.

Q. I took you to that a moment ago. So it was clear thatthe Northern Territory had considered both those documentsat the time it provided its submission; that's right, isn'tit?A. Probably not together, but, yes, at different pointsin time, yes.

Q. Prior to providing its submission to this Inquiry, ithad considered both pieces of information, those three orfour pages in total, hadn't it?A. Yes, yes.

Q. That is, I suggest, a damning indictment on theNorthern Territory department; do you agree with that,Mr Marozzi?A. That's probably a bit harsh, but it's certainly

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2173

reflective of something we could have done better, yes.

Q. And is it reflective, in your mind, of the need tolook at things more closely in the future?A. If the regulations required it, yes, yes. Even so,perhaps if we knew there was a problem, we would havescrutinised it harder; fair comment.

Q. But the concern that I'm raising, Mr Marozzi, is thatit was not a case of not realising the problem: we'd hadone of the worst blowouts in Australian history at the timewhen this information was scrutinised, hadn't we?A. Yes, okay, I take your point.

Q. One of the worst blowouts in Australian history thathad happened on your watch and the watch of yoursupervisor; that's correct, isn't it?A. That's correct, yes.

Q. In those circumstances, the relevant information wasconsidered and scrutinised, and still there was no joiningof the dots; that's the position reflected by theinformation provided to the Inquiry, isn't it?A. That's correct.

Q. And that's a very real cause for concern about thecompetence of the Northern Territory to fulfil a regulatoryfunction in relation to the offshore petroleum industry;agreed?A. If you consider only this situation and ignore all theother things we've done before this, then I take yourpoint.

Q. Do you consider, upon reflection, Mr Marozzi, thatperhaps you didn't have sufficient expertise or experienceto properly comprehend the daily drilling report of 7 March2009 and what its ramifications were?A. It's a fair comment to suggest that I was out ofpractice in terms of the scrutiny, heavy scrutiny, thatcompliance monitoring requires of cementing operations.That's a fair comment, yes.

Q. You say you're out of practice of heavy scrutiny; isthat what I understood you to say?A. Yes, of taking figures and putting a calculator to itand duplicating the work of the operator. In this case, ifI had seen a problem, I would have made those calculations,

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2174

perhaps, but I didn't recognise that at the time.

Q. I suggest that your evidence over the past coupleof days, Mr Marozzi, suggests not just the absence of heavyscrutiny but the absence of any real scrutiny whatsoever inrelation to whether PTT was complying with good oilfieldpractice; do you agree with that?A. Yes, I agree with that, yes.

Q. And that's not an acceptable situation for someone whois effectively the prime person responsible for assessingdrilling applications and drilling activities, is it?A. Perhaps not. However, like I mentioned yesterday, weare resourced to a level that is in line with therequirements of the regulations.

Q. Whatever the level of resourcing, do you accept nowthat things could have been done better and should havebeen done better, Mr Marozzi?A. That's a good - that's a fair comment, yes.

Q. If we could turn, please, to NTG.0001.0002.0224, doyou recognise this document, Mr Marozzi?A. Not immediately.

Q. If I suggest that it's an email sent by Alan Hollandto the Victorian DPI, including a Mr David Wong, seekingtheir views in relation to the WOMP that PTT had putforward in relation to the relief well, does that appearright to you?A. Yes.

Q. If the operator could scroll up the email string,please, do you see that there a Mr David Wong, principalpetroleum operations adviser from the Victorian DPIE,purports to provide some comments on PTT's WOMP?A. I see that.

Q. If the operator could continue scrolling up, please,and perhaps go to the top of this email and scroll downslowly so Mr Marozzi can read it. Do you see there on4 September 2009 at 11.44am David Wong was sending an emailto Mr Holland, and he cc'd you in?A. Yes, I see that.

Q. Do you recall receiving this email now?A. That looks familiar, yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2175

Q. And do you see he says there:

Attached is our comments on the DrillingProgram.

A. Yes, yes.

Q. And he says:

Because of the many unknowns, we could notcome to a conclusion whether the WOMP andthe Drilling Program are adequate orcomplete.

Do you see that?A. I see that, yes.

Q. Then he says at the start of the next page:

We fully support GA's comments that weresent earlier from Dong Hai.


Q. "GA" stands for Geoscience Australia, doesn't it?A. Yes.

Q. And Geoscience Australia has people with someexpertise in relation to offshore petroleum drilling,doesn't it?A. I believe so, yes.

Q. If the operator could continue to scroll down, please,do you see that the email is signed off:

We will be happy to discuss if required.

A. Yes, I see that.

Q. I suggest that that email represented an attempt byMr Wong to offer any assistance that was reasonablyrequired by the Northern Territory in undertaking thisimportant task; do you agree with that?A. Yes, I agree.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2176

Q. If we go down a bit further, and the operator willthen need to scroll down through this slowly so Mr Marozzican read it, do you see there a suggestion about the WOMPand the drilling program.A. Which part are you asking me to read?

Q. If you could read it all, Mr Marozzi. You might notneed to read all the inserted bits from the regulations ifyou're familiar with them, but you tell us when you'reready to move on.A. Yes.

Q. If the operator could scroll down, please. Do youneed to read regulation 6 of the regulations, Mr Marozzi,about the contents of a WOMP, or are you sufficientlyfamiliar?A. No, that's just a cut and paste, I think.

Q. If the operator could keep scrolling down, then,please. Does this prompt a sufficient recollection of thisemail, or would you like to read through it in detail?A. I'll read it in detail if I - I'll ask, if I need to.

Q. Would you agree that Mr Wong was doing his best tooffer good-faith assistance to the Northern Territoryregulator in responding to this crisis that had arisen?A. Yes, I agree.

Q. Would you agree that he was making constructivecomments about perceived failings in the WOMP submitted byPTT?A. He was attempting to, yes. I believe that was hisintention, yes.

Q. The burden of what he was suggesting, was it not, wasthat the WOMP didn't have sufficient detail to enable theregulator, in his view, to accept it as meeting all thecriteria in the relevant regulations; is that right?A. That was his view about this WOMP for the relief well,yes.

Q. Were you present the other day when Mr Jacob gaveevidence that he thought that there were two schools ofthought in relation to WOMPs?A. Yes, I think I was here.

Q. Do you recall Mr Jacob saying that he thought more

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2177

detail was better?A. I don't remember the exact time he said that, butI take your word for it.

Q. He gave evidence to the effect that there wasthe roadmap approach and then the more detailed approach,and his personal view, given his extensive experience bothin Australia and overseas, was that the more detailed viewwas the better one; do you recall him saying that?A. I'll accept what you're saying, yes - that he saidthat, yes.

Q. This is exactly the approach being advocated byMr Wong, isn't it?A. At this time, yes, that's right.

Q. You certainly don't suggest to the Commissioner thatit's not a valid view to have taken on the part of Mr Wongor Mr Jacob, do you?A. It's a valid view, but it didn't help us at the time,given our priorities.

Q. I suggest that it's more than a valid view,Mr Marozzi; it's the correct view, when one has regard tothe fact that the WOMP is the crucial aspect of the newregulatory and legislative regime that has been in placesince 2004. Do you agree with that?A. No. At this point in time, the WOMP was the least ofmy concerns.

Q. Well, do you take issue with the suggestion that theWOMP is the crucial regulatory and legislative regime?A. Not the crucial, no.

Q. You don't think it is?A. I wouldn't use the word "crucial". It's theoverarching document that reflects the well constructionprocess, but it's not specific to the requirements of thewell. During this time, we were trying to approvea program to intercept the blowout. The information was inthe program.

Q. Just listen to my question, Mr Marozzi, and directyour answer to the question I ask you. I'm asking whetheryou agree that what is contained in a WOMP, and ensuringcompliance with what is in a WOMP, is the central aspect ofthe regime that has been in place since 2004?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2178

A. Yes, generally speaking, yes.

Q. It's all based around a WOMP, isn't it? Activitiescan't be conducted without an approved WOMP in place;that's right, isn't it?A. That's right, yes.

Q. And if an operator isn't complying with the Act or theregulations, then their WOMP can be revoked; that's right,isn't it?A. That's correct.

Q. And if a WOMP is revoked, then they can't undertakeactivities; that's right, isn't it?A. That's correct, yes.

Q. And the manner in which an operator satisfiesa regulator that it's conducting its activities inaccordance with good oilfield practice is what's containedin the WOMP?A. Not only the WOMP, but yes.

Q. But that's the primary document that's meant tosatisfy the regulator that that is going to occur, isn'tit?A. Yes.

Q. Could you have a look at the last sentence on thescreen, Mr Marozzi, namely, Mr Wong's statement that:

Without sighting the relevant sections of[various] documents, we are unable to gaugewhether the relevant sections are adequateor have met the requirements of theRegulations. While the WOMP can be asgeneric as possible, the relevant company'smanuals and management systems must belisted or referenced or provided to enablethe DA to make the decision to accept ornot to accept the WOMP.

Do you agree with that statement?A. Yes. Yes.

Q. What that is suggesting is that the relevantdocuments, such as the well construction standards, have tobe carefully considered prior to accepting a WOMP; that's

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2179

right, isn't it?A. Yes.

Q. One way of doing it is to effectively extract relevantparts and include them in the WOMP; that's right, isn't it?A. Yes, that's right.

Q. But if that's not done, at least there's a requirementto carefully consider what those documents contain beforeticking off on the WOMP; that's right, isn't it?A. That's correct, yes.

Q. Good regulatory practice is not just to tick offa WOMP because it states that there is going to becompliance with well construction standards, if you don'tknow what's in those well construction standards; that'sright, isn't it?A. That's right.

Q. These are the points that Mr Wong was trying to maketo the Northern Territory DA in this email; do you agree?A. He was, yes.

Q. Do you recall the response that you gave to thisemail, Mr Marozzi?A. No, not the exact wording, no.

Q. Do you recall the general nature of the response? Wasit, "Thank you very much for those helpful comments,Mr Wong. We're really appreciative"?A. Well, no, I don't believe I replied to Mr Wong.

Q. Well, you made some comments about his suggestions,didn't you?A. To my supervisor.

Q. Do you recall what those comments were?A. Not exactly.

Q. Do you have a general recollection?A. That at that point in time Mr Wong's comments inrelation to the WOMP were not our focus. It didn't help usmuch.

Q. Well, let's have a look at what you actually said,Mr Marozzi, if the operator could go to the top of thedocument, please. You say to Mr Holland that Mr Wong's

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2180

response is predominantly of very limited help.A. Yes.

Q.All ... but 2 of the comments constituteeither cosmetics (window dressing), micromanagement, asking the obvious or asking usstuff that is not our responsibility ...

Upon reflection, do you agree that that is not a faircomment to have made, Mr Marozzi?A. No, I don't accept that. This was about help we werehoping to get about the relief well.

Q. A relief well for a company that had just had a wellblowout, isn't it?A. Which at the time we did not understand why.

Q. Yes, and it might very well have been that the blowouthad occurred because the company had not complied with itsown construction standards, mightn't it?A. Yes, all --

Q. And it was a relief well for a blowout in relation toa company that might not have complied with its WOMP;that's right, isn't it?A. Can you repeat that?

Q. The document being considered was a WOMP for a reliefwell in relation to a blowout that had occurred in relationto a company where there would be real cause to considerwhether in fact they had been conducting their operationsproperly; that's right, isn't it?A. Hence --

Q. Because almost by definition, in the absence of anearthquake or a rocket hitting a well or something of thatnature, a blowout constitutes a failure to comply with goodoilfield practice, doesn't it?A. Arguably so, yes.

Q. You don't allow wells to blow out through no fault ofanyone else or an act of God unless there has beena significant failure - almost by definition that's right,isn't it?A. Yes, fair comment, yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2181

Q. So when we're looking at a relief well for this verycompany, do you not think these sorts of things are morethan micro-management or window-dressing and might be aimedat preventing the very things that had caused the blowoutfrom being repeated in the relief well operation?A. I had to focus on the drilling program to assist --

Q. But you had to ensure that it was done properly,didn't you, Mr Marozzi?A. I had to assist - my supervisor had instructed me tofocus on the drilling program, and that's what I did.

Q. That didn't mean just conduct a tick and flickexercise --A. No.

Q. -- whereby you approved the thing as quickly aspossible, did it?A. That program was very heavily scrutinised to make surethat when the West Triton arrived, PTT was not waiting foran approval; that the rig was ready to go and spud the wellas soon as it arrived. That was our focus, and that's whatI was very carefully reminded of by my supervisor.

Q. Are you intending to suggest to the Commissioner thatthe focus, in considering the relief well documentation,was not to inconvenience PTT?A. The focus was to bring an end to the flow as soon aswe possibly could and assist PTT to do that.

Q. One of the most important aspects of that, I suggest,was to ensure that the relief well was conducted safely andappropriately in accordance with good oilfield practice?A. Hence the reason to focus on the drilling program,that's the specifics. The WOMP is just a generic documentabout a well construction process. That process hardlychanges. The specifics to this drilling project lay in thedrilling program. I had to focus on that.

Q. You agreed yesterday, I think, that a drilling programsays what is going to happen, but the WOMP adds colour andmovement and detail in relation to how it's going to bedone; is that right?A. In an overarching way, yes.

Q. And it may be no good whatsoever if the right stepsare going to be taken but they're not going to be done in

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2182

the right manner; that's right, isn't it?A. Please say that again?

Q. It might be no use whatsoever if the right steps areset out in the drilling program but they are doneincompetently or poorly; that's right, isn't it?A. That's right.

Q. So it's no good, for example, having a cemented casingshoe in the relief well if it's not going to be aneffective barrier preventing further hydrocarbons enteringa relief well?A. Sure.

Q. So surely an important part of ensuring well integrityis to look at how the company is going to do the verythings it's proposing in its drilling program?A. Yes, which we always do, because the nature of theWOMP that PTT submit - its style has not changed sinceI started in this position, so I didn't see the need toreinvent the wheel with a generic document that's hardlychanged.

Given the circumstances, I had to focus on thedrilling program, as I was instructed by my supervisor, andthat's why he took care of these comments. Okay, I've madesome disparaging or not so complimentary points, but giventhe circumstances, I stand by them.

Q. Do you stand by your comment in the email, Mr Marozzi,that maybe you get a little lax here at the NorthernTerritory, but only because you have such an open andongoing relationship with all the key players at PTTEP?A. Like I pointed out yesterday, before H1, PTT still hasgot an excellent track record.

Q. What, again, do you base that statement on?A. Like I mentioned yesterday, all of the activities theyhave done in drilling, in production facilities, inexploration wells, environmental, development wells - okay,H1, there was a problem, but they did not just arrive anddrill one well, botch it up and then leave. They've beenaround for a long time.

Okay, H1 - serious. I don't belittle that. But priorto that, they have got a very, very good track record, andI would say faultless.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2183

Q. When did PTTEPAA - you know who I'm referring tothere, Mr Marozzi - come into existence again?A. I can't remember.

Q. I suggest that it was in early 2009; does that soundright?A. Yes, that sounds right.

Q. Well, that's hardly a long period to have a faultlesstrack record, is it?A. It's a change in name. The same people are there.

Q. Well, is that all it is, Mr Marozzi?A. Yes, according to my level --

Q. Is exactly the same management structure in place?A. The same operational people I deal with, that's whatI should say.

Q. So you mean Mr Wilson and Mr Duncan hadn't changed?A. Mr Jacob - there's others, yes; there's a lot of them.

Q. Ms Breadmore and a few others?A. Yes.

Q. And because they hadn't changed, you considered thatthe company hadn't changed in any way, shape or form?A. I'm not sure what you're trying to put to me.

Q. I'm suggesting that merely because a handful ofindividuals are the same, that doesn't necessarily meanit's the same organisation, does it?A. The handful of individuals that contributed to thisexcellent track record they have before the H1 blowout.

Q. And if the new company had imposed completelydifferent standards or promoted a culture of cost cuttingor something like that, the fact that these individualswere still there might have still led to a very differentsituation, mightn't it?A. Given the professional nature of these individualsthat I've worked with over the past two and a half years,I wouldn't think that would happen, but it's possible.

Q. So you say that because you had dealt with thishandful of individuals for a few years and there had been

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2184

no incident, that justified getting a little bit lax inconsidering the company's drilling operations; is thatright?A. You're using the word "lax" just because I wrote itthere, and that's in relation to just a chain of commanddocument. But what I would say - I wouldn't use the word"lax". I would say that given that there is a very goodhistory of performance before H1, you do develop a verygood relationship with operators. There's no betterexample, in our department, as operators - officers fromPTT. Therefore --

THE COMMISSIONER: Q. Mr Marozzi, you know that none ofthe five wells on the wellhead platform for Montara comply,don't you?A. I understand that, yes.

Q. How do you know what the situation is with the otherwells?A. Because they weren't involved in a batch drillingsequence. The Montara --

Q. That's beside the point. What have you done tosatisfy yourself that they deserve this fine reputationover two and a half years of your experience? What's yourevidence for that assertion?A. I just don't have any reason to have a problem withthem.

Q. I don't think you have looked, have you, Mr Marozzi?A. Well, I've assessed a lot of their applications.

Q. But you haven't gone and seen if they've complied withtheir applications?A. True, I have not done heavy --

Q. Just --A. Okay, fair comment.

MR BERGER: Q. You've done no compliance monitoringwhatsoever in relation to PTT, have you, Mr Marozzi?A. Do you mean on-site compliance monitoring?

Q. I mean monitoring to ensure that they're complyingwith approved programs and their own standards other thanreviewing what they send you by way of information.A. Generally speaking, I admit, because we do not have

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2185

a robust and rigorous compliance monitoring process,because the regulations don't require it, I do very little,yes.

Q. Well, more than not having a rigorous compliancemonitoring program; you have none whatsoever in terms ofindependently verifying that PTT are doing what they'resupposed to be doing - that's right, isn't it?A. The extent of the monitoring I do is in terms ofprogress through the drilling report, just an activityprogress. That's probably the limited - if I seea problem, like I mentioned yesterday, I'll try to get toit. But if it has not been drawn to my attention,consistent with the regulations, yes, I do a very limitedamount of compliance monitoring.

Q. The compliance monitoring that you do do, as youdefine it, is solely reliant on information provided to youby PTT; that's right, isn't it?A. That's right.

Q. And that did very little good in relation to whetherthey had installed the 13-3/8" pressure-containingcorrosion cap, did it?A. Which size, which one?

Q. The 13-3/8" pressure-containing corrosion cap.A. Yes, things fell through the cracks there.

Q. The information they have provided suggests that ithad been installed, when in fact it hadn't; that's right,isn't it?A. That's right.

Q. And doesn't that rather suggest the danger of relyingsolely on information provided by an operator to ensurethat they are complying with approved programs and goodstandards?A. Yes, it represents a limitation, yes.

Q. Leaving aside the technical merits of the argumentsput forward by Mr Wong, do you agree that the emailexchange I have directed your attention to suggestsa significantly different approach between the Victorianregulator and the Northern Territory regulator in relationto the issue of WOMPs?A. Yes, I believe that's the case, yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2186

Q. And it's a fundamentally different approach inrelation to perhaps the most crucial aspect of the newlegislative and regulatory regime; do you agree?A. I wouldn't use the word "crucial", but I take yourpoint.

Q. You again wish to resile from the crucial nature ofthe WOMP in the regime, do you?A. I'm sorry? I beg your pardon?

Q. Do you wish to suggest that the WOMPs are nota crucial aspect of the regulatory regime you work in?A. It's important. It's important, but --

Q. And do you agree that it's not a good thing fordifferent regulators to have a fundamentally differentapproach to such a crucial thing as WOMPs?A. Yes, I agree.

Q. More than a difference of approach, this emailexchange suggests some animosity between the regulatorsfrom the Northern Territory and not only Victoria but alsoGeoscience Australia, doesn't it?A. I wouldn't say that. Animosity?

Q. It says that you guess you're "no longer surprisedthat DPI Vic supports GA's equally unhelpful comments".Does that suggest some ill feeling or less than cordialworking relationships between you and the relevant peoplefrom the other regulators?A. It does seem to suggest that. I don't really rememberwhy - what reference I'm making there, because I've notdirectly liaised with GA at all. I'm not really sure whyI brought that up. It's an email between me and Alan.Maybe we were sharing a joke at the time or something. I'mnot really sure, but I don't think it reflectsa deep-seated animosity or anything.

Q. Well, it doesn't look very good, does it, Mr Marozzi?A. No, it doesn't look good.

THE COMMISSIONER: Q. It's not just a disagreement withVictoria on WOMPs. What I have heard this morning isa profoundly different approach between Victoria and theNorthern Territory and between Western Australia and theNorthern Territory with respect to fundamental issues when

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2187

it comes to well integrity?A. Yes.

Q. You agree?A. Possibly, yes.

Q. Not "possibly"; yes?A. I'm just not sure exactly which parts you're referringto.

Q. The letters that Mr Berger took you to earlier.A. Okay, yes.

THE COMMISSIONER: So it's not just one regulator: it'sGA, it's Victoria and it's Western Australia; and, I mightthrow in, from what has so far come to this Inquiry,between NOPSA's understanding of regulatory requirementsand the Northern Territory's as well.

MR BERGER: Q. Mr Marozzi, finally, reflecting on thedocumentation that you reviewed in the lead-up to thisInquiry and the evidence that you have heard and theevidence that you have given, could you tell theCommissioner what steps you are going to take in the futurethat you haven't previously taken, as you return to assistthe delegate to fulfil his important regulatory function?A. The first one would be to make sure that if we doanother batch drilling project, offline activities areincluded on the DDR so that the DDR reflects all workundertaken on a well.

Q. How are you going to ensure that that happens,Mr Marozzi?A. I'll have to just raise it directly with my supervisorand then go from there about how we can do that.

Q. Is it not as simple as not approving any WOMPs thatdon't have data management plans or other documents thatsuggest that's going to occur?A. Remember, I don't approve. Are you suggesting unlessthe operator implements that change - I could probably doit that way.

Q. Then it would also require some scrutiny of dailydrilling reports to check that offline activities are beingincluded, wouldn't it?A. I would need a bit more help to do that, yes. Yes, on

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2188

the assumption that we have another engineer.

Q. That wouldn't be a hard thing to do, would it? Youhave to read the daily drilling reports, anyway, don't you?A. Provided we could recruit someone with thatunderstanding, yes. Yes, that's right.

Q. Can you not read a daily drilling report and determinewhether or not offline activities have been reported?A. I can, yes, but it's not my focus under the currentregulations and our current resources.

Q. So do you suggest that's not something you think youwill do?A. No. If I had the resources, I would very much like todo it, if I could.

Q. Well, how many more resources do you need to reada daily drilling report each day to determine if offlineactivities have been included or not?A. We need a couple more engineers. My focus isassessment of applications. I do operational assessments.I do survey assessments. I do environmental assessments.I do first approval assessments and operationalassessments.

Q. So you say it is not your job to read the dailydrilling report to determine whether things like barriershave been installed offline in a batch drilling operation?A. I'm not saying that.

Q. That's someone else's job, is it?A. I'm not saying that. It is my job, but I can only doit to a level that our resources allow.

Q. These daily drilling reports are hardly War and Peace,are they? They're typically two or three pages; that'sright, isn't it?A. That's true, yes.

Q. How many daily drilling reports would you receive, onaverage, each day?A. It depends on the level of activity at the time. Itdepends on how many onshore wells we have and how manyoffshore wells, so it could vary between one - sometimes itcould be zero. It could vary from zero to about - we'vehad up to five or six.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2189

Q. It's hardly an onerous obligation on your part to readthose carefully, is it?A. It is when you're overseeing those operationalapplications, four to five, up to six, operationalapplications. PTT's would be only one.

Q. Yes.A. So it can be onerous, yes; it can be onerous.

Q. We're talking about maybe 15 pages, 20 pages at most,on a day; is that right?A. Pages that you are suggesting that you are not justglancing at but heavily scrutinising, so it is onerous todo it properly.

Q. And you suggest that your department is not resourcedto enable that to occur?A. We could do with a bit more help, yes.

Q. What else do you think you will change as you go aboutyour work assisting the delegate, Mr Marozzi?A. Well, on that discussion about compliance monitoring,it would be useful, if we were resourced, to nominate anindividual who could do a bit more of a rigorous compliancemonitoring test or process. But I'm not responsible forresourcing, so I'm at the mercy of my supervisors there.

Q. So do you think that unless further resources areprovided to your department, it's not going to be possibleto embark on any further compliance monitoring than whathas occurred in the past; is that right?A. No. It's just going to continue to be a bit ofa struggle like it currently is.

Q. Do you think you might pay closer attention to wellconstruction standards when you're assessing drillingapplications in the future?A. Yes, yes, I will now.

Q. What else do you think you might do differently,Mr Marozzi?A. I think it would be very useful that, if we havea similar situation, where individuals on the rig andonshore support are signing off on replacement - sorry,installation and removal of barriers.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2190

Q. Is there anything else, Mr Marozzi?A. For future batch drilling operations, I would beasking the operator to please list estimated times betweenoperations so that in jumping from well to well, there'sa more explicit representation of the times taken.

Q. Yes. Anything else?A. At this stage, that's all I have.

Q. What about if there's a blowout or incident of thatkind in the future, Mr Marozzi - do you think you mightlook more closely at what has happened and why and what canbe learnt from that?A. Well, if we had a bit more resources, yes, I would.I would. Like I said before, my time had to be taken upwith the approval of that program.

Q. Do you say that the Northern Territory Department ofResources is not adequately resourced to enable you, as theperson solely responsible for technical assessment ofdrilling applications, to look back over the blowout andevents leading up to it and learn lessons from that?A. Yes, that's fair comment, because yesterday I saidwe're adequately resourced to meet outcomes, which arepredominantly assessment of applications; so I do struggleto get to the scrutiny required for DDRs, for compliancemonitoring.

THE COMMISSIONER: Q. Mr Marozzi, from what I've heard,I question whether or not you're even adequately resourcedto assess applications. There doesn't seem to have beenmuch inquiry or questioning.A. That's a fair question.

MR BERGER: Q. Mr Marozzi, I would like, finally, toshow you a comment made about your evidence bya Mr Danenberger, and I'll ask the operator to bring thesedocuments up on the screen, on the viewer. Before takingyou to these comments about your evidence, I would like youto assume that the person who made them was employed as anengineer in the United States Department of Interior'sOffshore Oil and Gas Program for 38 years, as a staffengineer in the Gulf of Mexico, and was Chief of TechnicalAdvisory Section at the Headquarters Office of theUS Geological Survey, and then was District Supervisor forMinerals Management Service field offices in Santa Maria,California and Hyannis, Massachusetts. You know what the

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2191

US MMS is, don't you?A. No.

Q. I'd like you further to assume that the person who hasmade these comments then became Chief of the EngineeringOperations Division at MMS Headquarters, and then laterserved as Chief of Offshore Regulatory Programs withresponsibilities for safety and pollution preventionresearch, engineering support, operating regulations andinspection and enforcement programs, and on 10 October 2009was inducted in the Offshore Energy Centre Hall of Fame asa Technology Pioneer. Could you assume that the author hasthose qualifications for me, please, Mr Marozzi?A. Yes.

THE COMMISSIONER: Q. Just by way of clarification, theMinerals Management Service is your counterpart; they'rethe offshore regulator in the United States.A. Yes, thank you.

MR BERGER: Q. If document ID INQ.9000.0001.0001 couldbe brought up, please, and if the operator could scrolldown, please, do you see there, Mr Marozzi, that the authoris commenting on Day 18 of what he calls the "Montarahearings"?A. Right.

Q. It then extracts a question and answer from yourevidence yesterday. Do you see that?A. This is yesterday's, yes.

Q. Yes.A. Right.

Q. Then if the operator could scroll down, please, do yousee that the author says:

To this outside observer, it was not a goodday for the Northern Territory Departmentof Resources. While it is premature tospeculate on the Commission's conclusionsand the followup actions by the AustralianGovernment, today's testimony has nothelped the NT cause. The witness'sattitude seems to be that if it's goodenough for the operator, it's good enoughfor the regulator ...

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2192

Pausing there, do you agree that's a fair assessment of theevidence that you have given to the Inquiry?A. What's the "it" he's referring to, if "it's" goodenough? Does it say that?

Q. Surely, you can understand the point he's making,Mr Marozzi?A. Well, I'm not really sure I wish to speculate, butwhat's - I don't know. Is he referring to somethingspecific?

Q. What he's suggesting is that if the operator isprepared to conduct activities in a certain way, thenthat's good enough for you in assessing the applicationsand you don't need independently to scrutinise it orcompare it to their standards or think about whether itconstitutes good oilfield practice; they can be trusted todo what's best, and if they are satisfied with it, then youshould be satisfied with it. That's the burden of thecomment that's being made, I suggest to you.A. Yes, I wouldn't agree with that. I can understandwhat he's trying to say, but it's also a function of thecurrent non-prescriptive regulations.

THE COMMISSIONER: Q. It's very close to a summary ofwhat you said yesterday, I would suggest, Mr Marozzi. Theimport of it is very close to what I believe you suggestedyesterday to me. Do you disagree?A. I just believe it's probably watered right down, butif he's trying to say that what I would have been saying,in general, as a summary, is that, yes, we can't compliancemonitor to a level that we'd like to, and we're probablyresourced to a level that the regulations require us to be,so that could be borne out in those comments, yes, that'sfair enough.

MR BERGER: Q. Do you see that the author then goes onto say:

While operator's responsibility should bea fundamental tenet of any regulatoryregime, the regulator needs to verify theeffectiveness of the management andoperational systems.

Do you see that?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2193

A. Well, yes, in theory, that's - yes, that's --

Q. And do you agree with that statement?A. In theory, yes, yes.

Q. But you say, whilst that might be good in theory, yourdepartment is not resourced to do that properly; is thatright?A. That's a fair comment, yes.

Q. Then the author continues:

This can be accomplished through somecombination of audits, inspections, programand plan reviews, performance measures, andother means.


Q. You would agree with that?A. Yes. Yes.

Q. But your department does virtually none of thosethings in relation to operators in the Northern Territoryarea, does it?A. That's correct, yes.

Q. Again, you would say because it's not resourced to doso?A. That's right, yes.

Q. Then the author concludes his comment on your evidenceby saying:

However, the regulator cannot be passive inany type of regime - performance-based,prescriptive, or hybrid.


Q. Do you agree with that statement?A. Yes, that's a fair comment if - yes.

Q. And do you agree that the Northern Territory DA isa very passive regulator?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2194

A. Yes, that's the way this is written - that's a fair -we don't micro-manage, so that can be taken as relativelypassive, yes.

Q. I suggest there is no "relative" about it, Mr Marozzi;it's an entirely passive regulator?A. Well, I meant relative to perhaps other regulators.But I take your point.

THE COMMISSIONER: May I just interrupt, Mr Berger. Yousaid, I think, earlier, that the Northern Territorydepartment is not adequately resourced to do so. I don'tthink that has been established. All I've heard is thatMr Marozzi and his unit don't have the resources to respondproperly. I doubt very much if the department doesn't havesufficient resources, should it so choose, to allocatesufficient resources to this task. It's a matter of choiceon their behalf, I would have thought, but that's somethingthat can be established at some stage over the next day ordo.

MR BERGER: Commissioner, those are probably issues thatmight be more properly addressed with the witnesses thatwill follow rather than Mr Marozzi.

THE COMMISSIONER: Yes, but you were saying that thedepartment is not adequately resourced, and that's all I'mdrawing your attention to. I don't think it's thedepartment. I think it's Mr Marozzi's area that is notadequately resourced.

MR BERGER: Q. Do you want to comment on that,Mr Marozzi?A. Yes, I can, because rigorous and robust compliancemonitoring requires someone with a drilling background,I believe, in my opinion. You need to understand what'shappening on a rig floor to do effective compliancemonitoring and --

Q. Just pausing there, you're the only one in thedepartment with that background; that's right, isn't it?A. That's correct, yes.

Q. So the department has not provided sufficientresources, in your view, to enable further compliancemonitoring to take place; is that your position?A. Yes, we don't have another drilling engineer.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647

.14/4/10 (19) J P F WHITFIELD (Mr Berger)Transcript produced by Merrill Legal Solutions

2195

Q. Whether they have the money available to do that ornot is a different question, but, in your mind, there arenot the people onboard --A. With those skills, yes. We just don't have someoneelse who understands what happens on a drilling rig.

MR BERGER: Thank you, Mr Marozzi. I have no furtherquestions.

MR GRANT: I have no questions, Mr Commissioner.

MR ABBOTT: I have no questions. Thank you,Mr Commissioner.

THE COMMISSIONER: Thank you. Nothing further that youwant to come back to, Mr Berger?

MR BERGER: No, Commissioner.

THE COMMISSIONER: Thank you. We will proceed with thenext witness, then. I think you are excused, Mr Marozzi.Thank you very much for your attendance, but feel free tocontinue to sit in, I think, for the rest of the NorthernTerritory's --

THE WITNESS: I think I have a plane to catch, but I'm notsure. Thank you.

THE COMMISSIONER: Okay.

<THE WITNESS WITHDREW

MR BERGER: If Mr Whitfield could be called to giveevidence, please, Commissioner.

<JEREMY PAUL FRANK WHITFIELD, sworn: [3.40pm]

<EXAMINATION BY MR BERGER:

MR BERGER: Q. Sir, your full name is Jeremy Paul FrankWhitfield?A. That's correct.

Q. And your work address is 5th floor, CentrepointBuilding, Smith Street Mall, Darwin, Northern Territory;correct?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2196

A. Correct.

Q. You are currently the Director of Energy within theMinerals and Energy Titles Division of the NorthernTerritory Department of Resources?A. Yes.

Q. That's a position you've held since 1 September 2005?A. Yes.

Q. You are currently the delegate of the designatedauthority for the offshore area for the Territory ofAshmore and Cartier Islands?A. That's right.

Q. That's the area where PTT held their productionlicence; correct?A. Yes.

Q. Could you outline to the Commissioner your formalqualifications?A. I have several qualifications. I have a certificatein land and engineering survey drafting, I havea certificate in surveying and a graduate diploma inadministration.

Q. Have you undergone any formal on-the-job training,such as attendance at seminars or matters of that kind?A. Yes, I have.

Q. Could you tell us what that consists of?A. Can I just seek clarification - I'll just focus on thepetroleum-focused areas?

Q. Yes, or other things that you think are relevant tofulfilling your duties.A. In terms of things that are relevant, I've studiedseveral legal units, including native title law, offshorepetroleum law. I've attended, I think, three differentcourses on offshore and onshore petroleum exploration andexploitation. I've done basic geology classes. Ingeneral, I've focused on things that are pertinent toresource management. In addition to that, there's beenadministrative-type courses.

Q. Is it the case that you and Mr Holland chop and changein terms of who is the delegate, or is it only if you're on

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2197

leave or something of that kind that Mr Holland becomes theofficial delegate?A. Generally when I'm on leave, Mr Holland becomes thedelegate. There was a circumstance late last year whenI was on another project for a couple of months, soI wasn't actually on leave, but Mr Holland was the delegateduring that period as well, but that's unusual.

Q. How was that change of delegates effected?A. The delegation is to the title of Director of Energy.The Director of Energy is a position appointed by the CEOof the department and it's effected by a document sent tothe CE, who signs that document agreeing to the change ofposition.

Q. But unless and until that position as Director ofEnergy changes, you are, at all times, delegate andMr Holland is not; is that the position?A. That's correct, that's correct.

Q. Do you know who was the delegate throughout last yearat various times?A. Not offhand. I do know that I had leave early in theyear, mid-December to mid-February. I think I had a coupleof weeks' leave mid-year, and then late in the year I wasseconded to another project for approximately two months.

Q. Can you be more specific about when your leave wasduring mid-year?A. Not without doing some research.

Q. Do you recall if you were the delegate during March oflast year?A. I believe I was.

Q. If the memorandums of 9 March bearing your signatureare any indication, that would suggest that you weredelegate at least at that time, wouldn't it?A. Yes, yes.

Q. That is also the case in relation to the drillingprogram approved in July last year; correct?A. That's correct, if I signed the document, I wasdelegate.

Q. So we can be satisfied that, at the time you signedmemorandums prepared by Mr Marozzi and thereby signified

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2198

your approval of the application, you were the delegate?A. Yes.

Q. Whilst you were delegate, Mr Holland had no legalstatus to approve anything; that's right, isn't it?A. Yes.

Q. Did you hear Mr Marozzi give evidence yesterday abouta practice that had developed that if preliminary approvalwas sought, he would try to discuss it with you, but if hecouldn't discuss it with you, he'd discuss it withMr Holland?A. Yes.

Q. Did you hear that evidence?A. Yes.

Q. Is that consistent with your understanding of thepractice that had developed, at least by last year, in thedepartment?A. Generally, the process that Mr Marozzi outlined isconsistent with the practice and the instructions that I'dgiven to that effect. I don't agree that it was to theextent that Mr Marozzi himself had authority to approvewithout discussing it further with myself or Mr Holland.

Q. Did you hear Mr Marozzi give evidence to the effectthat whilst initially after he started, if preliminaryapproval was sought, he would ask you or Mr Holland whethersuch approval should be given, the practice came to thepoint where he would really tell you that he was going togive what he considered preliminary approval and then woulddo so unless he was told not to do so?A. I heard him say that. I didn't agree with thatstatement.

Q. So you considered it to be the case that it was not aninforming of you or Mr Holland about what was going tohappen, but it still had to be a request by Mr Marozzi forapproval before he was to signify that preliminary approvalhad been given; is that the case?A. That's correct.

Q. Is that the case regardless of who was delegate at thetime?A. Yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2199

Q. So that if, for example, you were engaged in a meetingor out of the office when preliminary approval was sought,then preliminary approval could be signified, providedMr Holland had been consulted and had agreed that thatshould occur?A. Only in exceptional circumstances. If it was a matterthat I was out of the office for a short period - forexample, there was a meeting on but I was still thedelegate - I would have wanted to know, unless there wasa very good reason why the approval needed to be urgent.

Q. You've seen the documents in relation to the approvalsought by PTT on the afternoon of 6 March 2009, haven'tyou?A. Yes, yes.

Q. They sought approval at 2.37pm; is that right?A. Yes.

Q. And do you recall that approval was given at 3.07pm?A. Yes.

Q. Now, do you have any recollection of that day or thatprocess?A. I have no recollection. I checked my diary yesterday,and I was in Melbourne on the Thursday, but I believeI flew back to Darwin that day. But I don't recall thatdiscussion on the Friday - or any discussion on the Friday.

Q. When you say that you flew back to Darwin "that day",do you mean the Thursday or the Friday?A. Thursday, Thursday.

Q. But you're not sure if you were in the office on theFriday?A. I believe I was, but I definitely can't recalla discussion on that day about that well. That's not tosay it didn't happen, but I can't recall.

Q. Would you be able to check records that the departmenthas about travel requisitions or matters of that kind todetermine if you were in Darwin on 6 March?A. I was in Darwin on 6 March.

Q. Have you checked your diary or any other records thatyou maintain to see if there is any notation of discussionswith Mr Marozzi about the approval of suspension of the H1

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2200

well that day?A. I haven't. I don't keep a diary to the extent thatI record those types of meetings with staff members.

Q. Do you recall seeing the memorandum that Mr Marozziprovided to you on 8 March 2009 in relation to thesuspension, in the course of the past couple of days?A. Yes.

Q. Perhaps if the operator could bring upNTG.0001.0004.0145. Do you recognise this document?A. Yes.

Q. If the operator could scroll over to the next page,you'll see that you have signed it on 9 March 2009; that'sright?A. Yes.

Q. And you've crossed through the words "not signed"?A. Yes.

Q. And, in doing that, you intended to signify youapproved the suspension that had been sought by PTT; isthat right?A. Yes.

Q. If the operator could go back, please, to "Time frame"on the previous page, does that or anything else in thememorandum suggest to you whether or not it was likely thatMr Marozzi consulted with you prior to --A. I don't recall he did. I have no memory of thatspecific approval.

Q. But my question is, does what's contained in thisdocument, in light of practices that had developed oranything else, suggest to you one way or the other whetheror not it's likely he did consult with you?A. No.

Q. Whilst the document doesn't say anything like, "Asdiscussed on Friday", or suggest any assumed knowledge onyour part, you don't consider that necessarily suggeststhat no conversation occurred?A. No.

Q. Is this the sort of memorandum that you wouldtypically receive from Mr Marozzi when an application had

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2201

been made for approval by an operator?A. Yes.

Q. Is it the case that this was all you would everreceive from Mr Marozzi in seeking your approval tosomething that had been submitted to the Northern Territorydepartment?A. No. The submission would be accompanied by a letterof approval if the recommendation was to approve, andI believe in this case it was.

Q. Just pausing there for a moment, Mr Whitfield, if theoperator could bring up, please, NTG.0001.0004.0144 andscroll down to the bottom of the letter, is this the letteryou speak of, Mr Whitfield?A. Yes.

Q. So a blank one of those, in the sense that it could besigned by you, would be attached to the memorandum providedby Mr Marozzi; is that right?A. Yes.

Q. Would you receive other information from Mr Marozzitypically when you were asked to approve an application?A. In some instances, depending what the application was,I would receive the correspondence from the applicant.I wouldn't, in this instance, for example, have receiveda large document to approve, but if there was a letter ora smaller document, I would receive that.

Q. So you would sometimes receive the letter constitutingapplication for approval; sometimes you wouldn't?A. Yes.

Q. Would you ever receive any technical information orrisk assessment or anything like that, in being asked toapprove an application?A. I don't recall any risk assessments. In someinstances, I would receive some technical information.

Q. You heard Mr Marozzi's evidence to the effect that heconsidered he was the only person in the department withthe skills or experience to properly assess the technicalaspects of applications relating to drilling activitiessubmitted to the department; you heard that evidence?A. Yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2202

Q. And do you agree with his evidence on that point?A. We have had instances where other people in the energyoperations area have approved well operations. That hasparticularly occurred in the absence of Mr Marozzi.

Q. That wasn't quite my question, Mr Whitfield. Myquestion was whether you agree with his evidence to theeffect that he was the only person in the department withthe sufficient skills and experience to undertake ananalysis of the technical aspects in a drillingapplication?A. Within the energy operations area, yes. I can't speakfor the whole department. I suspect so.

Q. In relation to the part of the department that assistsyou to fulfil your role as delegate, do you agree that'sthe case?A. Yes.

Q. So you would agree that that's the case in relation totechnical assessment of drilling matters as opposed to dataor environmental or other aspects; agreed?A. Yes.

Q. You said that sometimes people other than Mr Marozziwould approve an application. Do you recall giving thatanswer a moment ago?A. If I said "approve", obviously the approval is notwith that officer. Other officers have reviewedapplications and prepared submissions.

Q. In relation to offshore drilling activities?A. Yes.

Q. Which other officers have fulfilled such a role, toyour recollection?A. The manager of energy operations, Brett Struck.

Q. Anybody else?A. No.

Q. Has Mr Struck had any experience in the offshorepetroleum industry, to your knowledge?A. I believe he has. I'm not sure of the extent.

Q. Has he ever been on a rig, do you know?A. I am not sure.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2203

Q. Does he have any formal qualifications relating tooffshore drilling or engineering matters?A. I believe he has a degree in engineering.

Q. You wouldn't say that equips him to undertake detailedanalysis of drilling activities, would you?A. No. I didn't say that he did take a detailedanalysis, but he did assist, when Mr Marozzi was away, toprepare the recommendations, and he used expertise from ourformer manager of petroleum operations, who still lives andworks in Darwin.

Q. Would it be fair to say that Mr Struck didn't haveanything like the skills or experience in relation tooffshore drilling matters that Mr Marozzi had, in yourview?A. Yes.

Q. You referred a moment ago to Mr Struck consulting withanother person. Do you recall giving evidence about that?A. Yes.

Q. Does this person work for the Northern TerritoryDepartment of Resources?A. No.

Q. Who does he work for?A. The Power and Water Authority.

Q. That's of the Northern Territory, is it?A. Yes.

Q. What, if any, background or experience or trainingdoes this person have in relation to offshore drillingactivities?A. This person was a former manager, energy operations,and his prime role, when working with the department - heleft the department, from memory, approximately 18 monthsago, and I believe he was with the department forapproximately 15-plus years, and his main focus was welloperations.

Q. What is this person's name?A. Dusan Sajdak.

Q. How would you spell the surname?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2204

A. I'm not sure. I think it is S-A-J-D-A-K.

Q. When this Mr Sajdak was consulted, would he provideinformation as a favour to Mr Struck or someone else, or ona more formal basis than that?A. It was on an informal basis.

Q. Do you think that's a good practice to have developed,Mr Whitfield?A. I think drilling engineers are very difficult to get.Mr Sajdak was very experienced, in our opinion, and heoffered, and his employer was happy for him to assist attimes - and I might add, there were very, very few times wewere in the situation - when Mr Marozzi wasn't available.

Q. You will have seen in recommendations prepared byMr Marozzi an assessment that he provides, which is to theeffect that the application has been assessed and is foundto satisfy the applicable legislative requirements; do yourecall seeing that in the past few days?A. Yes.

Q. Is that a phrase that was included in boilerplate-typefashion in each and every memorandum provided to you byMr Marozzi in relation to an application seeking approval?A. No. In many instances, he would identify theparticular legislation and sometimes the sections of thelegislation he was particularly referring to.

Q. Can you recall which sections of the legislation wouldbe identified by Mr Marozzi?A. That would be subject to the particular approval hewas seeking - seeking my approval on.

Q. Do you yourself have any detailed knowledge orunderstanding of the Petroleum (Submerged Lands)(Management of Well Operations) Regulations?A. I've referred to it occasionally. I don't know it interms of being able to quote numbers or anything like that.

Q. You'd rely on Mr Marozzi in relation to any detailedunderstanding required of those regulations; is that right?A. Yes.

Q. Would Mr Marozzi's assessment ever say more than thephrase we've just spoken about, namely, PTT's or anotheroperator's application has been assessed and is found to

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2205

satisfy the applicable legislative requirements, or perhapsmention what the particular legislative requirements are?A. Yes.

Q. On those occasions, what do you recall his assessmentconsisting of?A. I can't recall an example at this point in time.

Q. Do you think it's likely that Mr Marozzi's assessmentnever extended beyond a sentence or two, as reflected toyou in the memorandums seeking your approval?A. They were never more than a paragraph; perhaps severalsentences, but they weren't extensive.

Q. Were his memorandums to you seeking approval ever morethan two pages, not including annexures?A. Yes.

Q. On those occasions, what would the memorandums detailthat is not detailed in the memorandums we have beenreferring to in the past few days?A. The template or the format of the memorandum would besimilar to the one you've shown me on screen just recently,but the content under each heading may be larger.

Q. If we could turn, please, to NTG.0001.0004.0145 andjust scroll down slightly, do you see there is the heading"Legislation"?A. Yes.

Q. And then the relevant legislative provision isinserted beside that?A. Yes.

Q. Might that be what you were thinking of when yousuggested that Mr Marozzi's assessment would sometimesinclude the relevant legislation?A. Yes.

Q. So is it the case that, on reflection, on mostoccasions Mr Marozzi's assessment just included words tothe effect, "[Insert operator's name] application has beenassessed and is found to have satisfied the applicablelegislative requirements"?A. Could you rephrase that, please?

Q. Is it the case that Mr Marozzi's assessment, as

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2206

provided to you in memorandum of the kind of that we havereferred to seeking your approval, typically only said,"[Insert name of operator here]" - so whether it's PTT orEsso or whoever else might be seeking approval - "theirapplication has been assessed and is found to satisfy theapplicable legislative requirements", full stop, end ofparagraph?A. The majority did.

Q. If we go over the next page to "Recommendation",you'll see that this particular recommendation was simply:

It is recommended that you approve thesuspension of Montara H1-ST1 by signing theattached correspondence.


Q. And is that the recommendation that was typicallygiven by Mr Marozzi?A. Yes.

Q. Can you recall his recommendation ever extendingbeyond a sentence or two?A. No.

Q. Returning back to his assessment, namely, that theapplication had been assessed and was found to satisfy theapplicable legislative requirements, when you approvedapplications, what did you understand that assessment tomean?A. The assessment that I required was that it be assessedagainst the relevant legislation - whether that be the Actor the regulations, any guidelines that were in place, anymanagement plans that were applicable. Often these werecaptured through, in this example, perhaps section 17 ofthat Act, which might require certain plans to be lodged.So the assessment was against the relevant documentationthat it had to be assessed against.

Q. Did you understand that assessment to be referring toall applicable legislative requirements relating to thedrilling activities being considered or only thelegislative requirements applicable to the need forapproval of a certain task; do you understand thedistinction?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2207

A. I understood that, in recommending approval under thatsection that refers to "approval" - and, commonly, it wouldrefer to things that need to be considered on thatapproval - those things would have been considered. Forexample, if there had to be consideration of anenvironmental management plan, consideration would havebeen given to that environmental plan and the proposedaction.

Q. Did you also understand that that would mean that anydata management plan or well construction standards ormanagement framework that was submitted as part of anoperator's well operations management plan had beenconsidered by Mr Marozzi?A. I would have expected it would have been considered.

Q. And in signing the document, did you understand thatMr Marozzi had formed the view that all the material insuch documents was consistent with the application that hadbeen submitted for approval?A. Yes.

Q. You have heard evidence now that that really doesn'tseem to have been the way that Mr Marozzi approached it,haven't you?A. Yes.

Q. Does that cause you, sitting there today, very graveconcern --A. It does.

Q. -- about the basis upon which you have been approvingapplications in the past?A. It does.

Q. Really, I'm not suggesting that it was donedeliberately, but the situation has developed where youhave been operating, in fulfilling your role as delegate,on a completely different understanding from what is reallythe case; that's right, isn't it?A. Yes.

Q. That's not a good situation at all, is it?A. No.

Q. You would agree that your role as delegate is a veryimportant one, wouldn't you?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2208

A. Yes.

Q. Would it be fair to describe your role as delegate asthe person responsible, on behalf of the public, forensuring that all offshore petroleum activities conductedin the area you're responsible for are conducted in a waythat well integrity is likely to be ensured?A. Yes.

Q. And you understand that if that role is not fulfilled,then there can be very grave consequences in terms of riskto human life and the environment, and all sorts of things?A. Yes.

Q. Do you have an understanding that there wasa significant change in the legislative or regulatoryregime in 2004?A. I don't. I didn't start as the director until 2005,so I wasn't aware of a significant change in terms of thephilosophy.

Q. Do you have any understanding of there being a changefrom a regime based on minimum prescriptive requirements toa regime that was intended to encourage greater flexibilityon the part of the operator in ensuring well integrity?A. I understand that there was a movement towards that.

Q. Do you have any awareness or understanding of therevocation of what's called "the specific requirements"?A. Yes.

Q. Did you understand that the flipside of the revocationof the specific requirements was the move towards the WOMPas the central tenet of the new regime?A. Yes.

Q. Did you have an understanding that ensuring companies'WOMPs were appropriate and represented good oilfieldpractice, and then ensuring that the companies actedconsistently with what they had put forward in their WOMPas the way they would do that, was the central tenet of thenew regime?A. Yes.

Q. And the WOMP was the mechanism by which operatorsproffered how they were going to achieve good oilfieldpractice; correct?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2209

A. Yes.

Q. And deal with risks; correct?A. I'm not sure of the risk component.

Q. Do you accept that a crucial aspect of good oilfieldpractice is the avoidance of risks of blowouts?A. Yes.

Q. One of the main features of the well operationsmanagement plan was to identify how those risks were goingto be dealt with and avoided; did you understand that?A. Yes.

Q. And although you mightn't have had a specificunderstanding of the regulatory requirements in relation toa WOMP, you had a general understanding that it needed tosatisfy requirements designed to ensure well integrity andsafety of those offshore platforms; is that right?A. That's right.

Q. Did you have any involvement in directions in relationto an obligation to comply with specific requirements orrevocation of specific requirements, to your knowledge?A. In terms of giving directions to comply with specificrequirements, it was part of the process and the grant ofvarious titles, and I was the signatory.

Q. If the operator could please bring upNTG.0001.0007.0005, and if the operator could scroll down,please. Pausing there, when did you commence with thedepartment, Mr Whitfield?A. With the department or in this position?

Q. In the position you currently occupy.A. September '05.

Q. So you would know who Mr Errington is; is that right?A. Yes.

Q. Tell us if you need to go up or down in relation tothis letter, but are you familiar with the correspondencethat is being displayed on the screen?A. Could we scroll up?

Q. I don't necessarily mean this specific one toMr Jacob, but letters of this kind.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2210

A. Yes.

Q. Did you ever sign a letter of this kind yourself, asdelegate?A. I believe I might have. I'm not sure.

Q. Do you see that the letter purports to, as delegate,direct Coogee Resources, as they then were, to comply withthe specific requirements, if the operator could scrolldown, please?A. Yes, item 3.

Q. And if the operator could go, please, toNTG.0001.0007.0010, do you recognise such a document,Mr Whitfield?A. Yes.

Q. This is a direction that you have issued; correct?A. Yes.

Q. You'll see in the second paragraph that you, in thisinstrument:

... hereby direct - Coogee Resources[predecessor to PTT] ... to comply, inrelation to the operations carried out bythem in the adjacent area, with therequirements set out in the Schedule tothis Direction ...


Q. And you further direct that:

... those requirements are in addition to,and to be read as part of, and wherenecessary, as amending the Directionsentitled "Specific Requirements ...

Which are then defined as the specific requirements; do yousee that?A. Yes.

Q. Then do you see at the bottom of the page in (ii), youfurther direct that:

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2211

... in the interpretation of thisDirection, words and expressions defined inthe Act or the Schedule to this Directionor the Specific Requirements and used inthis Direction shall, unless the contraryintention appears, have in this Directionthe meanings given to them by the Act, theSchedule or the Specific Requirements ...

Do you see that?A. I see the words.

Q. A plain reading of this direction suggests that thereis a schedule to the direction which is different from thespecific requirements; do you agree with that,Mr Whitfield?A. Yes.

Q. That's not the case, is it?A. No.

Q. In fact, there was no schedule to the direction; isthat right?A. That's correct.

Q. And any reference to this formal direction to complywith the schedule to the direction is in error; is thatright?A. Yes. I think the word "or" should have been "of" inthis context.

Q. That's not a good thing in a formal direction given bythe delegate, is it, Mr Whitfield?A. No.

Q. What the direction was, in fact, intended to do wasdirect Coogee Resources to comply with the specificrequirements, which were attached to the direction and thecorrespondence; is that right?A. Yes.

Q. Are you aware that the Inquiry has asked the NorthernTerritory department to tell us what the applicablespecific requirements were that Coogee Resources weredirected to comply with?A. Yes.

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2212

Q. Are you aware that searches of files have been made inan attempt to answer that question?A. Yes.

Q. You would agree that it's a fairly fundamental pointto be able to answer, wouldn't you?A. Yes.

Q. Exactly what the company that is heavily involved inevents we're dealing with here was directed to comply withis not an unimportant issue for this Commission; would youagree with that?A. Yes.

Q. Particularly so when submissions have been received bythe Inquiry to the effect that if the specific requirementshad been complied with by PTT, the blowout never would haveoccurred; do you accept that?A. Yes. I'm not aware of the submission, but I acceptyour statement.

Q. Well, if you assume that for a moment. Are you awarethat the specific requirements impose requirements inrelation to things like notifying the designated authorityin the event of certain matters occurring after cementingof the casing shoe?A. No, I'm not aware of that particular detail.

Q. Do you have any detailed understanding of the specificrequirements?A. I've read certain parts of the specific requirementswhere an issue has arisen that requires me to read them.I'm not aware of that particular section.

Q. It's the case, isn't it, that even now, the departmentcannot tell this Inquiry which specific requirements CoogeeResources was directed to comply with; that's right, isn'tit?A. The specific requirements that they were directed tocomply with were the ones that were in force at that date.

Q. There's no copy on a file anywhere, as I understandit, of what those were from the department's perspective;is that the case?A. Yes.

Q. And it could have been, for example, that the specific

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2213

requirements attached to the correspondence or thedirection were a variant to what was in force at thespecific time; is that right?A. Could you say that again?

Q. The direction purported to direct Coogee Resources tocomply with the attached specific requirements; is thatright?A. Yes.

Q. And it's the case that in correspondence to CoogeeResources and a number of operators prior to this directionbeing given, correspondence was sent saying: "These aspectsof specific requirements are revoked and you no longer haveto comply with them"; is that right?A. Yes.

Q. And it was that formal notification that the companyno longer had to comply with the specific requirements thatrelieved them of the obligation to comply with them; thatwas how it worked, wasn't it?A. With those specific requirements that had beenrevoked.

Q. Yes.A. Yes.

Q. And unless a direction had been given or notificationhad been given to an operator that it no longer had tocomply with aspects of the specific requirements, then theposition was that they still had to do so; is that right?A. All operators were notified when there was a change inspecific requirements.

Q. The relevant provision of the legislation, namelysection 101 of the Petroleum (Submerged Lands) Act 1967,gave the DA a power to issue directions; that's right,isn't it?A. Yes.

Q. And the DA could have issued a direction that anoperator, such as Coogee Resources, comply with clause 504,for example, of the specific requirements, if he wished todo so; correct?A. Yes.

Q. And even though those specific requirements might have

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2214

been revoked, either generally or in the case of someoperators, a direction could still be issued that, in thisparticular case, the operator needed to comply with thatclause of the specific requirements; that's the case, isn'tit?A. Yes.

Q. It's the case that your department can't tell thisInquiry which, if any, of the specific requirements CoogeeResources was directed to comply with in sending thisdirection of 22 March 2007; correct? All you can do isoffer a supposition that it's likely to have been the onesthat were generally not revoked at the time; that's thebest you can do, isn't it?A. I wouldn't have expected them to comply witha specific requirement that had been revoked. Myunderstanding --

Q. But the point is that we don't know what they weredirected to comply with, because there's no record of itanywhere in your department; that's right, isn't it?A. There's no record on PTTEP's file, that's correct.

Q. Well, the fact that they can't tell us, either, isa different point, but the point I'm directing yourattention to, Mr Whitfield, is that your department, whichis responsible for assisting you to fulfil your role asdelegate of the DA, can't tell us which, if any, specificrequirements Coogee Resources was directed to comply withwith any degree of certainty, can it?A. I believe we can.

Q. And you say that just based upon general practice?A. No. I say that because, in my view, the specificrequirements that they were required to adhere to were theones that were in place at the time. If they had beenpreviously revoked, they didn't apply. If they had beenadvised at a later date that specific requirements had beenrevoked, they wouldn't apply.

Q. There was no general revocation of all specificrequirements operating against the world at large, wasthere, Mr Whitfield?A. No.

Q. It was done on a case-by-case basis by notification toindividual operators; that's right, isn't it?

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2215

A. The notification was to individual operators. Therewere some general revocations of a number of specificrequirements.

Q. And how were they effected?A. The specific requirements were --

Q. The general revocation that you spoke of.A. There was revocation of a number of the specificrequirements, and that was general to all operators.

Q. Was that done by publishing something in the Gazetteor how was it done?A. It was done by the Commonwealth Department of RET.They advised the Territory and, I believe, otherjurisdictions, and they asked us to notify all theoperators that the list of specific requirements had beenrevoked.

THE COMMISSIONER: Just pause for a moment, Mr Berger.

Q. This is just a background point, Mr Whitfield: whenI have looked at the specific requirements in otherjurisdictions, it seems, unless I'm mistaken, thatdifferent jurisdictions have taken that guidance from DRETdifferently in terms of what they've revoked and what theyhaven't revoked, and that's why I think I need to geta clear understanding of exactly what your revocationinvolved.A. Can I answer you on that?

Q. Yes, please.A. We didn't revoke any specific requirements. TheCommonwealth Government revoked the specific requirementsand then advised us or asked us to advise the individualoperators which requirements had been revoked.

MR BERGER: Q. Are you sure about that, Mr Whitfield?A. Yes.

Q. The Commonwealth couldn't, by any steps it took,effect a revocation of the specific requirements thatreleased the operators in your jurisdiction from anyrequirement to comply with them, could it - or it didn't?A. Sorry, I probably haven't made myself clear. Thedocument called the "schedule of specific requirements"contained a number of requirements. The Commonwealth

1234567891011121314151617181920212223242526272829303132333435363738394041424344454647


2216

revoked, on two occasions that I know of, various of thoserequirements. They wrote to us and requested us to issueanother direction advising operators of the new specificrequirements. That's my understanding of that sequence.

THE COMMISSIONER: Q. And your belief is that youfollowed what DRET suggested that you do?A. Definitely. I looked at the file several weeks --

Q. Whereas my understanding is that some of the otherjurisdictions might have departed from that, either inspecific instances or in the generality, reflecting theirown approach to offshore petroleum issues. That's notrelevant for your consideration. I'm not making thatpoint, but I'm just trying to go through my thoughtprocesses, because I've had considerable difficulty tryingto understand what the regime was that would apply to theoffshore petroleum industry across Australia.A. And I should say that it's a little bit moredifficult, in that the base schedule of specificrequirements that is on RET's site is not updated to thelatest revocations, so there is another element ofconfusion there.

Q. If you go to the RET site - the last time I looked atit - it draws your attention to the fact that the differentjurisdictions have done things differently, and the onlyplace you can go to, at their instruction, is each specificjurisdiction to find out what happened.A. And that document doesn't reflect the revocations inrespect of well operations.

MR BERGER: I note the time, Commissioner. Is thata suitable time?

THE COMMISSIONER: Yes. Thank you. I'm none the cleareron the point, but maybe you will both be able to clarify itfor me tomorrow. Thank you very much.

AT 4.36PM THE COMMISSION WAS ADJOURNEDTO THURSDAY, 15 APRIL 2010 AT 9.30AM

'

'05 [1] - 2209:36

0

0005 [1] - 2120:400008 [1] - 2120:400019 [1] - 2129:340046 [1] - 2120:470276 [1] - 2104:220280 [1] - 2146:240291 [1] - 2109:18

1

1 [2] - 2082:26,2196:8

10 [20] - 2103:45,2104:33, 2105:26,2105:40, 2106:7,2109:12, 2109:42,2122:38, 2123:21,2123:30, 2124:25,2124:30, 2125:35,2127:47, 2150:34,2150:42, 2151:33,2161:17, 2167:16,2191:10

10.30 [1] - 2096:22101 [1] - 2213:3610:30 [2] - 2096:23,

2117:1511 [2] - 2109:42,

2166:1411.20 [1] - 2115:2711.44am [1] -

2174:42110 [1] - 2148:1012 [2] - 2109:27,

2110:712-1/4 [1] - 2109:1813 [7] - 2103:45,

2105:26, 2105:41,2106:7, 2109:12,2109:43, 2112:15

13-3/8 [36] - 2096:16,2103:29, 2103:41,2104:44, 2106:17,2106:26, 2106:32,2108:44, 2111:11,2122:14, 2122:21,2130:33, 2141:1,2141:9, 2142:6,2142:19, 2142:27,2143:25, 2144:24,2144:30, 2147:7,2147:20, 2156:9,

2158:27, 2158:34,2159:19, 2162:42,2163:11, 2163:18,2163:36, 2164:4,2164:32, 2164:37,2168:45, 2185:23,2185:27

13-3/8" [2] - 2106:23,2108:45

1347 [1] - 2146:3414 [2] - 2082:37,

2134:1614:00 [2] - 2096:23,

2117:1515 [3] - 2155:26,

2189:11, 2216:4115-plus [1] - 2203:41156 [1] - 2145:1916 [2] - 2141:39,

2167:516:00 [1] - 2157:217 [2] - 2167:5,

2206:3718 [2] - 2191:24,

2203:3919 [5] - 2082:39,

2109:27, 2156:35,2156:40, 2165:4

1967 [1] - 2213:361980s [1] - 2133:219:00 [1] - 2157:191B [18] - 2119:6,

2119:14, 2120:18,2127:45, 2130:13,2135:42, 2135:47,2137:3, 2138:34,2138:43, 2139:27,2140:4, 2145:23,2145:45, 2155:47,2158:8, 2162:1,2164:18

2

2 [25] - 2102:31,2102:33, 2102:35,2102:41, 2103:1,2103:4, 2104:43,2105:9, 2105:40,2106:6, 2108:25,2110:1, 2110:11,2111:43, 2112:16,2113:6, 2115:39,2115:45, 2117:13,2134:43, 2152:4,2164:43, 2171:21,2172:13, 2180:5

2.37pm [1] - 2199:1720 [11] - 2099:26,

2121:32, 2144:42,2144:43, 2147:18,2157:34, 2157:43,2158:20, 2158:42,2159:4, 2189:11

2004 [3] - 2177:27,2177:47, 2208:17

2005 [2] - 2196:8,2208:18

2007 [1] - 2214:112009 [37] - 2085:16,

2088:38, 2091:24,2095:19, 2101:20,2101:26, 2102:30,2115:41, 2119:7,2119:15, 2120:25,2141:39, 2144:42,2154:29, 2154:38,2154:43, 2155:19,2155:42, 2155:47,2156:40, 2164:20,2165:5, 2165:16,2165:24, 2165:42,2167:1, 2167:7,2167:37, 2172:28,2173:37, 2174:42,2183:6, 2191:10,2199:13, 2200:6,2200:15

2010 [2] - 2082:37,2216:41

20th [1] - 2165:5210 [2] - 2108:35,

2108:47211 [1] - 2108:3222 [2] - 2148:41,

2214:1124 [9] - 2119:13,

2146:35, 2157:2,2157:15, 2157:35,2158:21, 2158:43,2159:6, 2163:17

244mm [1] - 2165:624th [2] - 2158:11,

2160:2125 [1] - 2144:126 [8] - 2119:13,

2164:20, 2165:16,2165:24, 2167:1,2167:37, 2172:6,2172:28

26(b [1] - 2119:4226(b) [1] - 2119:35269(d [2] - 2146:25,

2146:3027.6 [1] - 2112:1270 [3] - 2106:13,

2108:44, 2109:128 [2] - 2167:16,

2167:17

29 [1] - 2167:34

3

3 [2] - 2139:4,2210:11

3.07pm [1] - 2199:203.40pm [1] - 2195:3730 [2] - 2167:16,

2168:17311mm [1] - 2109:25340mm [6] -

2109:24, 2141:46,2142:6, 2142:12,2168:24, 2170:34

35 [2] - 2149:19,2149:20

38 [1] - 2190:4239 [3] - 2106:8,

2106:36, 2106:38

4

4 [8] - 2120:41,2157:10, 2157:15,2157:34, 2158:10,2158:20, 2158:42,2174:42

4.36PM [1] - 2216:4042 [2] - 2108:42,

2120:4743 [2] - 2108:42,

2148:3344 [4] - 2104:24,

2104:25, 2108:4245 [6] - 2134:17,

2134:21, 2134:32,2134:47, 2135:20,2135:37

46 [2] - 2148:33,2148:39

47 [2] - 2149:19,2149:21

48 [1] - 2149:31

5

5 [1] - 2106:115.24 [1] - 2106:395.26 [2] - 2108:37,

2108:405.29 [2] - 2106:8,

2106:1250 [3] - 2085:24,

2146:3, 2146:7504 [1] - 2213:42508mm [3] -

2141:47, 2142:13,


1

2168:151 [4] - 2082:26,

2085:22, 2085:24,2085:30

52(b [2] - 2130:29,2130:43

53 [2] - 2146:4,2146:7

58 [1] - 2156:559 [3] - 2156:5,

2156:13, 2156:285th [1] - 2195:45

6

6 [4] - 2176:14,2199:13, 2199:42,2199:43

6.06am [1] - 2091:3567 [1] - 2170:668 [1] - 2171:1

7

7 [11] - 2085:16,2091:24, 2095:19,2109:27, 2111:23,2120:25, 2165:42,2167:7, 2172:5,2172:19, 2173:36

8

8 [30] - 2085:25,2085:36, 2085:46,2086:6, 2086:17,2086:25, 2088:38,2091:7, 2091:19,2091:35, 2092:2,2092:3, 2095:24,2097:23, 2097:34,2101:19, 2102:30,2110:6, 2122:38,2123:21, 2123:29,2124:25, 2124:29,2125:35, 2127:47,2130:1, 2150:34,2150:42, 2151:33,2200:6

80 [1] - 2126:9

9

9 [9] - 2093:26,2094:1, 2101:4,2101:16, 2101:20,2101:26, 2112:38,2197:36, 2200:15

9-5/8 [64] - 2092:9,2093:27, 2096:16,2098:3, 2098:11,2104:1, 2104:44,2106:20, 2106:26,2108:34, 2110:7,2110:27, 2110:36,2111:3, 2111:9,2118:17, 2122:12,2122:19, 2123:17,2123:23, 2123:42,2124:45, 2125:2,2125:10, 2125:23,2125:38, 2130:31,2130:32, 2144:32,2145:20, 2145:27,2145:33, 2147:21,2147:24, 2148:11,2149:4, 2149:12,2149:39, 2150:7,2150:30, 2151:7,2156:8, 2157:5,2157:14, 2157:23,2157:24, 2157:32,2157:41, 2158:9,2158:19, 2158:28,2158:41, 2159:3,2159:20, 2159:25,2162:41, 2163:20,2164:8, 2164:32,2165:12, 2167:45,2168:44, 2169:3,2170:35

9.30AM [1] - 2216:419.30am [2] - 2082:37,

2083:1

A

ABBOTT [2] -2093:7, 2195:13

Abbott [1] - 2093:14Abbott) [1] - 2093:8ability [1] - 2137:46able [10] - 2083:45,

2092:37, 2126:30,2126:38, 2126:44,2157:39, 2199:40,2204:39, 2212:6,2216:37

absence [5] -2164:37, 2174:4,2174:5, 2180:36,2202:4

absolutely [5] -2100:44, 2109:43,2128:30, 2131:21,2160:10

accept [36] -2090:38, 2101:25,

2102:4, 2113:4,2114:14, 2114:22,2114:25, 2116:36,2116:43, 2116:45,2118:20, 2118:26,2124:23, 2124:30,2126:17, 2126:20,2129:17, 2129:20,2136:2, 2139:24,2147:31, 2155:39,2169:40, 2169:45,2170:1, 2170:47,2171:28, 2174:17,2176:37, 2177:10,2178:39, 2178:40,2180:12, 2209:6,2212:18, 2212:19

acceptable [3] -2137:5, 2137:21,2174:10

accepted [2] -2136:38, 2140:41

accepting [1] -2178:47

accepts [2] - 2120:4,2120:9

access [1] - 2133:2accessible [1] -

2107:38accompanied [1] -

2201:8accomplished [1] -

2193:13accordance [3] -

2162:20, 2178:19,2181:33

according [7] -2090:4, 2090:7,2102:14, 2103:44,2109:42, 2125:12,2183:15

account [3] -2090:10, 2113:27,2118:34

accurate [2] -2135:20, 2168:14

achieve [1] - 2208:46ACT [1] - 2082:27Act [7] - 2135:21,

2178:8, 2206:34,2206:38, 2211:3,2211:7, 2213:36

act [3] - 2090:23,2132:14, 2180:43

acted [1] - 2208:39acting [4] - 2085:39,

2086:13, 2086:47,2099:43

action [7] - 2089:39,2091:9, 2091:10,

2095:28, 2112:34,2112:38, 2207:8

actions [4] -2089:31, 2117:19,2117:32, 2191:42

activities [25] -2090:18, 2094:40,2095:18, 2095:46,2107:35, 2120:5,2126:2, 2127:26,2160:14, 2174:12,2178:3, 2178:14,2178:18, 2182:38,2187:28, 2187:45,2188:9, 2188:20,2192:14, 2201:44,2202:32, 2203:7,2203:36, 2206:44,2208:5

activity [9] -2088:44, 2088:47,2094:45, 2098:22,2109:37, 2144:8,2144:20, 2185:10,2188:43

add [2] - 2089:17,2204:13

added [1] - 2103:42addition [3] -

2113:10, 2196:43,2210:36

additional [5] -2089:17, 2120:24,2120:29, 2120:35,2151:29

address [1] -2195:45

addressed [1] -2194:23

addressing [1] -2084:11

adds [5] - 2112:12,2115:11, 2130:45,2132:13, 2181:41

adequate [4] -2102:24, 2103:10,2175:13, 2178:33

adequately [6] -2190:19, 2190:24,2190:30, 2194:12,2194:27, 2194:30

adhere [1] - 2214:35adjacent [1] -

2210:27ADJOURNED [1] -

2216:40ADJOURNMENT [2]

- 2115:29, 2152:6adjournment [1] -

2092:45

administration [1] -2196:25

administrative [1] -2196:44

administrative-type[1] - 2196:44

admit [1] - 2184:47adopt [1] - 2128:33advanced [1] -

2150:47advice [5] - 2083:35,

2111:33, 2111:38,2114:19, 2154:26

advise [1] - 2215:35advised [3] -

2214:38, 2215:15,2215:35

adviser [1] - 2174:35advising [3] -

2142:18, 2143:17,2216:3

Advisory [1] -2190:44

advocated [1] -2177:13

affairs [1] - 2124:26affected [1] -

2171:25affirmation [1] -

2083:1afforded [1] -

2083:11afternoon [6] -

2157:15, 2157:35,2158:10, 2158:21,2158:43, 2199:13

ago [9] - 2095:9,2095:43, 2114:27,2161:24, 2171:22,2172:32, 2202:27,2203:20, 2203:40

agree [108] -2087:15, 2094:11,2094:13, 2094:14,2098:23, 2098:24,2098:30, 2098:45,2100:6, 2100:9,2100:11, 2100:14,2100:21, 2103:5,2105:37, 2105:38,2108:21, 2113:15,2114:41, 2114:47,2119:13, 2120:34,2122:15, 2122:22,2122:23, 2124:27,2127:13, 2127:15,2127:19, 2127:20,2127:26, 2127:28,2127:34, 2127:39,2127:41, 2127:43,


2

2128:10, 2128:11,2128:16, 2128:17,2128:27, 2130:25,2130:26, 2134:33,2134:36, 2135:33,2135:34, 2135:38,2135:46, 2138:31,2138:40, 2139:8,2139:15, 2139:17,2139:36, 2140:33,2140:34, 2143:19,2143:20, 2145:5,2149:37, 2150:35,2150:38, 2155:34,2155:45, 2157:13,2157:29, 2165:42,2166:22, 2168:41,2169:12, 2169:19,2171:36, 2171:41,2172:45, 2174:7,2174:8, 2175:45,2175:46, 2176:24,2176:27, 2176:29,2177:27, 2177:45,2178:42, 2179:21,2180:10, 2185:42,2186:4, 2186:16,2186:19, 2187:4,2192:2, 2192:22,2193:3, 2193:21,2193:43, 2193:46,2198:23, 2198:34,2202:1, 2202:7,2202:16, 2202:20,2207:46, 2211:15,2212:5, 2212:12

agreed [18] -2101:36, 2105:43,2106:2, 2113:8,2113:25, 2136:10,2139:13, 2139:19,2139:29, 2153:23,2157:30, 2159:6,2165:45, 2170:3,2173:29, 2181:40,2199:4, 2202:22

agreeing [1] -2197:13

agreement [1] -2083:39

aimed [1] - 2181:3aircraft [3] - 2128:13,

2128:19, 2128:20Alan [3] - 2160:33,

2174:26, 2186:35alarm [3] - 2090:21,

2099:17Allara [1] - 2082:26alleviate [1] -

2091:10

allocate [1] -2194:16

allow [2] - 2180:42,2188:34

allowable [1] -2125:31

allowance [1] -2128:9

almost [2] - 2180:36,2180:44

alternative [5] -2083:16, 2083:34,2087:34, 2150:6,2150:46

alternatives [1] -2087:16

amended [1] -2148:24

amending [1] -2210:38

amount [4] -2121:38, 2132:10,2136:31, 2185:15

amounted [1] -2148:44

analysis [4] -2169:23, 2202:10,2203:7, 2203:9

Andy [3] - 2160:24,2163:16, 2163:27

animosity [3] -2186:22, 2186:25,2186:38

annexures [1] -2205:16

annual [1] - 2144:43annulus [2] -

2087:14, 2087:29answer [17] -

2100:36, 2101:45,2115:34, 2116:14,2116:24, 2138:30,2139:38, 2147:42,2153:14, 2159:2,2171:19, 2177:44,2191:28, 2202:27,2212:2, 2212:6,2215:30

answering [4] -2108:16, 2116:47,2145:43, 2151:12

answers [3] -2100:1, 2116:13,2171:17

ANTHONY [1] -2083:1

anyhow [1] - 2147:9anyway [4] -

2087:23, 2087:33,2096:1, 2188:4

AO [1] - 2082:32apart [2] - 2084:24,

2158:21apparent [2] -

2139:44, 2139:45appear [2] - 2084:20,

2174:29applicable [12] -

2119:21, 2119:29,2135:22, 2204:19,2205:1, 2205:43,2206:6, 2206:30,2206:36, 2206:43,2206:45, 2211:43

applicant [1] -2201:26

application [47] -2102:31, 2102:35,2102:41, 2103:2,2103:4, 2104:43,2105:9, 2115:39,2115:45, 2120:18,2121:24, 2122:1,2123:26, 2124:16,2129:44, 2131:33,2132:18, 2132:23,2133:4, 2133:22,2140:26, 2141:15,2141:21, 2141:25,2155:8, 2155:9,2155:13, 2156:7,2156:15, 2156:17,2156:20, 2170:32,2198:1, 2200:47,2201:24, 2201:25,2201:32, 2201:37,2202:11, 2202:26,2204:18, 2204:25,2204:47, 2205:42,2206:5, 2206:29,2207:19

applications [20] -2128:34, 2154:44,2155:10, 2161:39,2170:33, 2174:12,2184:31, 2184:34,2188:22, 2189:5,2189:6, 2189:38,2190:21, 2190:25,2190:31, 2192:15,2201:44, 2202:30,2206:31, 2207:33

applied [2] - 2111:9,2114:10

apply [3] - 2214:37,2214:39, 2216:17

appointed [1] -2197:11

appreciative [1] -2179:30

approach [15] -2088:36, 2127:17,2136:44, 2139:32,2140:24, 2140:25,2177:6, 2177:13,2185:44, 2186:2,2186:18, 2186:21,2186:45, 2216:13

approached [1] -2207:24

approaches [1] -2140:31

appropriate [4] -2087:3, 2128:38,2139:12, 2208:38

appropriately [1] -2181:33

approval [58] -2103:23, 2110:11,2112:16, 2113:5,2116:8, 2119:6,2127:44, 2130:12,2135:47, 2141:21,2151:9, 2151:13,2151:14, 2151:22,2154:45, 2155:9,2155:41, 2155:46,2156:7, 2156:16,2159:3, 2161:10,2170:33, 2181:21,2188:24, 2190:16,2198:1, 2198:9,2198:29, 2198:30,2198:32, 2198:40,2199:2, 2199:3,2199:10, 2199:12,2199:17, 2199:20,2199:47, 2200:32,2201:1, 2201:5,2201:9, 2201:32,2202:28, 2204:25,2204:32, 2204:33,2205:11, 2205:15,2206:2, 2206:4,2206:46, 2207:1,2207:2, 2207:4,2207:20

approvals [1] -2166:18

approve [13] -2136:27, 2138:3,2177:39, 2187:40,2198:5, 2198:24,2201:9, 2201:24,2201:28, 2201:37,2202:26, 2202:28,2206:13

approved [30] -2096:17, 2102:14,2113:39, 2123:28,

2139:27, 2140:3,2140:8, 2140:13,2143:36, 2143:39,2144:26, 2144:34,2155:14, 2157:41,2158:4, 2158:5,2158:8, 2158:33,2163:47, 2164:18,2168:4, 2178:4,2181:17, 2184:45,2185:37, 2197:42,2200:23, 2202:3,2206:30

approving [3] -2158:14, 2187:37,2207:32

APRIL [1] - 2216:41April [2] - 2082:37,

2141:39area [9] - 2160:14,

2193:26, 2194:29,2196:12, 2196:16,2202:3, 2202:12,2208:6, 2210:27

areas [1] - 2196:33arguably [1] -

2180:40argued [1] - 2171:37argument's [1] -

2110:22arguments [1] -

2185:41arise [3] - 2083:16,

2097:41, 2118:6arisen [5] - 2098:45,

2110:10, 2112:23,2176:26, 2212:32

arising [1] - 2135:31armed [1] - 2165:27arrive [1] - 2182:41arrived [2] - 2181:20,

2181:22as-built [5] -

2160:26, 2163:38,2163:41, 2164:8,2164:30

ascertain [1] -2091:6

Ashmore [1] -2196:13

aside [1] - 2185:41aspect [10] -

2085:19, 2097:15,2118:1, 2136:45,2151:30, 2177:25,2177:46, 2186:3,2186:13, 2209:6

aspects [7] - 2106:5,2181:31, 2201:44,2202:10, 2202:22,


3

2213:13, 2213:30assertion [1] -

2184:26assess [2] - 2190:31,

2201:43assessed [27] -

2102:41, 2104:42,2115:39, 2115:45,2121:23, 2122:31,2123:26, 2124:6,2124:35, 2125:1,2131:7, 2131:27,2131:32, 2132:7,2132:17, 2132:23,2133:4, 2133:21,2141:14, 2184:31,2204:18, 2204:47,2205:43, 2206:5,2206:29, 2206:33,2206:40

assessing [19] -2100:16, 2105:8,2108:25, 2121:47,2124:16, 2128:33,2129:43, 2130:38,2130:42, 2131:16,2137:3, 2141:25,2155:8, 2155:12,2160:13, 2160:43,2174:11, 2189:37,2192:15

assessment [29] -2112:17, 2113:18,2125:14, 2125:24,2137:4, 2138:13,2138:20, 2140:19,2155:15, 2161:31,2170:31, 2188:22,2190:20, 2190:25,2192:2, 2201:36,2202:21, 2204:17,2204:45, 2205:5,2205:9, 2205:36,2205:41, 2205:47,2206:28, 2206:31,2206:33, 2206:39,2206:42

assessments [8] -2119:19, 2119:43,2188:22, 2188:23,2188:24, 2188:25,2201:38

assist [9] - 2134:20,2154:23, 2163:46,2181:6, 2181:10,2181:29, 2187:25,2203:9, 2204:12

assistance [3] -2114:23, 2175:43,2176:25

assisted [2] -2134:44, 2167:31

assisting [9] -2083:9, 2083:47,2084:2, 2084:15,2128:45, 2146:40,2155:18, 2189:22,2214:27

assists [1] - 2202:15assume [28] -

2090:30, 2097:18,2098:6, 2107:18,2108:19, 2132:41,2134:32, 2141:26,2145:10, 2145:42,2145:46, 2146:5,2148:9, 2148:34,2149:2, 2149:6,2149:10, 2156:37,2156:44, 2157:32,2158:3, 2158:26,2158:34, 2160:4,2190:40, 2191:4,2191:12, 2212:22

assumed [2] -2132:36, 2200:41

assumes [1] -2167:36

assuming [5] -2111:8, 2111:10,2111:11, 2158:5,2158:29

assumption [12] -2108:14, 2108:24,2121:42, 2121:44,2121:47, 2123:47,2131:16, 2131:23,2131:25, 2146:2,2149:15, 2188:1

assumptions [2] -2106:46, 2117:4

AT [2] - 2216:40,2216:41

Atlas [1] - 2084:16Atlas/Seadrill's [1] -

2148:35atmosphere [6] -

2127:46, 2128:15,2135:28, 2137:21,2150:32, 2158:26

attached [7] -2163:42, 2175:4,2201:19, 2206:15,2211:38, 2213:1,2213:7

attempt [2] -2175:42, 2212:2

attempting [1] -2176:32

attend [2] - 2084:20,

2085:6attendance [2] -

2195:23, 2196:28attended [1] -

2196:39attention [27] -

2083:17, 2102:5,2102:18, 2102:23,2102:25, 2114:2,2115:6, 2118:22,2122:30, 2124:46,2130:16, 2134:17,2134:24, 2135:12,2141:2, 2145:1,2148:33, 2148:43,2149:38, 2149:43,2151:1, 2185:13,2185:43, 2189:36,2194:28, 2214:26,2216:26

attitude [1] - 2191:45audit [1] - 2166:17audited [1] - 2140:41audits [1] - 2193:14August [27] -

2096:13, 2144:42,2144:43, 2147:18,2148:42, 2156:35,2156:40, 2157:2,2157:15, 2157:34,2157:35, 2157:43,2158:20, 2158:21,2158:42, 2158:43,2159:4, 2159:6,2163:17, 2164:20,2165:5, 2165:16,2165:24, 2167:1,2167:37, 2172:6,2172:28

Australia [8] -2140:24, 2175:27,2175:30, 2177:8,2186:24, 2186:46,2187:15, 2216:18

Australian [11] -2136:6, 2136:11,2136:16, 2136:24,2139:26, 2139:45,2140:8, 2159:44,2173:11, 2173:15,2191:42

author [6] - 2191:12,2191:23, 2191:36,2192:38, 2193:11,2193:33

authorising [1] -2113:46

Authority [1] -2203:29

authority [4] -

2114:24, 2196:12,2198:24, 2212:24

available [6] -2092:36, 2145:40,2166:28, 2169:24,2195:2, 2204:14

average [1] -2188:42

avoidance [1] -2209:7

avoided [1] -2209:12

avoiding [1] -2097:13

aware [48] - 2086:17,2086:18, 2089:11,2090:10, 2097:23,2097:45, 2098:2,2098:6, 2098:11,2099:2, 2099:4,2099:6, 2099:8,2099:14, 2107:23,2107:25, 2107:28,2111:21, 2112:31,2112:33, 2113:31,2117:43, 2125:16,2126:30, 2126:33,2129:6, 2129:10,2129:12, 2129:14,2129:17, 2143:22,2143:30, 2144:30,2144:37, 2144:41,2144:44, 2149:24,2151:22, 2154:24,2169:30, 2169:31,2208:19, 2211:42,2212:1, 2212:19,2212:22, 2212:27,2212:33

awareness [6] -2099:11, 2103:21,2116:29, 2117:37,2169:36, 2208:28

B

background [9] -2086:18, 2095:30,2095:35, 2102:6,2107:3, 2194:35,2194:41, 2203:34,2215:22

backs [2] - 2123:13,2124:2

bad [1] - 2090:38ball [2] - 2091:31,

2093:23barrier [93] -

2088:40, 2091:26,2100:12, 2100:23,

2101:38, 2101:43,2102:36, 2102:43,2103:10, 2103:22,2103:28, 2105:17,2105:27, 2105:47,2111:12, 2111:27,2111:30, 2112:5,2112:7, 2112:9,2112:12, 2112:19,2112:47, 2113:19,2114:1, 2114:28,2114:35, 2114:41,2115:15, 2116:9,2122:32, 2122:37,2123:1, 2123:22,2123:29, 2123:31,2124:36, 2124:42,2125:4, 2125:9,2125:19, 2127:34,2127:37, 2127:39,2127:47, 2128:10,2128:15, 2128:29,2128:46, 2129:2,2129:3, 2129:29,2130:14, 2130:21,2130:46, 2131:1,2131:6, 2131:28,2131:34, 2131:37,2131:41, 2131:45,2132:2, 2132:9,2132:12, 2132:14,2133:23, 2133:39,2134:7, 2134:8,2135:29, 2135:32,2136:26, 2136:34,2137:6, 2137:22,2138:32, 2138:41,2139:10, 2139:16,2140:17, 2143:17,2150:33, 2158:28,2162:30, 2163:1,2165:22, 2165:29,2165:34, 2166:3,2169:16, 2182:11

barriers [24] -2089:41, 2090:11,2091:12, 2091:21,2101:36, 2101:37,2102:15, 2102:37,2103:15, 2105:41,2107:23, 2109:1,2110:28, 2113:11,2125:44, 2128:28,2128:39, 2130:30,2141:32, 2147:44,2148:19, 2162:40,2188:28, 2189:46

base [3] - 2087:1,2182:37, 2216:20

based [26] - 2094:40,2101:30, 2102:35,


4

2105:1, 2105:2,2106:42, 2112:37,2112:42, 2112:46,2117:37, 2119:43,2123:5, 2123:22,2123:36, 2123:39,2123:40, 2123:47,2131:8, 2131:11,2136:28, 2136:37,2136:44, 2178:3,2193:37, 2208:23,2214:33

basic [6] - 2115:21,2170:2, 2171:6,2171:35, 2171:39,2196:41

basis [12] - 2083:7,2090:30, 2094:29,2096:17, 2104:3,2112:17, 2164:5,2167:36, 2204:5,2204:6, 2207:32,2214:46

batch [17] - 2088:15,2088:20, 2088:27,2115:6, 2115:9,2115:20, 2121:19,2121:41, 2126:7,2127:13, 2127:18,2127:23, 2127:30,2184:20, 2187:28,2188:29, 2190:2

bear [1] - 2147:5bearing [3] -

2108:29, 2146:2,2197:36

became [3] -2117:43, 2163:36,2191:5

becomes [2] -2197:1, 2197:3

becoming [1] -2143:30

beg [1] - 2186:10behalf [3] - 2145:12,

2194:18, 2208:4behind [1] - 2157:47belief [2] - 2086:26,

2216:6belittle [1] - 2182:45bells [1] - 2099:18below [3] - 2087:21,

2087:31, 2109:25beneath [4] -

2096:40, 2097:24,2097:36, 2112:29

beneficial [1] -2139:41

BERGER [39] -2085:12, 2085:14,

2088:36, 2093:10,2093:40, 2093:46,2094:38, 2096:20,2099:32, 2100:38,2102:29, 2104:41,2110:43, 2111:41,2114:16, 2115:24,2115:31, 2128:24,2140:47, 2143:17,2148:27, 2148:32,2152:1, 2153:3,2154:33, 2184:40,2187:20, 2190:35,2191:21, 2192:38,2194:22, 2194:32,2195:8, 2195:19,2195:34, 2195:39,2195:41, 2215:38,2216:33

berger [10] - 2083:3,2088:28, 2088:33,2100:34, 2101:35,2104:29, 2115:26,2128:19, 2148:23,2152:3

Berger [4] - 2187:11,2194:10, 2195:17,2215:20

berger's [2] -2100:22, 2110:38

berger) [1] - 2092:47beside [2] - 2184:23,

2205:32best [8] - 2093:40,

2099:39, 2102:22,2118:34, 2134:12,2176:24, 2192:19,2214:14

betray [1] - 2169:41betrayed [1] -

2171:31betrays [3] -

2169:43, 2171:28,2171:39

better [8] - 2110:24,2128:6, 2173:1,2174:18, 2174:19,2177:1, 2177:9,2184:9

between [28] -2084:32, 2096:23,2103:45, 2104:44,2105:16, 2105:26,2105:40, 2106:25,2108:47, 2109:38,2117:14, 2122:38,2126:1, 2127:11,2140:24, 2153:24,2158:18, 2158:33,2158:41, 2185:44,

2186:22, 2186:30,2186:35, 2186:45,2186:46, 2187:17,2188:45, 2190:3

beyond [4] - 2089:1,2091:24, 2205:10,2206:25

BHP [4] - 2098:15,2099:21, 2099:33,2133:1

big [1] - 2129:4bit [25] - 2087:39,

2088:14, 2090:25,2093:36, 2094:32,2102:5, 2102:20,2109:26, 2109:32,2110:20, 2125:40,2128:6, 2142:42,2148:40, 2149:30,2149:31, 2172:47,2176:1, 2184:1,2187:47, 2189:19,2189:25, 2189:33,2190:14, 2216:19

bits [1] - 2176:8blank [1] - 2201:18blow [1] - 2180:42blowing [1] -

2165:31blown [1] - 2124:30blowout [65] -

2088:40, 2091:27,2102:44, 2103:11,2103:16, 2110:29,2112:6, 2112:19,2113:19, 2114:41,2115:16, 2122:7,2126:23, 2126:26,2126:31, 2126:37,2126:39, 2127:6,2127:39, 2128:38,2130:15, 2130:22,2131:29, 2131:35,2133:23, 2135:30,2139:10, 2144:47,2145:14, 2153:6,2153:9, 2153:10,2153:11, 2154:4,2154:38, 2159:31,2162:11, 2162:15,2162:29, 2163:22,2164:14, 2164:22,2164:32, 2165:13,2165:18, 2165:23,2165:29, 2166:3,2169:2, 2169:12,2169:17, 2169:30,2169:37, 2171:23,2177:40, 2180:16,2180:19, 2180:24,

2180:30, 2180:38,2181:4, 2183:35,2190:10, 2190:21,2212:17

blowouts [5] -2129:16, 2129:24,2173:11, 2173:15,2209:7

board [1] - 2145:11boilerplate [1] -

2204:23boilerplate-type [1] -

2204:23bond [3] - 2087:15,

2087:21, 2087:28BOP [2] - 2123:42,

2158:28BOPs [4] - 2124:3,

2125:29, 2125:30,2129:3

BOPs" [1] - 2109:24borne [1] - 2192:35Borthwick [1] -

2082:32botch [1] - 2182:42bother [1] - 2151:11bottom [9] - 2093:35,

2094:8, 2109:47,2138:29, 2146:30,2149:21, 2168:18,2201:14, 2210:45

box [1] - 2117:3Breadmore [1] -

2183:24Brett [1] - 2202:37briefly [1] - 2104:7bring [23] - 2085:21,

2091:40, 2093:40,2095:4, 2104:15,2104:16, 2104:35,2109:46, 2111:41,2114:1, 2124:38,2127:5, 2149:18,2156:3, 2156:28,2158:15, 2163:29,2164:2, 2181:28,2190:37, 2200:10,2201:13, 2209:29

bringing [1] -2146:46

brings [1] - 2097:25broad [1] - 2083:39brought [6] -

2091:43, 2113:28,2113:29, 2163:43,2186:35, 2191:22

Building [1] -2195:46

built [5] - 2160:26,2163:38, 2163:41,

2164:8, 2164:30bump [3] - 2089:46,

2090:14, 2090:20bumped [4] - 2090:3,

2090:8, 2090:24,2099:1

bumping [2] -2098:36, 2098:42

burden [2] - 2176:35,2192:20

business [1] -2084:46

BY [2] - 2085:12,2195:39

bypass [1] - 2158:15

C

calculation [3] -2104:3, 2124:5,2124:14

calculations [2] -2132:24, 2173:47

calculator [2] -2172:25, 2173:45

California [1] -2190:47

Canberra [1] -2082:27

cannot [2] - 2193:36,2212:36

canvass [1] -2084:19

canvassed [1] -2128:32

Cap [3] - 2167:46,2168:1, 2168:24

cap [65] - 2096:16,2103:29, 2103:42,2107:5, 2107:44,2110:8, 2110:28,2111:3, 2122:12,2122:17, 2122:20,2125:3, 2125:10,2125:23, 2125:39,2130:33, 2130:34,2141:10, 2142:6,2142:20, 2142:28,2142:43, 2143:5,2143:12, 2143:15,2143:26, 2144:25,2144:31, 2144:32,2145:27, 2145:33,2148:11, 2149:4,2149:13, 2150:30,2151:7, 2151:35,2156:9, 2157:5,2157:14, 2157:25,2157:33, 2157:42,


5

2158:10, 2158:16,2158:19, 2158:35,2159:4, 2159:21,2159:26, 2162:42,2162:43, 2163:11,2163:21, 2164:5,2164:9, 2164:33,2165:6, 2165:7,2165:12, 2168:44,2168:45, 2171:16,2185:24, 2185:27

Cap) [1] - 2168:1caps [11] - 2102:37,

2107:18, 2108:20,2122:5, 2133:43,2141:46, 2141:47,2142:12, 2142:13,2164:21, 2165:18

captured [1] -2206:37

care [2] - 2132:32,2182:26

career [1] - 2159:32careful [5] - 2089:40,

2098:8, 2098:21,2169:23, 2171:43

carefully [12] -2090:41, 2094:46,2113:4, 2115:33,2117:1, 2118:25,2118:41, 2118:47,2178:47, 2179:9,2181:23, 2189:3

carried [1] - 2210:26Cartier [1] - 2196:13case [55] - 2098:32,

2098:35, 2099:1,2104:37, 2105:45,2107:41, 2107:45,2111:7, 2116:29,2116:40, 2121:31,2121:33, 2122:26,2122:27, 2123:27,2125:33, 2127:37,2129:21, 2130:23,2135:41, 2151:6,2151:25, 2154:42,2155:39, 2157:23,2159:27, 2160:4,2165:41, 2166:6,2172:17, 2173:10,2173:46, 2185:47,2196:46, 2197:41,2198:37, 2198:41,2198:44, 2201:4,2201:10, 2202:17,2202:20, 2205:40,2205:47, 2207:40,2211:19, 2212:35,2212:44, 2213:11,

2214:1, 2214:3,2214:4, 2214:8,2214:46

case-by-case [1] -2214:46

casing [119] -2085:39, 2086:1,2086:3, 2086:8,2086:13, 2086:43,2087:7, 2087:19,2087:38, 2087:42,2087:46, 2088:10,2088:39, 2089:2,2089:6, 2089:8,2089:26, 2089:32,2089:38, 2090:14,2090:19, 2090:47,2091:2, 2091:9,2091:25, 2092:10,2092:25, 2093:27,2095:45, 2096:40,2096:47, 2097:9,2097:41, 2098:3,2098:7, 2098:11,2098:16, 2100:7,2100:11, 2100:22,2101:18, 2101:43,2102:36, 2102:42,2103:9, 2106:13,2107:38, 2107:43,2109:24, 2110:9,2110:10, 2110:27,2111:2, 2111:47,2112:18, 2112:22,2112:29, 2114:29,2115:42, 2115:47,2116:30, 2116:37,2117:29, 2117:38,2118:11, 2118:16,2118:17, 2118:25,2121:11, 2122:14,2122:21, 2123:31,2124:37, 2124:42,2124:44, 2125:8,2125:22, 2125:34,2125:35, 2129:7,2129:11, 2129:15,2129:28, 2129:37,2130:14, 2130:21,2130:24, 2130:31,2133:39, 2134:1,2134:7, 2135:29,2135:31, 2136:19,2139:9, 2139:11,2147:7, 2148:20,2150:33, 2157:23,2157:28, 2157:29,2158:11, 2158:14,2159:5, 2159:7,2162:41, 2162:47,2163:2, 2165:23,

2165:33, 2167:9,2167:22, 2167:24,2169:3, 2182:9,2212:26

casings [1] -2121:14

catch [1] - 2195:27cause(s [1] -

2166:29caused [4] -

2095:11, 2169:30,2171:23, 2181:4

causes [2] - 2129:16,2169:36

cc'd [1] - 2174:43CE [1] - 2197:13ceased [1] - 2084:20cement [78] -

2085:30, 2085:35,2085:38, 2086:1,2086:8, 2086:10,2086:14, 2086:22,2086:26, 2086:43,2086:47, 2087:7,2087:15, 2087:19,2087:20, 2087:28,2087:29, 2087:41,2087:45, 2088:10,2088:12, 2089:17,2089:23, 2089:44,2089:45, 2090:1,2090:3, 2090:7,2090:8, 2090:28,2090:31, 2090:38,2090:39, 2091:37,2094:22, 2095:26,2095:31, 2095:34,2095:36, 2096:15,2096:46, 2097:4,2097:9, 2097:10,2097:14, 2097:15,2097:20, 2097:25,2097:30, 2097:35,2097:46, 2098:27,2098:31, 2098:41,2099:15, 2100:31,2101:43, 2102:26,2106:16, 2106:43,2106:47, 2107:4,2107:8, 2107:19,2107:41, 2107:45,2107:47, 2108:5,2108:10, 2108:11,2108:19, 2110:24,2110:36, 2114:46,2115:17, 2130:32,2171:15

cementation [1] -2136:19

cemented [25] -

2089:32, 2110:8,2110:27, 2111:2,2114:29, 2124:37,2124:42, 2125:8,2125:21, 2125:34,2125:35, 2129:28,2130:14, 2130:21,2134:7, 2135:28,2139:9, 2139:11,2148:20, 2150:33,2159:7, 2162:41,2162:47, 2165:33,2182:9

cementing [19] -2088:39, 2089:26,2090:13, 2092:9,2096:47, 2097:9,2097:41, 2101:18,2110:10, 2112:23,2129:7, 2129:11,2129:15, 2129:36,2130:24, 2135:31,2165:47, 2173:40,2212:25

cent [2] - 2121:32,2126:9

central [3] - 2177:46,2208:34, 2208:41

Centre [1] - 2191:11Centrepoint [1] -

2195:45CEO [1] - 2197:11certain [11] - 2085:9,

2132:10, 2143:12,2166:35, 2166:45,2192:14, 2206:38,2206:46, 2212:25,2212:31

certainly [8] -2084:37, 2100:27,2107:41, 2128:47,2139:15, 2155:17,2172:47, 2177:17

certainty [1] -2214:30

certificate [2] -2196:22, 2196:24

certificates [1] -2120:31

cetera [3] - 2114:1,2160:29, 2160:37

chain [1] - 2184:5challenges [1] -

2097:46chance [1] - 2155:24chances [1] -

2128:21change [47] - 2083:7,

2110:34, 2115:21,2115:22, 2125:40,

2132:12, 2145:21,2145:23, 2146:26,2146:27, 2147:36,2147:37, 2149:40,2149:41, 2150:1,2150:13, 2150:15,2150:16, 2150:35,2150:36, 2150:42,2151:10, 2151:13,2151:15, 2151:19,2151:23, 2151:24,2151:28, 2151:41,2151:43, 2158:44,2159:11, 2164:16,2164:17, 2164:39,2171:15, 2183:12,2187:41, 2189:21,2196:46, 2197:9,2197:13, 2208:16,2208:19, 2208:22,2213:32

changed [7] -2088:22, 2099:35,2182:19, 2182:22,2183:21, 2183:27,2183:28

changes [2] -2181:37, 2197:17

changing [1] -2159:16

channels [1] -2097:19

chase [1] - 2158:18chasing [1] -

2154:13chat [3] - 2110:14,

2153:44, 2154:39chats [1] - 2153:25check [7] - 2085:33,

2111:22, 2148:28,2160:44, 2164:38,2187:45, 2199:40

Checked [1] -2092:24

checked [3] -2124:18, 2199:25,2199:45

Chief [3] - 2190:43,2191:5, 2191:7

choice [1] - 2194:17choose [1] - 2194:16chop [1] - 2196:46Chris [7] - 2091:29,

2094:20, 2095:37,2109:41, 2110:14,2110:31, 2146:5

circulation [5] -2133:28, 2133:38,2133:43, 2134:2,2134:10


6

circumstance [2] -2112:15, 2197:4

circumstances [11] -2089:39, 2090:16,2098:20, 2103:27,2140:18, 2151:37,2168:47, 2173:20,2182:24, 2182:28,2199:6

clarification [2] -2191:16, 2196:32

clarify [2] - 2085:20,2216:37

classes [1] - 2196:41clause [2] - 2213:42,

2214:4clean [2] - 2159:19,

2159:20cleaned [1] -

2159:27clear [14] - 2089:43,

2093:31, 2104:41,2109:47, 2121:18,2122:11, 2122:40,2133:31, 2133:36,2163:36, 2165:12,2172:32, 2215:28,2215:45

clearer [1] - 2216:36clearly [2] - 2135:6,

2141:9clock [2] - 2106:18,

2106:33close [3] - 2084:46,

2192:26, 2192:28closely [3] - 2127:24,

2173:4, 2190:12closer [3] - 2151:3,

2169:43, 2189:36closest [1] - 2150:20clouded [1] - 2102:5collar [5] - 2096:36,

2096:45, 2097:3,2097:24, 2097:36

collecting [2] -2161:32, 2161:35

colour [1] - 2181:41column [9] -

2130:32, 2130:44,2130:45, 2131:5,2131:19, 2131:33,2132:8, 2132:13,2141:43

combination [3] -2098:20, 2101:19,2193:14

comfort [11] -2093:26, 2093:32,2101:10, 2101:21,2101:25, 2101:26,

2101:30, 2110:21,2132:28, 2132:35,2133:8

comfortable [4] -2091:31, 2103:16,2132:39, 2133:17

coming [2] - 2096:7,2104:31

command [1] -2184:5

commence [2] -2144:7, 2209:31

commences [2] -2109:26, 2123:16

commencing [1] -2104:27

commend [1] -2084:40

comment [37] -2095:2, 2097:38,2103:12, 2108:22,2111:5, 2119:47,2120:13, 2121:34,2127:35, 2128:1,2133:25, 2135:44,2139:34, 2140:44,2151:46, 2159:35,2159:36, 2159:45,2166:24, 2169:20,2171:8, 2172:7,2173:7, 2173:38,2173:41, 2174:20,2180:11, 2180:46,2182:30, 2184:38,2190:23, 2190:36,2192:21, 2193:9,2193:33, 2193:44,2194:32

commenting [1] -2191:24

comments [17] -2094:10, 2141:43,2145:4, 2155:34,2174:36, 2175:4,2175:21, 2176:30,2179:29, 2179:33,2179:37, 2179:41,2180:5, 2182:26,2190:39, 2191:5,2192:35

comments" [1] -2186:28

COMMISSION [2] -2082:20, 2216:40

Commission [5] -2084:27, 2113:30,2157:40, 2171:21,2212:11

Commission's [1] -2191:41

COMMISSIONER[37] - 2084:24,2088:24, 2088:32,2093:43, 2094:20,2094:36, 2096:5,2099:28, 2100:19,2100:34, 2101:34,2104:27, 2110:38,2111:7, 2113:27,2115:26, 2128:19,2140:36, 2143:10,2148:23, 2148:30,2152:3, 2154:31,2184:13, 2186:43,2187:14, 2190:29,2191:16, 2192:26,2194:10, 2194:26,2195:16, 2195:21,2195:30, 2215:20,2216:6, 2216:36

Commissioner [36] -2082:32, 2083:3,2083:6, 2083:14,2083:19, 2083:23,2083:26, 2083:30,2083:44, 2084:4,2084:13, 2084:39,2085:5, 2099:24,2105:8, 2115:24,2118:29, 2128:24,2132:6, 2148:27,2150:40, 2152:1,2154:23, 2154:34,2160:18, 2171:10,2177:17, 2181:25,2187:24, 2194:22,2195:11, 2195:14,2195:19, 2195:35,2196:20, 2216:33

Commissioner's [2]

- 2083:24, 2084:7common [1] -

2099:29commonly [1] -

2207:2Commonwealth [4] -

2215:14, 2215:34,2215:41, 2215:47

communicating [1] -2160:33

communication [2] -2154:47, 2160:37

communications [2]

- 2155:2, 2155:12companies [1] -

2208:39companies' [1] -

2208:37company [12] -

2138:11, 2151:21,

2180:15, 2180:20,2180:25, 2180:31,2181:2, 2182:16,2183:28, 2183:37,2212:9, 2213:18

company's [2] -2178:36, 2184:2

compare [1] -2192:17

competence [1] -2173:27

competency [2] -2089:22, 2090:31

competent [2] -2092:21, 2101:38

complete [3] -2085:3, 2167:12,2175:14

completed [3] -2084:46, 2122:14,2122:21

completely [3] -2170:47, 2183:37,2207:39

completing [2] -2156:9, 2170:26

Completion [1] -2168:5

complexity [1] -2115:11

compliance [24] -2102:24, 2113:14,2114:5, 2143:35,2143:36, 2143:39,2155:13, 2173:40,2177:46, 2179:15,2184:40, 2184:42,2185:1, 2185:5,2185:15, 2185:17,2189:23, 2189:25,2189:31, 2190:26,2192:32, 2194:34,2194:37, 2194:45

complied [5] -2162:25, 2180:20,2180:25, 2184:33,2212:17

complimentary [1] -2182:27

comply [25] -2113:23, 2180:38,2184:14, 2209:23,2209:25, 2210:8,2210:25, 2211:26,2211:37, 2211:45,2212:10, 2212:37,2212:40, 2213:7,2213:15, 2213:19,2213:20, 2213:30,2213:42, 2214:3,

2214:10, 2214:15,2214:20, 2214:29,2215:44

complying [6] -2111:19, 2155:19,2174:6, 2178:8,2184:44, 2185:37

component [2] -2129:29, 2209:4

compounded [3] -2117:20, 2117:28,2166:1

comprehend [1] -2173:36

compromised [2] -2097:20, 2097:26

conceded [2] -2114:12, 2118:10

concedes [1] -2147:43

concern [7] - 2091:2,2091:8, 2091:28,2095:26, 2173:9,2173:26, 2207:29

concerned [3] -2084:44, 2102:20,2125:30

concerns [10] -2089:5, 2089:14,2089:26, 2089:32,2089:34, 2089:37,2090:46, 2091:10,2105:46, 2177:29

conclude [3] -2167:21, 2168:3,2168:22

concluded [1] -2083:22

concludes [1] -2193:33

conclusion [4] -2083:8, 2140:23,2170:7, 2175:12

conclusions [1] -2191:41

concrete [1] -2167:24

conduct [6] -2087:37, 2088:12,2089:38, 2162:19,2181:13, 2192:14

conducted [10] -2085:34, 2085:47,2098:27, 2137:4,2157:24, 2158:12,2178:4, 2181:32,2208:5, 2208:6

conducting [6] -2098:30, 2098:40,2127:26, 2138:12,


7

2178:18, 2180:32conductors [3] -

2141:47, 2142:13,2147:6

conference [2] -2085:37, 2085:44

configuration [1] -2168:25

confirm [1] - 2086:45confirmed [3] -

2139:12, 2166:18,2169:16

confronting [2] -2102:16, 2111:37

confusion [1] -2216:23

conscious [2] -2084:26, 2116:29

consensus [1] -2083:39

consent [1] -2084:14

consequence [7] -2105:37, 2127:46,2150:1, 2150:10,2150:16, 2150:21,2150:35

consequences [1] -2208:11

conservatively [1] -2109:31

consider [18] -2083:34, 2105:31,2105:36, 2110:24,2113:5, 2131:44,2135:19, 2138:9,2139:15, 2145:22,2150:8, 2150:15,2151:6, 2173:30,2173:34, 2179:9,2180:31, 2200:42

considerable [1] -2216:16

consideration [11] -2083:5, 2083:16,2083:20, 2084:37,2084:41, 2124:39,2126:10, 2134:11,2207:5, 2207:6,2216:14

considered [22] -2083:13, 2100:36,2112:5, 2112:18,2119:20, 2131:6,2146:20, 2146:26,2172:33, 2172:40,2173:21, 2178:47,2180:29, 2183:27,2198:32, 2198:37,2201:42, 2206:44,

2207:3, 2207:4,2207:14, 2207:15

considering [6] -2103:4, 2119:28,2121:39, 2127:18,2181:26, 2184:2

consistency [2] -2139:35, 2139:39

consistent [7] -2135:22, 2135:42,2158:3, 2185:14,2198:18, 2198:22,2207:19

consistently [3] -2158:35, 2158:36,2208:40

consisting [1] -2205:6

consists [1] -2196:31

constitute [2] -2133:22, 2180:5

constituted [3] -2119:46, 2151:19,2151:42

constitutes [5] -2120:11, 2143:4,2143:35, 2180:38,2192:18

constituting [1] -2201:31

construction [15] -2111:19, 2111:22,2111:25, 2111:28,2145:21, 2162:4,2162:21, 2177:37,2178:46, 2179:15,2179:16, 2180:21,2181:36, 2189:37,2207:11

constructive [1] -2176:29

consult [1] - 2200:37consultation [1] -

2160:35consulted [3] -

2199:4, 2200:30,2204:3

consulting [1] -2203:20

contacted [2] -2147:38, 2160:24

contain [1] - 2179:9contained [8] -

2092:14, 2128:4,2134:32, 2156:19,2177:45, 2178:19,2200:34, 2215:47

containing [54] -2102:37, 2103:29,

2103:42, 2107:18,2108:19, 2110:8,2110:28, 2111:3,2122:5, 2122:12,2122:19, 2125:3,2125:10, 2125:23,2125:39, 2130:33,2130:34, 2141:10,2142:6, 2142:19,2142:27, 2143:25,2144:25, 2144:31,2144:32, 2145:27,2145:33, 2149:4,2149:12, 2150:30,2151:7, 2156:8,2157:33, 2157:42,2158:9, 2158:19,2158:35, 2159:4,2159:21, 2159:26,2162:42, 2162:43,2163:11, 2163:21,2164:4, 2164:9,2164:21, 2164:33,2165:12, 2165:17,2168:44, 2168:45,2185:23, 2185:27

Containing [2] -2167:46, 2168:24

contaminate [1] -2097:30

contaminated [1] -2086:11

contamination [2] -2097:14, 2097:35

contemplated [1] -2083:7

content [9] -2095:37, 2095:38,2110:26, 2110:30,2111:2, 2111:9,2116:8, 2116:11,2205:24

contents [1] -2176:15

context [6] -2084:12, 2094:40,2096:6, 2102:11,2158:47, 2211:30

continue [14] -2084:20, 2089:7,2091:21, 2096:3,2108:42, 2109:13,2122:45, 2144:20,2148:39, 2161:7,2174:39, 2175:35,2189:33, 2195:24

continued [1] -2091:23

continues [3] -2137:36, 2167:43,

2193:11continuing [1] -

2087:9CONTINUING [1] -

2085:12contrary [6] -

2083:25, 2142:29,2143:23, 2143:24,2144:25, 2211:5

contrast [1] -2163:47

contributed [1] -2183:34

contributing [4] -2167:25, 2168:6,2168:27, 2169:12

control [4] - 2128:38,2151:23, 2161:9,2171:35

controlled [1] -2144:21

controlled] [1] -2144:15

convenient [2] -2115:24, 2152:1

conventional [9] -2087:6, 2087:18,2088:9, 2088:15,2088:16, 2088:17,2088:18, 2088:29

conventional" [1] -2088:21

conversation [2] -2110:45, 2200:43

convinced [1] -2164:36

Coogee [10] -2210:8, 2210:24,2211:37, 2211:44,2212:36, 2213:6,2213:11, 2213:42,2214:9, 2214:29

copy [4] - 2139:21,2163:38, 2164:10,2212:42

cordial [1] - 2186:29corners [2] -

2118:20, 2165:46correct [85] -

2085:43, 2095:20,2096:47, 2097:5,2100:4, 2101:2,2101:23, 2102:38,2102:39, 2105:34,2106:43, 2109:2,2109:43, 2111:39,2112:19, 2112:20,2112:24, 2112:43,2112:44, 2113:2,2113:21, 2114:20,

2114:43, 2115:22,2116:21, 2116:41,2117:45, 2117:46,2118:42, 2118:45,2123:33, 2128:35,2129:40, 2133:29,2135:16, 2135:17,2135:38, 2135:39,2138:21, 2138:27,2138:44, 2146:41,2148:6, 2148:7,2153:45, 2154:17,2154:40, 2155:42,2155:43, 2156:1,2165:19, 2166:22,2167:40, 2167:41,2169:38, 2171:4,2171:26, 2172:11,2172:24, 2173:17,2173:18, 2173:24,2177:24, 2178:11,2178:15, 2179:11,2193:27, 2194:42,2195:43, 2195:47,2196:1, 2196:17,2197:19, 2197:42,2197:43, 2198:42,2208:47, 2209:3,2210:18, 2211:24,2213:44, 2214:11,2214:22

correctly [2] -2087:36, 2120:2

correspondence [8]

- 2154:46, 2201:26,2206:15, 2209:42,2211:39, 2213:1,2213:11, 2213:13

Corrosion [3] -2167:46, 2168:1,2168:24

corrosion [58] -2102:37, 2103:29,2103:42, 2107:18,2108:20, 2110:8,2110:28, 2111:3,2122:5, 2122:12,2122:20, 2125:3,2125:10, 2125:23,2125:39, 2130:33,2130:34, 2141:10,2141:46, 2142:6,2142:12, 2142:20,2142:28, 2143:26,2144:25, 2144:31,2144:32, 2145:33,2149:4, 2149:12,2150:30, 2151:7,2156:8, 2157:5,2157:14, 2157:24,2157:33, 2157:42,


8

2158:10, 2158:19,2159:4, 2159:21,2159:26, 2162:42,2162:43, 2163:11,2163:21, 2164:5,2164:9, 2164:21,2164:33, 2165:7,2165:12, 2165:18,2168:44, 2168:45,2185:24, 2185:27

cosmetics [1] -2180:6

cost [1] - 2183:38counsel [4] - 2083:8,

2083:47, 2084:2,2084:15

counterpart [1] -2191:17

couple [6] - 2169:22,2174:3, 2188:21,2197:5, 2197:24,2200:7

course [18] -2083:25, 2083:46,2084:14, 2085:37,2095:10, 2095:28,2125:16, 2154:29,2154:37, 2154:43,2155:8, 2155:12,2155:19, 2161:35,2161:45, 2168:26,2200:7

courses [2] -2196:40, 2196:44

courtesy [2] -2153:25, 2154:38

covered [1] -2161:45

cracks [1] - 2185:28Craig [3] - 2109:41,

2110:31, 2146:36crane [1] - 2107:27created [2] -

2103:21, 2117:20crew [2] - 2090:35crisis [1] - 2176:26criteria [1] - 2176:38critical [2] - 2087:32,

2088:43criticism [1] - 2104:9cross [1] - 2085:2cross-examination

[1] - 2085:2crossed [1] -

2200:19crucial [9] - 2177:25,

2177:32, 2177:33,2186:3, 2186:5,2186:8, 2186:13,2186:18, 2209:6

crucial" [1] -2177:36

crude [1] - 2126:6culture [1] - 2183:38Cup [1] - 2161:19current [3] -

2188:10, 2188:11,2192:24

cut [1] - 2176:17cuts [1] - 2084:33cutting [2] - 2158:18,

2183:38

D

DA [12] - 2111:33,2111:36, 2140:42,2143:31, 2151:45,2171:40, 2178:39,2179:21, 2193:46,2213:37, 2213:41,2214:28

daily [45] - 2085:15,2086:7, 2088:37,2094:21, 2094:30,2094:32, 2094:39,2094:47, 2095:4,2095:14, 2095:18,2096:21, 2096:44,2098:26, 2100:6,2101:17, 2102:30,2115:32, 2117:9,2118:21, 2118:30,2118:40, 2119:2,2130:2, 2141:38,2142:29, 2142:33,2143:3, 2143:25,2154:45, 2154:46,2161:36, 2165:41,2167:7, 2172:4,2172:19, 2172:21,2173:36, 2187:44,2188:4, 2188:8,2188:19, 2188:27,2188:36, 2188:41

damning [2] -2168:36, 2172:44

Danenberger [1] -2190:37

danger [2] - 2127:10,2185:35

dangerous [1] -2108:14

Darwin [9] - 2153:6,2154:13, 2154:26,2195:46, 2199:27,2199:30, 2199:42,2199:43, 2203:12

data [11] - 2129:20,2131:14, 2132:46,

2132:47, 2133:2,2171:43, 2187:38,2202:21, 2207:11

date [2] - 2212:40,2214:38

dated [1] - 2167:37David [4] - 2082:32,

2174:27, 2174:34,2174:42

dawn [1] - 2116:11dawned [1] -

2116:25days [42] - 2102:3,

2102:29, 2103:20,2103:45, 2104:33,2104:46, 2105:16,2105:26, 2105:40,2105:41, 2106:6,2106:7, 2109:8,2109:12, 2109:27,2109:33, 2109:34,2109:35, 2109:43,2110:7, 2110:19,2110:29, 2110:33,2110:46, 2110:47,2111:4, 2113:1,2114:46, 2125:22,2145:44, 2146:47,2150:31, 2150:34,2150:41, 2151:8,2151:31, 2174:4,2200:7, 2204:20,2205:21

DDR [9] - 2095:32,2130:9, 2130:17,2142:19, 2155:22,2169:35, 2169:43,2187:29

DDRs [1] - 2190:26deadline [1] -

2084:26deal [3] - 2147:11,

2183:18, 2209:3dealing [15] -

2085:19, 2094:4,2095:7, 2103:1,2108:18, 2119:14,2120:17, 2121:14,2126:7, 2127:13,2127:22, 2127:30,2128:29, 2156:6,2212:10

dealings [3] -2146:15, 2146:40,2148:6

dealt [2] - 2183:46,2209:12

debumped [1] -2099:2

December [1] -

2197:24decide [1] - 2115:34decision [4] -

2147:21, 2147:22,2170:33, 2178:39

declaration [8] -2146:19, 2170:13,2170:18, 2170:21,2170:26, 2170:30,2170:38, 2171:12

deep [1] - 2186:38deep-seated [1] -

2186:38define [1] - 2185:18defined [2] -

2210:41, 2211:2definitely [3] -

2150:21, 2199:36,2216:8

definition [3] -2165:33, 2180:36,2180:44

degree [3] - 2124:30,2203:4, 2214:30

delay [1] - 2113:44delays [1] - 2125:37delegate [32] -

2111:33, 2111:36,2114:19, 2114:24,2120:17, 2128:45,2146:40, 2155:18,2187:26, 2189:22,2196:11, 2196:47,2197:2, 2197:4,2197:6, 2197:17,2197:21, 2197:32,2197:38, 2197:44,2198:1, 2198:4,2198:44, 2199:9,2202:16, 2207:38,2207:46, 2208:3,2210:4, 2210:7,2211:33, 2214:28

delegates [1] -2197:9

delegation [1] -2197:10

delete [1] - 2085:29deliberate [1] -

2143:2deliberately [2] -

2171:2, 2207:37demonstrate [1] -

2090:37departed [1] -

2216:11Department [16] -

2136:6, 2136:12,2136:17, 2137:12,2139:1, 2153:5,

2155:25, 2155:35,2159:39, 2160:34,2190:18, 2190:41,2191:39, 2196:5,2203:25, 2215:14

department [36] -2092:37, 2137:16,2160:9, 2160:19,2160:31, 2172:45,2184:10, 2189:17,2189:30, 2193:7,2193:24, 2194:12,2194:15, 2194:27,2194:29, 2194:41,2194:44, 2197:12,2198:20, 2199:40,2201:7, 2201:42,2201:45, 2202:8,2202:13, 2202:15,2203:38, 2203:39,2203:40, 2209:32,2209:33, 2211:43,2212:35, 2214:8,2214:21, 2214:26

department's [1] -2212:43

departure [1] -2168:4

depended [1] -2156:19

depicted [2] -2141:27, 2141:33

depicting [1] -2141:31

derrick [10] -2121:31, 2121:37,2121:43, 2124:35,2126:8, 2126:14,2127:1, 2127:5,2127:31, 2157:9

describe [1] - 2208:3described [2] -

2129:2, 2158:13describing [1] -

2092:9deserve [1] -

2184:24designated [3] -

2114:24, 2196:11,2212:24

designed [2] -2096:45, 2209:18

detail [9] - 2102:5,2118:36, 2176:21,2176:22, 2176:36,2177:1, 2181:42,2205:19, 2212:27

detailed [9] -2102:18, 2177:6,2177:8, 2203:6,


9

2203:8, 2204:35,2204:41, 2205:20,2212:29

determine [6] -2086:38, 2087:28,2188:8, 2188:19,2188:28, 2199:42

develop [1] - 2184:8developed [5] -

2198:9, 2198:19,2200:35, 2204:8,2207:37

development [4] -2093:18, 2126:22,2131:9, 2182:40

deviation [1] -2148:44

diagram [14] -2111:43, 2141:6,2141:9, 2141:15,2141:17, 2141:20,2141:27, 2141:31,2141:33, 2143:24,2163:41, 2164:4,2164:8, 2164:30

diagrams [2] -2161:44, 2163:38

diary [4] - 2154:27,2199:25, 2199:45,2200:2

differ [2] - 2108:31,2125:24

difference [8] -2105:40, 2148:12,2158:18, 2158:22,2158:33, 2158:40,2159:22, 2186:21

different [25] -2097:46, 2127:2,2136:45, 2139:32,2140:24, 2140:31,2151:31, 2171:14,2172:36, 2183:38,2183:40, 2185:44,2186:2, 2186:17,2186:45, 2195:3,2196:39, 2207:39,2211:14, 2214:25,2215:25, 2216:26

differently [3] -2189:41, 2215:26,2216:27

difficult [3] -2088:14, 2204:10,2216:20

difficulty [2] -2166:7, 2216:16

dig [1] - 2095:12diligently [1] -

2114:11

diploma [1] -2196:24

direct [11] - 2094:14,2134:16, 2148:32,2170:42, 2177:43,2210:8, 2210:24,2210:34, 2210:46,2211:37, 2213:6

directed [17] -2090:45, 2090:47,2118:22, 2139:43,2148:43, 2149:38,2149:42, 2149:47,2150:47, 2185:43,2211:45, 2212:10,2212:37, 2212:39,2214:10, 2214:20,2214:29

directing [5] -2122:30, 2134:24,2141:2, 2158:32,2214:25

direction [23] -2083:6, 2210:18,2210:29, 2211:2,2211:3, 2211:5,2211:6, 2211:13,2211:14, 2211:22,2211:26, 2211:27,2211:32, 2211:36,2211:38, 2213:2,2213:6, 2213:12,2213:28, 2213:41,2214:2, 2214:11,2216:3

directions [4] -2209:22, 2209:25,2210:38, 2213:37

directly [8] -2086:23, 2097:44,2160:15, 2160:34,2161:31, 2167:47,2186:34, 2187:34

Director [4] - 2196:3,2197:10, 2197:11,2197:16

director [1] -2208:18

disagree [3] -2115:17, 2115:18,2192:29

disagreed [2] -2135:6, 2135:11

disagreement [4] -2155:31, 2166:39,2166:41, 2186:43

disasters [1] -2159:44

discerned [1] -2108:30

disclose [1] -2166:29

discovery [3] -2141:1, 2148:41,2148:44

discuss [5] -2085:15, 2175:38,2198:10, 2198:11

discussed [4] -2153:31, 2153:42,2153:45, 2200:41

discussing [2] -2101:9, 2198:25

discussion [6] -2110:32, 2125:41,2189:23, 2199:28,2199:37

discussions [4] -2154:11, 2154:16,2154:37, 2199:46

disparaging [1] -2182:27

displace [1] -2090:27

displayed [1] -2209:43

disservice [1] -2114:22

distinct [1] - 2104:36distinction [4] -

2126:1, 2126:6,2127:11, 2206:47

distinguish [1] -2117:1

District [1] - 2190:45Division [2] - 2191:6,

2196:4DMP.9001.0001.

0001 [2] - 2136:4,2136:22

DMP.9001.0002.0001 [1] - 2136:15

document [45] -2092:47, 2093:4,2093:14, 2095:6,2095:8, 2103:8,2104:15, 2104:17,2104:28, 2104:36,2118:25, 2129:34,2134:23, 2134:28,2134:33, 2139:4,2146:4, 2146:25,2155:29, 2156:29,2157:44, 2157:45,2158:3, 2165:46,2174:23, 2177:37,2178:23, 2179:47,2180:29, 2181:35,2182:21, 2184:6,2191:21, 2197:12,

2197:13, 2197:43,2200:11, 2200:35,2200:40, 2201:28,2201:29, 2207:17,2210:14, 2215:46,2216:30

Document [1] -2093:7

documentation [4] -2166:17, 2181:26,2187:21, 2206:39

documented [1] -2104:9

documents [13] -2104:30, 2121:18,2130:8, 2140:40,2160:42, 2172:33,2178:32, 2178:46,2179:9, 2187:38,2190:38, 2199:12,2207:19

DOMINIC [1] -2083:1

done [33] - 2100:43,2109:36, 2113:15,2114:11, 2124:17,2142:34, 2142:35,2142:37, 2143:37,2147:31, 2151:25,2161:27, 2166:1,2173:1, 2173:31,2174:18, 2174:19,2179:8, 2181:8,2181:43, 2181:47,2182:5, 2182:39,2184:23, 2184:35,2184:40, 2196:41,2207:36, 2214:46,2215:12, 2215:13,2215:14, 2216:27

Dong [1] - 2175:22dots [4] - 2172:10,

2172:14, 2172:18,2173:22

double [1] - 2148:28double-check [1] -

2148:28doubt [3] - 2085:4,

2090:3, 2194:15doubts [4] - 2089:1,

2089:45, 2096:11,2103:21

down [49] - 2085:22,2087:22, 2089:17,2091:13, 2091:41,2091:44, 2092:3,2092:4, 2093:46,2094:8, 2095:34,2095:36, 2096:22,2098:44, 2109:26,

2110:33, 2110:47,2111:46, 2114:47,2119:36, 2120:16,2120:21, 2134:19,2136:23, 2137:19,2137:25, 2141:42,2147:14, 2148:40,2149:30, 2149:31,2157:19, 2163:34,2164:42, 2174:40,2175:35, 2176:1,2176:2, 2176:13,2176:19, 2191:23,2191:35, 2192:30,2201:14, 2205:27,2209:30, 2209:41,2210:10

DPI [2] - 2174:27,2186:28

DPI.0001.0002.0001[2] - 2138:46, 2155:30

DPI.0002.0001.0001[1] - 2137:10

DPIE [1] - 2174:35draft [1] - 2083:19drafting [2] -

2134:40, 2196:23draw [6] - 2115:6,

2124:46, 2126:1,2126:7, 2130:16,2135:11

drawing [2] -2127:11, 2194:28

drawn [3] - 2128:43,2144:47, 2185:13

draws [1] - 2216:26dressing [2] -

2180:6, 2181:3DRET [2] - 2215:25,

2216:7drew [1] - 2101:25dries [3] - 2097:14,

2097:20, 2097:30drill [14] - 2086:19,

2087:23, 2087:24,2087:33, 2087:38,2088:19, 2102:7,2107:4, 2108:10,2108:32, 2108:40,2109:25, 2116:3,2182:42

drilled [6] - 2087:1,2087:42, 2087:46,2087:47, 2132:44,2133:1

drilling [193] -2085:16, 2086:7,2086:18, 2087:8,2087:9, 2087:10,2087:25, 2087:29,


10

2088:10, 2088:15,2088:18, 2088:20,2088:27, 2088:37,2089:7, 2089:21,2089:22, 2090:26,2090:35, 2091:11,2091:23, 2094:30,2094:32, 2094:39,2094:47, 2095:4,2095:14, 2095:18,2095:30, 2095:35,2096:21, 2096:45,2097:44, 2098:26,2099:14, 2099:15,2099:16, 2099:35,2099:38, 2100:6,2100:16, 2100:30,2101:17, 2102:6,2102:10, 2102:19,2102:30, 2104:8,2104:18, 2104:24,2105:10, 2105:14,2105:21, 2105:32,2106:5, 2107:3,2107:9, 2108:18,2108:38, 2109:16,2109:18, 2109:26,2109:28, 2109:38,2112:12, 2115:7,2115:9, 2115:20,2115:32, 2117:9,2118:21, 2118:30,2118:41, 2119:2,2119:6, 2119:14,2120:18, 2120:43,2121:9, 2121:19,2121:41, 2122:1,2122:4, 2122:26,2123:26, 2124:6,2124:41, 2125:2,2125:15, 2126:2,2126:7, 2127:13,2127:19, 2127:23,2127:30, 2127:45,2128:34, 2129:33,2130:2, 2130:13,2130:38, 2130:42,2131:7, 2131:17,2131:28, 2131:33,2132:8, 2132:17,2132:23, 2133:5,2133:22, 2133:31,2133:36, 2134:6,2135:20, 2135:42,2135:47, 2137:3,2137:32, 2138:25,2138:34, 2138:43,2139:27, 2139:33,2140:4, 2141:38,2142:29, 2142:33,2143:3, 2143:25,

2144:33, 2145:45,2148:16, 2148:44,2153:31, 2154:45,2155:9, 2155:47,2156:7, 2157:44,2160:14, 2161:36,2162:1, 2165:41,2167:7, 2172:5,2172:19, 2172:21,2173:36, 2174:12,2175:31, 2176:4,2181:6, 2181:11,2181:34, 2181:37,2181:38, 2181:40,2182:5, 2182:17,2182:25, 2182:39,2184:2, 2184:20,2185:10, 2187:28,2187:45, 2188:4,2188:8, 2188:19,2188:28, 2188:29,2188:36, 2188:41,2189:37, 2190:2,2190:21, 2194:35,2194:47, 2195:6,2197:41, 2201:44,2202:10, 2202:21,2202:32, 2203:3,2203:7, 2203:16,2203:35, 2204:10,2206:44

Drilling [3] - 2168:4,2175:4, 2175:13

dug [1] - 2161:41Duncan [6] -

2110:31, 2146:36,2146:43, 2147:3,2147:29, 2183:21

duplicate [1] -2132:25

duplicating [1] -2173:46

during [11] -2085:44, 2095:10,2107:34, 2113:31,2148:18, 2154:43,2168:25, 2177:39,2197:7, 2197:29,2197:32

Dusan [1] - 2203:45duties [1] - 2196:36

E

early [3] - 2161:21,2183:6, 2197:23

earnest [1] - 2084:41earthquake [1] -

2180:37easily [1] - 2140:41

effect [12] - 2110:46,2110:47, 2153:26,2177:5, 2198:23,2198:27, 2201:41,2202:8, 2204:18,2205:42, 2212:16,2215:42

effected [3] - 2197:9,2197:12, 2215:5

effective [10] -2127:39, 2131:6,2133:23, 2162:30,2163:1, 2165:29,2165:34, 2169:17,2182:11, 2194:37

effectively [4] -2086:14, 2109:36,2174:11, 2179:4

effectiveness [2] -2103:22, 2192:44

effort [1] - 2169:16eight [4] - 2109:34,

2109:35, 2110:20,2110:47

either [16] - 2086:22,2086:42, 2087:14,2095:11, 2099:29,2110:34, 2111:33,2140:13, 2144:42,2155:8, 2165:29,2167:22, 2180:6,2214:1, 2214:24,2216:11

elapse [1] - 2106:25element [1] -

2216:22elevated [1] -

2139:35email [43] - 2091:32,

2091:34, 2091:44,2092:5, 2092:8,2092:14, 2092:32,2092:38, 2093:2,2093:16, 2093:25,2093:31, 2093:36,2094:41, 2094:45,2095:6, 2095:37,2100:47, 2101:4,2101:6, 2101:8,2101:19, 2101:20,2101:26, 2101:31,2112:37, 2119:1,2130:1, 2154:45,2174:26, 2174:33,2174:40, 2174:42,2174:46, 2175:36,2175:42, 2176:21,2179:21, 2179:25,2182:30, 2185:42,2186:21, 2186:35

emails [2] - 2155:4,2155:7

embark [1] - 2189:31employed [1] -

2190:40employer [1] -

2204:12enable [7] - 2083:30,

2170:32, 2176:36,2178:38, 2189:18,2190:19, 2194:45

encountered [5] -2098:16, 2099:20,2099:25, 2099:42,2100:2

encourage [1] -2208:24

end [7] - 2085:4,2108:43, 2159:39,2170:21, 2171:11,2181:28, 2206:6

endeavour [1] -2165:27

endorse [1] -2155:34

ends [1] - 2091:42energy [4] - 2202:2,

2202:12, 2202:37,2203:37

Energy [6] - 2191:11,2196:3, 2196:4,2197:10, 2197:11,2197:17

enforcement [1] -2191:10

engaged [1] - 2199:1engagement [2] -

2154:42, 2155:2engine [3] - 2128:14,

2128:20, 2128:21engineer [9] -

2097:44, 2099:14,2099:15, 2099:35,2099:38, 2188:1,2190:41, 2190:43,2194:47

engineering [9] -2119:34, 2119:43,2120:12, 2128:4,2128:8, 2191:9,2196:23, 2203:3,2203:4

Engineering [1] -2191:5

engineers [3] -2090:26, 2188:21,2204:10

engines [1] -2128:21

ensure [11] -

2090:28, 2096:46,2132:36, 2133:7,2155:18, 2181:8,2181:32, 2184:44,2185:36, 2187:32,2209:18

ensured [2] -2131:18, 2208:7

ensuring [8] -2097:10, 2097:15,2177:45, 2182:15,2208:5, 2208:25,2208:37, 2208:39

entered [1] - 2169:18entering [4] -

2100:12, 2100:23,2116:5, 2182:11

entire [2] - 2115:34,2124:44

entirely [1] - 2194:6entitled [1] - 2210:39entries [8] - 2092:2,

2096:22, 2096:35,2117:14, 2117:19,2118:21, 2157:18

entry [14] - 2092:2,2106:38, 2116:16,2116:31, 2116:38,2127:25, 2136:28,2142:10, 2143:22,2144:32, 2144:41,2156:40, 2156:46,2157:3

environment [2] -2155:10, 2208:12

environmental [5] -2182:40, 2188:23,2202:22, 2207:6,2207:7

envisaged [6] -2134:6, 2138:34,2138:43, 2144:33,2150:31, 2151:8

equally [1] - 2186:28equipment [1] -

2095:36equips [1] - 2203:6equivalent [2] -

2136:11, 2137:15Errington [1] -

2209:38error [3] - 2108:43,

2136:1, 2211:27especially [1] -

2090:35essentially [9] -

2086:18, 2092:18,2092:20, 2095:26,2095:30, 2095:32,2101:2, 2101:23,


11

2107:11Esso [1] - 2206:4establish [5] -

2085:34, 2086:42,2087:2, 2087:41,2087:45

established [7] -2085:23, 2085:47,2086:9, 2086:26,2169:23, 2194:13,2194:19

establishing [4] -2087:7, 2087:14,2087:18, 2088:9

estimate [10] -2108:38, 2108:40,2109:11, 2109:16,2123:7, 2124:8,2124:10, 2124:14,2124:24

estimated [4] -2109:7, 2109:35,2122:38, 2190:3

et [3] - 2114:1,2160:29, 2160:37

evaluation [1] -2125:41

evening [1] - 2159:5event [10] - 2083:33,

2084:35, 2085:9,2138:1, 2145:5,2149:5, 2149:13,2159:31, 2159:38,2212:25

events [5] - 2091:24,2092:9, 2158:24,2190:22, 2212:10

evidence [58] -2084:46, 2091:27,2094:38, 2095:43,2103:14, 2105:8,2110:44, 2111:1,2114:30, 2117:41,2117:44, 2118:2,2118:10, 2118:15,2119:2, 2120:2,2125:43, 2134:38,2135:10, 2148:35,2149:11, 2149:33,2149:37, 2149:42,2149:46, 2151:1,2151:2, 2151:35,2153:4, 2153:26,2153:46, 2154:25,2160:47, 2161:45,2168:38, 2170:11,2170:16, 2174:3,2176:43, 2177:5,2184:26, 2187:22,2187:23, 2190:36,

2190:39, 2191:29,2192:3, 2193:33,2195:35, 2198:8,2198:15, 2198:27,2201:41, 2201:45,2202:1, 2202:7,2203:21, 2207:23

exact [4] - 2086:16,2118:3, 2177:2,2179:26

exactly [20] - 2090:3,2106:47, 2107:8,2107:19, 2107:39,2108:20, 2118:3,2124:9, 2140:26,2140:32, 2150:44,2160:36, 2162:33,2169:31, 2177:13,2179:38, 2183:17,2187:8, 2212:9,2215:28

examination [1] -2085:2

EXAMINATION [2] -2085:12, 2195:39

example [18] -2087:20, 2088:11,2091:13, 2099:46,2107:27, 2113:32,2125:21, 2141:35,2182:9, 2184:10,2199:1, 2199:8,2201:27, 2205:7,2206:37, 2207:5,2212:47, 2213:43

excellent [2] -2182:35, 2183:35

except [1] - 2093:44exceptional [1] -

2199:6exceptions [1] -

2170:34exchange [2] -

2185:43, 2186:22excused [1] -

2195:22exercise [1] -

2181:14existence [1] -

2183:3existing [1] -

2144:13expect [8] - 2121:31,

2131:10, 2131:20,2132:31, 2132:37,2132:41, 2133:12,2143:43

expectation [4] -2096:14, 2115:40,2131:25, 2141:15

expected [5] -2092:21, 2113:14,2147:44, 2207:15,2214:15

expecting [1] -2084:35

experience [16] -2083:47, 2084:10,2088:47, 2089:5,2089:37, 2090:16,2091:1, 2118:23,2173:35, 2177:7,2184:25, 2201:43,2202:9, 2202:42,2203:15, 2203:34

experienced [1] -2204:11

expertise [3] -2173:35, 2175:31,2203:10

explain [4] -2118:31, 2128:6,2150:44, 2166:8

explanation [3] -2118:28, 2120:10,2171:10

explicit [1] - 2190:5explicitly [1] -

2104:4exploitation [1] -

2196:41exploration [2] -

2182:40, 2196:40explore [1] - 2156:27exposure [1] -

2151:34express [1] -

2083:21expressions [1] -

2211:2extended [2] -

2151:34, 2205:10extending [1] -

2206:24extensive [2] -

2177:7, 2205:13extent [6] - 2088:28,

2142:39, 2185:9,2198:24, 2200:2,2202:44

extenuating [1] -2151:36

extra [1] - 2091:12extract [1] - 2179:4extracts [1] -

2191:28

F

faced [2] - 2090:16,2091:8

facilities [1] -2182:39

fact [31] - 2085:39,2090:38, 2091:1,2091:11, 2091:23,2094:22, 2101:12,2102:27, 2111:18,2113:10, 2113:46,2115:20, 2128:20,2133:42, 2142:28,2142:34, 2143:18,2143:26, 2148:42,2151:18, 2156:6,2162:36, 2165:11,2177:25, 2180:32,2183:39, 2185:31,2211:22, 2211:36,2214:24, 2216:26

factor [6] - 2084:24,2101:10, 2125:14,2167:25, 2168:6,2168:27

fail [1] - 2171:15failed [9] - 2089:16,

2090:15, 2095:27,2099:8, 2099:11,2116:11, 2129:40,2165:35

failing [6] - 2099:42,2099:45, 2100:2,2102:25, 2128:22,2130:4

failings [2] -2155:40, 2176:30

fails [1] - 2090:22failure [11] -

2099:20, 2105:36,2113:4, 2113:23,2117:20, 2117:28,2149:13, 2167:22,2168:23, 2180:38,2180:44

failures [1] - 2155:45fair [44] - 2095:2,

2097:38, 2101:28,2103:12, 2108:22,2111:5, 2119:47,2120:13, 2121:34,2125:31, 2127:35,2128:1, 2133:25,2135:44, 2149:41,2149:46, 2151:46,2153:47, 2159:35,2159:36, 2159:45,2165:14, 2166:24,

2169:4, 2169:13,2169:20, 2171:8,2172:7, 2173:7,2173:38, 2173:41,2174:20, 2180:10,2180:46, 2184:38,2190:23, 2190:33,2192:2, 2192:36,2193:9, 2193:44,2194:1, 2203:14,2208:3

fairly [2] - 2168:36,2212:5

faith [1] - 2176:25falls [1] - 2144:27false [1] - 2171:1falsely [1] - 2171:2Fame [1] - 2191:11familiar [5] -

2156:31, 2174:47,2176:9, 2176:16,2209:42

familiarise [1] -2161:28

far [4] - 2084:43,2088:27, 2114:36,2187:16

fashion [2] -2083:40, 2204:24

fault [1] - 2180:42faultless [2] -

2182:47, 2183:10favour [3] - 2083:45,

2084:8, 2204:4features [1] -

2209:10February [1] -

2197:24fell [1] - 2185:28felt [2] - 2108:1,

2108:6few [12] - 2095:9,

2096:26, 2099:22,2102:3, 2102:29,2103:20, 2183:24,2183:47, 2204:13,2204:20, 2205:21

field [2] - 2132:44,2190:46

fifth [1] - 2121:43figure [9] - 2104:33,

2109:42, 2142:43,2145:40, 2160:5,2160:19, 2161:2,2161:4, 2165:40

figures [4] - 2103:44,2132:38, 2172:26,2173:45

file [3] - 2212:42,2214:22, 2216:8


12

files [1] - 2212:1final [2] - 2083:22,

2084:47finally [3] - 2148:32,

2187:20, 2190:35findings [2] -

2083:24, 2084:25fine [5] - 2092:45,

2102:19, 2110:19,2110:46, 2184:24

finished [4] -2085:15, 2109:45,2147:6, 2149:27

finishes [1] -2109:27

first [19] - 2093:4,2093:35, 2093:47,2104:12, 2106:38,2108:40, 2116:14,2117:43, 2119:10,2123:16, 2132:43,2133:1, 2134:23,2134:28, 2138:30,2166:14, 2166:43,2187:27, 2188:24

firstly [3] - 2145:9,2147:19, 2160:25

fit [1] - 2107:47fitted [13] - 2107:19,

2107:20, 2108:20,2109:1, 2113:12,2141:46, 2141:47,2142:12, 2142:13,2142:20, 2142:28,2143:18, 2144:26

five [14] - 2088:26,2096:7, 2102:2,2121:24, 2121:42,2145:44, 2150:31,2150:34, 2150:41,2151:8, 2151:31,2184:14, 2188:47,2189:5

flavour [1] - 2094:33flew [2] - 2199:27,

2199:30flexibility [1] -

2208:24flick [1] - 2181:13flipside [1] - 2208:32float [11] - 2087:21,

2096:36, 2096:45,2097:3, 2097:24,2097:36, 2099:20,2112:29, 2117:20,2117:28, 2167:23

floats [14] - 2090:15,2092:19, 2092:24,2092:29, 2093:20,2095:27, 2099:8,

2099:11, 2099:42,2099:45, 2100:2,2112:26, 2129:40,2130:4

floor [2] - 2194:37,2195:45

flow [6] - 2092:30,2096:40, 2097:24,2112:29, 2138:1,2181:28

flow-back [1] -2092:30

flowing [2] -2138:14, 2138:24

flows [1] - 2097:36fluid [8] - 2097:36,

2112:12, 2133:23,2133:27, 2133:32,2133:37, 2134:9,2136:27

fluids [1] - 2097:29fly [2] - 2128:13,

2128:19focus [16] - 2088:34,

2102:15, 2171:43,2179:42, 2181:6,2181:11, 2181:22,2181:26, 2181:28,2181:34, 2181:38,2182:24, 2188:10,2188:21, 2196:32,2203:41

focused [2] -2196:33, 2196:42

folder [1] - 2093:11follow [5] - 2145:6,

2155:46, 2157:18,2158:4, 2194:24

followed [5] -2107:2, 2141:33,2157:22, 2167:46,2216:7

following [6] -2083:46, 2091:28,2130:30, 2137:27,2156:46, 2166:7

followup [1] -2191:42

force [5] - 2114:12,2162:11, 2162:14,2212:40, 2213:2

forcing [1] - 2098:43forecast [6] -

2156:38, 2156:45,2157:13, 2157:22,2157:44, 2158:7

foreshorten [1] -2084:31

forgot [1] - 2111:32form [3] - 2092:17,

2097:19, 2183:28formal [14] -

2145:23, 2153:29,2153:42, 2153:44,2154:3, 2154:10,2154:16, 2196:20,2196:27, 2203:2,2204:5, 2211:26,2211:32, 2213:18

format [1] - 2205:22formation [18] -

2086:20, 2086:30,2086:34, 2086:35,2086:39, 2086:47,2087:5, 2087:26,2087:37, 2087:39,2088:19, 2094:10,2101:11, 2101:13,2109:32, 2132:29,2133:6, 2133:8

formed [4] - 2083:23,2095:23, 2112:37,2207:18

former [3] - 2083:1,2203:11, 2203:37

forming [3] -2092:13, 2093:15,2093:19

forward [6] -2117:41, 2146:46,2158:16, 2174:29,2185:42, 2208:40

four [18] - 2099:30,2099:32, 2099:34,2109:33, 2118:20,2123:9, 2123:11,2123:15, 2123:45,2128:20, 2145:44,2150:31, 2151:8,2151:31, 2165:45,2172:9, 2172:41,2189:5

fracture [1] -2086:38

frame [2] - 2120:22,2200:27

frames [2] - 2104:8,2124:7

framework [1] -2207:12

FRANK [1] - 2195:37frank [1] - 2195:41free [1] - 2195:23frequent [1] -

2146:15Friday [6] - 2085:1,

2199:28, 2199:31,2199:35, 2200:41

friend [3] - 2083:44,2093:3, 2154:33

front [1] - 2088:34fulfil [8] - 2128:45,

2155:18, 2155:40,2171:40, 2173:27,2187:26, 2202:16,2214:27

fulfilled [2] -2202:35, 2208:10

fulfilling [3] -2114:23, 2196:36,2207:38

full [5] - 2090:29,2102:20, 2160:35,2195:41, 2206:6

fully [1] - 2175:21function [3] -

2173:28, 2187:26,2192:23

functions [2] -2128:45, 2171:41

fundamental [6] -2128:47, 2129:29,2171:28, 2186:47,2192:42, 2212:5

fundamentally [2] -2186:2, 2186:17

fundamentals [1] -2115:22

future [8] - 2100:17,2128:34, 2128:45,2173:4, 2187:24,2189:38, 2190:2,2190:11

G

GA [3] - 2175:27,2186:34, 2187:15

GA's [2] - 2175:21,2186:28

gainsay [1] -2169:35

gap [1] - 2125:31Gas [1] - 2190:42gathered [1] -

2160:22gauge [1] - 2178:32gazette [1] - 2215:12General [1] -

2154:34general [13] -

2097:45, 2153:25,2154:39, 2179:28,2179:40, 2192:32,2196:42, 2209:17,2214:33, 2214:41,2215:2, 2215:8,2215:10

generalisation [1] -

2153:47generality [1] -

2216:12generally [14] -

2115:1, 2120:4,2120:6, 2120:9,2122:2, 2136:38,2151:21, 2155:15,2178:1, 2184:47,2197:3, 2198:21,2214:1, 2214:13

generic [3] -2178:36, 2181:35,2182:21

GEO.0003.0001.1100 [1] - 2141:37

Geological [1] -2190:45

geology [1] -2196:41

Geoscience [3] -2175:27, 2175:30,2186:24

GI [1] - 2121:27given [40] - 2084:19,

2102:23, 2103:14,2111:30, 2113:6,2113:7, 2114:29,2115:6, 2116:13,2117:44, 2119:11,2121:32, 2121:43,2123:23, 2128:47,2143:5, 2145:11,2148:35, 2156:17,2157:45, 2158:14,2177:7, 2177:21,2182:24, 2182:27,2183:42, 2184:7,2187:23, 2192:3,2198:23, 2198:30,2198:41, 2199:20,2206:21, 2207:7,2211:7, 2211:32,2213:13, 2213:28,2213:29

glancing [1] -2189:14

glossing [1] -2095:33

God [1] - 2180:43good-faith [1] -

2176:25Gouldin [7] -

2148:36, 2149:10,2149:21, 2149:47,2151:1, 2151:2,2151:3

Gouldin's [1] -2149:33

government [1] -


13

2147:38Government [2] -

2191:43, 2215:34graduate [1] -

2196:24grant [2] - 2154:31,

2209:26Grant [2] - 2093:3,

2093:5GRANT [3] -

2083:44, 2154:23,2195:11

Grant) [1] - 2093:4granted [1] - 2112:16grave [2] - 2207:28,

2208:11greater [3] - 2097:35,

2098:41, 2208:24grip [1] - 2124:9guarantee [1] -

2124:24guess [6] - 2099:36,

2099:39, 2101:10,2151:4, 2161:4,2186:27

guidance [1] -2215:25

guidelines [2] -2135:22, 2206:35

Gulf [1] - 2190:43

H

H1 [41] - 2092:10,2093:17, 2093:19,2093:28, 2094:11,2094:17, 2102:31,2106:12, 2110:5,2113:17, 2121:27,2122:13, 2122:20,2122:31, 2123:16,2123:20, 2123:28,2124:2, 2124:36,2127:6, 2127:46,2134:6, 2137:5,2137:32, 2141:47,2142:7, 2142:14,2142:20, 2142:28,2142:43, 2143:23,2143:27, 2155:42,2160:43, 2165:4,2182:34, 2182:41,2182:45, 2183:35,2184:8, 2199:47

H1" [2] - 2106:9,2106:39

H1-ST1 [11] -2095:19, 2111:43,2118:17, 2130:31,

2135:28, 2138:25,2141:11, 2157:10,2164:34, 2164:36,2206:14

H2 [4] - 2121:27,2124:3, 2129:36,2141:39

H3 [3] - 2121:27,2124:3, 2142:43

H3-ST1 [1] - 2142:1H4 [8] - 2094:4,

2094:11, 2094:14,2109:18, 2109:38,2110:2, 2121:27,2124:2

Hai [1] - 2175:22half [4] - 2090:27,

2090:29, 2183:43,2184:25

Hall [1] - 2191:11hand [4] - 2101:1,

2167:20, 2168:2,2168:21

handful [4] -2099:36, 2183:31,2183:34, 2183:47

happy [5] - 2083:37,2111:14, 2122:26,2175:38, 2204:12

hard [2] - 2124:9,2188:3

harder [1] - 2173:7hardly [5] - 2181:36,

2182:21, 2183:10,2188:36, 2189:2

harsh [1] - 2172:47hazard [1] - 2144:10hazards [1] -

2144:20head [8] - 2095:34,

2107:44, 2136:26,2138:32, 2138:41,2148:21, 2148:25

heading [6] -2093:47, 2106:12,2120:22, 2129:35,2205:24, 2205:27

Headquarters [2] -2190:44, 2191:6

hear [6] - 2083:38,2102:19, 2129:19,2198:8, 2198:15,2198:27

heard [10] - 2113:34,2154:36, 2186:44,2187:22, 2190:29,2194:13, 2198:34,2201:41, 2201:45,2207:23

hearing [1] - 2149:8

hearings [4] -2083:8, 2084:44,2085:3, 2191:25

heavily [4] - 2134:40,2181:19, 2189:14,2212:9

heavy [4] - 2173:39,2173:43, 2174:4,2184:35

held [4] - 2092:19,2092:29, 2196:8,2196:16

Held [1] - 2082:26help [8] - 2084:28,

2106:33, 2177:20,2179:42, 2180:1,2180:12, 2187:47,2189:19

helped [2] - 2130:16,2191:44

helpful [3] - 2084:28,2120:34, 2179:29

helps [1] - 2172:20hence [2] - 2180:34,

2181:34hereby [1] - 2210:24hide [1] - 2114:4high [4] - 2096:40,

2097:36, 2139:40,2139:41

highlight [1] - 2095:7highlighted [2] -

2093:36, 2094:16highlighting [2] -

2095:6, 2101:8highlights [1] -

2094:33himself [1] - 2198:24hindsight [11] -

2100:42, 2100:44,2111:14, 2127:43,2130:11, 2150:12,2150:21, 2150:26,2150:28, 2167:13,2172:7

history [4] - 2159:44,2173:11, 2173:15,2184:8

hit [1] - 2087:22hitting [1] - 2180:37hmm [2] - 2156:42,

2169:7hold [1] - 2099:16holding [3] - 2097:9,

2098:44, 2167:24holds [1] - 2086:45hole" [1] - 2109:25Holland [16] -

2160:15, 2160:33,2174:26, 2174:43,

2179:47, 2196:46,2197:1, 2197:3,2197:6, 2197:18,2198:4, 2198:12,2198:25, 2198:29,2198:38, 2199:4

hooked [5] -2133:27, 2133:37,2133:42, 2134:2,2134:9

hope [3] - 2093:12,2110:18, 2166:8

hopefully [1] -2128:25

hoping [1] - 2180:13horizon [1] - 2111:8horizontal [6] -

2097:42, 2097:44,2097:46, 2098:2,2098:17, 2100:2

hours [11] - 2122:38,2123:21, 2123:30,2124:25, 2124:30,2125:35, 2127:47,2150:34, 2150:42,2151:33, 2157:26

HOWE [3] - 2083:3,2084:18, 2084:31

Howe [2] - 2084:24,2146:43

human [1] - 2208:12hurt [1] - 2120:37Hyannis [1] -

2190:47hybrid [1] - 2193:38hydrocarbons [5] -

2097:29, 2100:12,2100:23, 2169:18,2182:11

hydrostatic [15] -2112:12, 2130:32,2130:44, 2130:45,2131:5, 2131:18,2131:33, 2132:8,2132:13, 2132:22,2136:26, 2138:32,2138:41, 2148:20,2148:25

I

ID [1] - 2191:21idea [1] - 2169:4identified [4] -

2130:24, 2144:11,2144:21, 2204:31

identify [2] -2204:26, 2209:11

ignore [1] - 2173:30

ii [2] - 2144:12,2210:45

ill [1] - 2186:29imagination [1] -

2111:20immediate [2] -

2084:36, 2149:5immediately [5] -

2089:42, 2125:30,2153:10, 2160:24,2174:24

impact [5] - 2091:24,2101:4, 2151:17,2151:40, 2151:44

impacted [2] -2149:6, 2149:14

implement [1] -2138:13

implements [1] -2187:41

implore [1] - 2110:39import [1] - 2192:28importance [2] -

2098:40, 2111:26important [16] -

2097:10, 2097:15,2105:36, 2114:23,2114:37, 2114:39,2114:45, 2153:30,2153:41, 2175:45,2181:31, 2182:15,2186:14, 2187:26,2207:47

importantly [1] -2089:44

impose [1] - 2212:23imposed [2] -

2084:26, 2183:37incident [2] - 2184:1,

2190:10inclination [1] -

2162:24include [3] -

2168:23, 2179:5,2205:37

included [9] -2119:45, 2124:7,2141:15, 2164:37,2187:29, 2187:46,2188:20, 2204:23,2205:41

including [3] -2174:27, 2196:38,2205:16

inclusive [1] -2117:15

incommunicado [1]

- 2154:25incompetently [1] -

2182:6


14

inconsistency [1] -2139:43

inconsistent [1] -2116:14

inconvenience [1] -2181:27

increase [1] -2144:12

increasing [1] -2128:21

indeed [1] - 2166:44independently [2] -

2185:7, 2192:16indicate [3] -

2084:13, 2140:10,2154:36

indicated [3] -2083:40, 2094:22,2142:29

indication [3] -2165:14, 2167:8,2197:37

indictment [2] -2168:36, 2172:44

individual [4] -2189:25, 2214:47,2215:1, 2215:35

individuals [7] -2155:5, 2183:32,2183:34, 2183:39,2183:42, 2183:47,2189:44

inducted [1] -2191:11

Industries [4] -2137:12, 2139:1,2155:25, 2155:35

industry [6] - 2120:4,2120:9, 2136:38,2173:28, 2202:43,2216:18

ineffective [1] -2166:2

infer [1] - 2100:1inferred [1] - 2107:7infinitely [1] -

2128:28influence [1] -

2125:17influenced [1] -

2125:14informal [3] -

2153:44, 2154:38,2204:6

information [62] -2092:14, 2094:44,2094:47, 2098:22,2103:20, 2103:28,2103:31, 2103:33,2103:38, 2112:43,

2112:47, 2113:5,2114:4, 2117:4,2118:22, 2120:10,2120:24, 2120:29,2120:35, 2121:36,2133:5, 2133:16,2134:44, 2136:17,2139:25, 2140:7,2154:13, 2156:19,2156:20, 2157:39,2157:47, 2159:10,2159:13, 2160:28,2161:33, 2161:35,2163:17, 2164:17,2164:25, 2164:29,2164:43, 2165:27,2169:10, 2169:24,2170:31, 2171:40,2171:46, 2172:2,2172:9, 2172:40,2173:12, 2173:20,2173:23, 2177:40,2184:46, 2185:18,2185:30, 2185:36,2201:23, 2201:35,2201:39, 2204:4

informed [1] -2170:32

informing [3] -2147:18, 2151:11,2198:38

inhibited [2] -2112:1, 2112:5

initial [2] - 2098:37,2098:43

input [1] - 2135:1INQ.0001.0001.

1537 [1] - 2143:47INQ.9000.0001.

0001 [1] - 2191:21inquiries [2] -

2084:12, 2092:37inquiry [1] - 2190:32Inquiry [46] -

2092:36, 2103:2,2103:8, 2117:41,2117:45, 2119:12,2128:44, 2134:19,2134:35, 2134:38,2136:18, 2136:24,2137:11, 2138:47,2139:25, 2140:7,2140:20, 2145:11,2146:6, 2146:18,2148:10, 2154:20,2160:47, 2161:30,2161:33, 2161:36,2163:8, 2166:11,2166:15, 2167:18,2168:18, 2169:28,

2169:47, 2170:12,2170:17, 2170:26,2170:29, 2172:39,2173:23, 2187:16,2187:22, 2192:3,2211:42, 2212:16,2212:36, 2214:9

INQUIRY [1] -2082:20

Inquiry's [1] -2083:10

insert [2] - 2205:42,2206:3

inserted [2] - 2176:8,2205:32

insertion [1] -2085:38

inside [1] - 2090:29insight [1] - 2084:3insignificance [6] -

2146:21, 2149:41,2150:2, 2150:9,2150:16, 2151:10

insignificant [1] -2147:36

insist [1] - 2147:23insisted [1] -

2159:25inspection [1] -

2191:10inspections [1] -

2193:14install [6] - 2106:17,

2107:44, 2108:5,2108:34, 2108:45,2132:38

installation [6] -2104:44, 2105:26,2106:25, 2142:5,2147:20, 2189:46

installed [31] -2103:30, 2104:1,2105:17, 2106:33,2106:47, 2107:1,2107:8, 2107:9,2107:24, 2107:27,2107:30, 2107:34,2113:1, 2123:43,2124:3, 2125:29,2125:30, 2126:42,2129:3, 2141:10,2143:15, 2143:26,2144:31, 2148:42,2158:29, 2158:35,2163:12, 2163:37,2185:23, 2185:31,2188:29

installing [2] -2147:6, 2147:7

instance [1] -

2201:27instances [6] -

2128:14, 2201:25,2201:39, 2202:2,2204:26, 2216:12

instead [1] - 2091:43instructed [2] -

2181:10, 2182:25instruction [1] -

2216:28instructions [1] -

2198:22instructors [1] -

2154:25instrument [1] -

2210:22insurance [1] -

2120:32integrity [64] -

2085:35, 2085:47,2086:8, 2086:21,2086:26, 2086:30,2086:34, 2086:43,2087:3, 2087:5,2087:7, 2087:19,2087:28, 2087:37,2087:41, 2087:45,2088:9, 2088:20,2089:2, 2089:6,2089:11, 2089:18,2089:35, 2089:38,2090:19, 2090:47,2091:2, 2091:9,2093:27, 2094:10,2095:12, 2095:44,2097:10, 2097:15,2097:19, 2097:25,2100:7, 2100:11,2100:22, 2100:32,2101:13, 2103:22,2105:46, 2110:36,2125:4, 2127:12,2127:18, 2128:39,2129:30, 2139:11,2144:10, 2151:18,2151:32, 2151:41,2151:44, 2167:8,2167:23, 2171:30,2182:15, 2187:1,2208:7, 2208:25,2209:18

intend [1] - 2119:44intended [3] -

2200:22, 2208:24,2211:36

intending [2] -2156:45, 2181:25

intensity [1] -2160:37

intention [2] -

2176:33, 2211:6intercept [1] -

2177:40intercepted [1] -

2161:15interception [1] -

2160:36interesting [1] -

2093:10Interior's [1] -

2190:41intermediate [1] -

2084:33interpretation [1] -

2211:1interpreted [1] -

2143:8interpreting [1] -

2143:11interrupt [2] -

2100:19, 2194:10interrupting [1] -

2148:30intervention [1] -

2136:28invoked [1] -

2172:21involve [1] - 2083:18involved [12] -

2089:47, 2097:43,2109:38, 2134:40,2150:7, 2160:13,2160:15, 2160:43,2165:5, 2184:20,2212:9, 2215:29

involvement [1] -2209:22

involving [1] -2165:3

Islands [1] - 2196:13issue [16] - 2083:5,

2089:47, 2098:36,2098:44, 2099:12,2100:39, 2101:11,2101:18, 2101:36,2135:31, 2177:31,2185:46, 2212:11,2212:32, 2213:37,2216:2

issued [5] - 2083:6,2210:18, 2213:41,2214:2

issues [7] - 2083:29,2110:9, 2112:22,2153:31, 2186:47,2194:22, 2216:13

item [1] - 2210:11itself [1] - 2100:7


15

J

Jacob [13] - 2148:1,2148:24, 2160:24,2160:25, 2161:3,2163:27, 2164:25,2164:29, 2176:42,2176:47, 2177:19,2183:22, 2209:47

Jacob's [3] -2163:16, 2172:5,2172:28

Jeremy [1] - 2195:41JEREMY [1] -

2195:37jigsaw [2] - 2171:14,

2171:22job [25] - 2086:22,

2089:17, 2089:23,2089:44, 2089:45,2090:1, 2090:3,2090:7, 2090:8,2090:31, 2090:38,2090:39, 2091:30,2091:37, 2092:33,2095:27, 2095:31,2099:44, 2102:26,2112:24, 2188:27,2188:32, 2188:33,2196:27

jobs [1] - 2089:30jogged [1] - 2130:5join [1] - 2172:10joined [2] - 2172:14,

2172:18joining [1] - 2173:21joke [1] - 2186:36judgment [1] -

2102:4July [20] - 2119:7,

2119:15, 2120:25,2122:1, 2122:30,2122:36, 2122:41,2123:26, 2124:5,2124:15, 2126:12,2129:6, 2129:10,2129:14, 2129:23,2131:7, 2131:17,2132:7, 2155:47,2197:42

jumping [1] - 2190:4jurisdiction [2] -

2215:43, 2216:29jurisdictions [5] -

2215:16, 2215:24,2215:25, 2216:11,2216:27

justification [3] -2138:12, 2156:21,

2157:47justified [1] - 2184:1justify [2] - 2158:14,

2159:11

K

keen [1] - 2160:4keep [3] - 2094:8,

2176:19, 2200:2key [1] - 2182:33kicked [3] - 2138:2,

2138:15, 2138:24kill [2] - 2138:33,

2138:42killed [1] - 2161:15kind [7] - 2190:11,

2196:28, 2197:1,2199:41, 2206:1,2209:47, 2210:3

knowing [1] - 2107:3knowledge [16] -

2102:17, 2104:36,2111:17, 2113:12,2113:35, 2113:38,2114:9, 2120:9,2132:34, 2160:12,2160:19, 2171:29,2200:41, 2202:43,2204:35, 2209:24

L

lack [7] - 2169:41,2171:28, 2171:31,2171:34, 2171:35,2171:39, 2171:43

land [1] - 2196:23landing [1] - 2108:33Lands [2] - 2204:36,

2213:36large [2] - 2201:28,

2214:42larger [1] - 2205:24last [69] - 2085:26,

2085:36, 2085:46,2086:6, 2091:7,2091:19, 2095:6,2095:24, 2096:26,2097:23, 2097:34,2100:25, 2101:16,2103:44, 2104:30,2104:33, 2105:20,2105:28, 2105:32,2106:6, 2107:13,2108:25, 2108:31,2109:7, 2110:5,2112:15, 2115:3,2115:46, 2116:24,

2116:30, 2122:1,2122:30, 2122:36,2122:41, 2123:27,2124:6, 2124:15,2126:13, 2126:23,2129:6, 2129:10,2129:14, 2129:23,2131:7, 2131:17,2132:7, 2139:28,2140:36, 2140:37,2153:10, 2153:20,2154:4, 2159:39,2161:21, 2161:40,2165:3, 2170:11,2170:16, 2170:25,2170:29, 2170:38,2171:19, 2178:28,2197:4, 2197:21,2197:33, 2197:42,2198:19, 2216:25

late [3] - 2133:2,2197:4, 2197:25

latest [1] - 2216:22law [2] - 2196:38,

2196:39lax [3] - 2182:31,

2184:1, 2184:4lax" [1] - 2184:7lay [1] - 2181:37lead [3] - 2123:28,

2164:30, 2187:21lead-up [1] - 2187:21leading [3] -

2121:10, 2129:15,2190:22

leak [10] - 2086:21,2086:31, 2086:38,2087:6, 2087:26,2087:38, 2088:19,2089:15, 2091:37,2116:3

leak-off [10] -2086:21, 2086:31,2086:38, 2087:6,2087:26, 2087:38,2088:19, 2089:15,2091:37, 2116:3

learn [3] - 2160:32,2161:29, 2190:22

Learned [1] -2141:43

learned [2] - 2093:3,2154:33

learning [1] -2132:47

learnt [3] - 2128:37,2130:1, 2190:13

least [11] - 2084:40,2085:1, 2085:10,2090:29, 2109:34,

2110:6, 2154:44,2177:28, 2179:8,2197:38, 2198:19

leave [23] - 2084:19,2084:47, 2111:2,2111:30, 2114:30,2114:34, 2114:37,2122:31, 2127:33,2137:5, 2137:21,2144:43, 2160:22,2170:12, 2170:17,2170:29, 2182:42,2197:1, 2197:3,2197:6, 2197:23,2197:25, 2197:28

leaves [1] - 2126:3leaving [10] - 2115:7,

2129:1, 2135:27,2150:32, 2150:40,2151:9, 2151:30,2151:32, 2159:7,2185:41

led [11] - 2113:5,2117:33, 2118:2,2151:13, 2154:10,2160:28, 2164:12,2166:2, 2169:31,2170:42, 2183:40

left [14] - 2096:14,2110:6, 2112:1,2122:37, 2122:47,2123:21, 2123:28,2124:36, 2129:2,2133:38, 2133:47,2134:7, 2157:43,2203:39

legal [2] - 2196:38,2198:4

legislation [8] -2166:20, 2204:27,2204:28, 2204:30,2205:28, 2205:37,2206:34, 2213:35

legislative [13] -2177:26, 2177:32,2186:4, 2204:19,2205:1, 2205:2,2205:31, 2205:44,2206:6, 2206:30,2206:43, 2206:45,2208:16

length [2] - 2085:2,2106:25

less [6] - 2094:46,2104:32, 2107:47,2108:5, 2169:22,2186:29

lesser [1] - 2147:1lesson [2] - 2127:17,

2128:46

lessons [3] -2128:37, 2128:43,2190:22

Lessons [1] -2141:43

letter [19] - 2137:11,2139:21, 2140:37,2155:25, 2155:30,2155:36, 2163:42,2164:30, 2165:16,2172:5, 2172:28,2201:8, 2201:14,2201:28, 2201:31,2209:42, 2210:3,2210:7

letters [2] - 2187:11,2209:47

Level [1] - 2082:26level [16] - 2114:6,

2115:11, 2118:36,2118:38, 2134:12,2155:21, 2168:37,2168:40, 2174:14,2174:17, 2183:15,2188:34, 2188:43,2192:33, 2192:34

levels [1] - 2171:6liaise [1] - 2084:15liaised [1] - 2186:34licence [1] - 2196:17life [1] - 2208:12light [7] - 2083:25,

2110:9, 2110:44,2158:23, 2168:38,2172:23, 2200:35

likelihood [4] -2105:26, 2162:26,2166:2, 2169:18

likely [20] - 2084:45,2091:20, 2094:46,2096:35, 2117:19,2117:33, 2117:43,2118:24, 2122:46,2127:38, 2140:25,2153:41, 2153:43,2169:11, 2169:36,2200:29, 2200:37,2205:9, 2208:7,2214:12

limitation [1] -2185:39

limited [8] - 2087:20,2087:24, 2089:35,2154:43, 2168:41,2180:1, 2185:11,2185:14

line [12] - 2095:34,2115:41, 2140:37,2142:42, 2146:35,2148:33, 2148:37,


16

2148:39, 2148:41,2149:19, 2149:20,2174:14

lines [2] - 2110:19,2110:32

list [4] - 2130:31,2137:28, 2190:3,2215:17

listed [2] - 2140:40,2178:38

listen [6] - 2084:38,2090:41, 2110:39,2115:33, 2116:47,2177:43

live [1] - 2136:25lives [1] - 2203:11located [2] -

2092:38, 2154:19location [2] -

2137:39, 2137:45lodged [1] - 2206:38log [2] - 2087:21,

2087:28logging [1] - 2087:15look [30] - 2092:44,

2093:4, 2093:5,2093:7, 2109:34,2117:14, 2120:41,2121:5, 2130:7,2145:19, 2148:10,2155:24, 2156:4,2156:31, 2157:2,2157:9, 2157:18,2161:44, 2162:1,2162:4, 2162:8,2172:4, 2173:4,2178:28, 2179:45,2182:16, 2186:40,2186:41, 2190:12,2190:21

looked [7] - 2096:28,2132:19, 2162:16,2184:30, 2215:23,2216:8, 2216:25

looking [7] -2093:14, 2095:32,2095:33, 2104:30,2108:18, 2140:36,2181:1

looks [1] - 2174:47low [1] - 2139:39lunch [2] - 2139:22,

2139:24LUNCHEON [1] -

2152:6lunchtime [1] -

2155:24

M

main [3] - 2162:18,2203:41, 2209:10

maintain [1] -2199:46

maintained [1] -2133:24

major [1] - 2095:26majority [1] - 2206:8malfunction [1] -

2097:3Mall [1] - 2195:46manage [1] - 2194:2Management [3] -

2190:46, 2191:17,2204:37

management [17] -2119:24, 2119:29,2144:1, 2155:20,2178:37, 2180:7,2181:3, 2183:17,2187:38, 2192:44,2196:43, 2206:36,2207:6, 2207:11,2207:12, 2207:13,2209:11

manager [5] -2148:36, 2149:11,2202:37, 2203:11,2203:37

manner [3] -2141:26, 2178:17,2182:1

manually [1] -2107:30

manuals [1] -2178:37

March [67] - 2085:16,2085:25, 2085:36,2085:46, 2086:6,2086:17, 2086:25,2088:38, 2091:7,2091:19, 2091:24,2091:35, 2092:2,2092:3, 2093:26,2094:1, 2095:19,2095:24, 2097:23,2097:34, 2100:25,2100:29, 2101:4,2101:16, 2101:19,2101:20, 2101:26,2102:16, 2102:17,2102:30, 2104:30,2104:32, 2104:37,2105:32, 2106:6,2107:13, 2108:25,2108:30, 2109:7,2110:5, 2111:23,

2112:15, 2112:38,2113:35, 2115:3,2115:40, 2115:46,2116:30, 2130:1,2155:26, 2155:42,2161:40, 2165:42,2167:7, 2171:21,2172:5, 2172:13,2172:19, 2173:36,2197:32, 2197:36,2199:13, 2199:42,2199:43, 2200:6,2200:15, 2214:11

margin [4] - 2110:33,2132:28, 2132:35,2133:7

Maria [1] - 2190:46MAROZZI [1] -

2083:1Marozzi [184] -

2083:4, 2085:14,2086:30, 2087:13,2087:36, 2088:25,2088:38, 2089:14,2090:41, 2092:3,2092:36, 2093:3,2093:5, 2093:11,2093:37, 2094:1,2094:39, 2095:15,2095:43, 2096:5,2096:23, 2100:21,2100:39, 2101:35,2102:22, 2102:29,2103:33, 2104:3,2104:18, 2104:42,2105:5, 2105:33,2106:23, 2106:41,2109:15, 2110:39,2110:43, 2111:8,2113:27, 2114:17,2115:4, 2115:10,2115:27, 2115:31,2116:13, 2117:10,2117:15, 2119:6,2119:12, 2120:16,2120:42, 2121:2,2126:19, 2126:45,2128:27, 2130:20,2131:1, 2131:41,2134:17, 2134:28,2135:27, 2136:5,2136:16, 2136:23,2137:11, 2138:5,2138:37, 2139:5,2139:22, 2139:38,2140:36, 2142:40,2142:46, 2143:46,2143:47, 2145:10,2145:42, 2146:4,2146:30, 2146:36,2148:2, 2148:32,

2149:2, 2149:20,2149:34, 2150:27,2152:3, 2153:3,2154:24, 2155:31,2156:5, 2156:30,2156:37, 2157:32,2158:32, 2158:46,2159:14, 2159:31,2161:13, 2163:31,2163:35, 2163:42,2164:3, 2164:44,2166:6, 2166:34,2167:12, 2167:17,2168:37, 2169:9,2169:46, 2170:8,2171:19, 2171:30,2172:17, 2172:21,2172:46, 2173:9,2173:34, 2174:4,2174:19, 2174:23,2174:41, 2176:2,2176:7, 2176:14,2177:24, 2177:43,2178:29, 2179:25,2179:46, 2180:11,2181:9, 2182:30,2183:3, 2183:14,2184:13, 2184:30,2184:41, 2186:40,2187:20, 2187:33,2189:22, 2189:42,2190:1, 2190:11,2190:29, 2190:35,2191:13, 2191:23,2192:8, 2192:27,2194:5, 2194:14,2194:24, 2194:33,2195:8, 2195:22,2197:47, 2198:8,2198:21, 2198:24,2198:27, 2198:39,2199:47, 2200:5,2200:30, 2200:47,2201:5, 2201:20,2201:23, 2202:4,2202:25, 2203:9,2203:16, 2204:14,2204:17, 2204:25,2204:31, 2204:41,2206:21, 2207:14,2207:18, 2207:24

Marozzi's [8] -2085:23, 2194:29,2201:41, 2204:45,2205:9, 2205:36,2205:41, 2205:47

Martin [1] - 2160:34Massachusetts [1] -

2190:47matching [1] -

2109:32

material [5] -2166:28, 2167:20,2168:2, 2168:21,2207:18

matter [11] -2084:35, 2084:43,2102:10, 2128:43,2146:20, 2150:8,2150:9, 2154:24,2170:2, 2194:17,2199:6

matters [20] -2084:1, 2084:6,2089:31, 2114:17,2114:18, 2115:33,2128:32, 2144:47,2153:42, 2153:44,2169:41, 2170:41,2171:30, 2196:28,2199:41, 2202:21,2203:3, 2203:16,2212:25

mean [17] - 2096:28,2106:20, 2119:24,2119:29, 2119:38,2123:23, 2139:38,2153:9, 2181:13,2183:21, 2183:32,2184:42, 2184:44,2199:31, 2206:32,2207:10, 2209:46

meanings [1] -2211:7

means [4] - 2125:28,2133:27, 2148:16,2193:16

meant [5] - 2092:14,2098:20, 2143:13,2178:23, 2194:7

measures [3] -2138:14, 2138:24,2193:15

mechanical [1] -2128:8

mechanism [1] -2208:45

meet [1] - 2190:24meeting [6] -

2153:14, 2153:30,2153:44, 2176:37,2199:1, 2199:8

meetings [10] -2153:5, 2153:23,2153:40, 2153:41,2154:3, 2154:10,2154:16, 2154:28,2154:37, 2200:3

Melbourne [2] -2161:19, 2199:26

members [2] -


17

2109:41, 2200:3memorandum [9] -

2102:47, 2120:17,2200:5, 2200:29,2200:46, 2201:19,2204:24, 2205:22,2206:1

memorandums [6] -2197:36, 2197:47,2205:11, 2205:15,2205:19, 2205:20

memory [4] -2099:40, 2130:5,2200:31, 2203:39

men [1] - 2107:30mention [2] -

2111:36, 2205:2mentioned [8] -

2086:30, 2089:15,2091:36, 2092:32,2094:31, 2174:13,2182:38, 2185:12

mercy [1] - 2189:27mere [2] - 2151:18,

2162:36merely [1] - 2183:31merit [1] - 2085:7merits [1] - 2185:41met [3] - 2135:21,

2166:18, 2178:34Mexico [1] - 2190:43micro [3] - 2180:6,

2181:3, 2194:2micro-manage [1] -

2194:2micro-management

[1] - 2181:3mid [4] - 2197:24,

2197:25, 2197:29mid-December [1] -

2197:24mid-February [1] -

2197:24mid-year [2] -

2197:25, 2197:29midday [5] -

2157:34, 2157:43,2158:20, 2158:41,2159:4

might [43] - 2083:28,2083:39, 2084:28,2085:3, 2085:5,2089:6, 2089:13,2090:46, 2092:42,2095:45, 2110:16,2112:38, 2120:31,2123:17, 2124:24,2130:16, 2136:44,2137:27, 2137:38,2151:18, 2151:41,

2153:15, 2153:24,2159:6, 2176:7,2180:19, 2180:25,2181:3, 2182:4,2183:40, 2187:15,2189:36, 2189:41,2190:11, 2193:6,2194:23, 2204:13,2205:35, 2206:4,2206:38, 2210:5,2213:47, 2216:11

mightn't [3] -2180:21, 2183:41,2209:15

mind [29] - 2083:29,2084:7, 2091:25,2092:14, 2093:21,2096:5, 2096:9,2099:12, 2100:47,2101:13, 2102:16,2108:29, 2116:32,2116:33, 2116:39,2116:44, 2118:2,2126:12, 2126:18,2146:2, 2147:5,2149:42, 2149:47,2160:40, 2165:23,2169:29, 2171:23,2173:3, 2195:3

mindful [2] -2086:23, 2090:6

Minerals [3] -2190:46, 2191:17,2196:4

Mines [2] - 2136:6,2136:17

minimum [1] -2208:23

minute [1] - 2121:6minutes [1] -

2169:22misleading [2] -

2143:2, 2143:4misplaced [1] -

2101:26misreading [3] -

2101:30, 2112:42,2112:46

miss [1] - 2084:6missed [1] - 2168:9missing [1] - 2141:1mistaken [1] -

2215:24misunderstand [1] -

2095:46misunderstood [1] -

2123:17mitigate [1] -

2126:31mitigation [3] -

2137:47, 2138:13,2138:23

MLS [3] - 2141:46,2142:12, 2159:19

mmm-hmm [2] -2156:42, 2169:7

MMS [2] - 2191:1,2191:6

moment [9] -2139:24, 2145:42,2149:3, 2172:32,2201:12, 2202:27,2203:20, 2212:22,2215:20

Monday [2] - 2094:1,2157:2

money [1] - 2195:2monitor [2] -

2137:47, 2192:33monitored [1] -

2133:24monitoring [20] -

2102:24, 2113:14,2114:5, 2155:13,2173:40, 2184:40,2184:42, 2184:44,2185:1, 2185:6,2185:9, 2185:15,2185:17, 2189:23,2189:26, 2189:31,2190:27, 2194:35,2194:38, 2194:46

MONTARA [1] -2082:20

Montara [20] -2093:18, 2094:4,2106:9, 2106:12,2106:39, 2126:22,2129:36, 2131:8,2132:44, 2133:1,2141:39, 2155:41,2156:10, 2156:39,2160:27, 2165:4,2184:14, 2184:21,2191:24, 2206:14

month [1] - 2171:22months [8] - 2096:7,

2102:2, 2111:13,2114:47, 2116:20,2197:5, 2197:26,2203:39

morning [18] -2091:29, 2091:34,2091:38, 2091:44,2092:44, 2094:41,2094:45, 2095:25,2100:47, 2101:4,2101:19, 2114:13,2118:31, 2119:1,2130:1, 2157:10,

2160:21, 2186:44most [10] - 2091:20,

2114:4, 2128:14,2134:45, 2171:6,2181:31, 2186:3,2189:11, 2205:40

move [7] - 2089:1,2089:39, 2090:17,2091:11, 2095:45,2176:10, 2208:33

moved [1] - 2126:40movement [2] -

2181:42, 2208:26MPa [1] - 2112:1MR [47] - 2083:3,

2083:44, 2084:18,2084:31, 2085:12,2085:14, 2088:36,2093:7, 2093:10,2093:40, 2093:46,2094:38, 2096:20,2099:32, 2100:38,2102:29, 2104:41,2110:43, 2111:41,2114:16, 2115:24,2115:31, 2128:24,2140:47, 2143:17,2148:27, 2148:32,2152:1, 2153:3,2154:23, 2154:33,2184:40, 2187:20,2190:35, 2191:21,2192:38, 2194:22,2194:32, 2195:8,2195:11, 2195:13,2195:19, 2195:34,2195:39, 2195:41,2215:38, 2216:33

mud [2] - 2138:33,2138:42

multiply [2] -2123:15, 2123:45

multiplying [2] -2123:9, 2123:11

must [3] - 2144:7,2144:20, 2178:37

N

name [6] - 2099:45,2183:12, 2195:41,2203:44, 2205:42,2206:3

namely [16] -2085:25, 2103:28,2114:28, 2121:27,2124:36, 2128:4,2128:9, 2135:20,2138:32, 2138:42,2144:41, 2171:21,

2178:29, 2204:46,2206:28, 2213:35

native [1] - 2196:38nature [10] -

2112:23, 2131:34,2145:2, 2153:15,2154:39, 2179:28,2180:38, 2182:18,2183:42, 2186:8

necessarily [5] -2084:3, 2096:1,2183:32, 2200:42,2209:46

necessary [1] -2210:38

necessity [1] -2156:21

need [45] - 2084:18,2084:36, 2085:6,2087:38, 2090:6,2090:9, 2091:30,2092:4, 2101:21,2103:6, 2106:36,2108:38, 2109:17,2110:34, 2110:35,2110:46, 2114:28,2114:34, 2122:25,2123:15, 2123:45,2128:24, 2132:28,2150:26, 2151:10,2156:36, 2157:46,2159:13, 2159:19,2159:20, 2173:3,2176:2, 2176:8,2176:14, 2176:22,2182:20, 2187:47,2188:18, 2188:21,2192:16, 2194:36,2206:45, 2207:3,2209:41, 2215:27

needed [9] -2101:37, 2151:44,2165:40, 2165:46,2172:4, 2172:9,2199:10, 2209:17,2214:3

needing [1] -2087:32

needs [5] - 2087:21,2133:23, 2133:27,2138:42, 2192:43

neglected [2] -2085:38, 2111:29

negotiable [1] -2136:33

net [1] - 2155:3never [6] - 2100:2,

2114:1, 2163:11,2205:10, 2205:12,2212:17


18

nevertheless [5] -2089:6, 2090:17,2095:45, 2103:23,2108:24

new [9] - 2131:9,2131:12, 2132:47,2177:25, 2183:37,2186:3, 2208:34,2208:42, 2216:3

news [1] - 2160:23next [27] - 2085:6,

2086:19, 2090:17,2092:1, 2094:9,2095:38, 2095:45,2108:37, 2120:46,2137:10, 2137:36,2138:8, 2138:46,2146:2, 2146:24,2146:34, 2147:15,2147:42, 2147:47,2149:20, 2149:32,2175:19, 2194:19,2195:22, 2200:14,2206:10

night [5] - 2084:5,2103:44, 2104:33,2105:20, 2105:28

nine [1] - 2110:20nipple [1] - 2109:24no-one [1] - 2172:18nominate [2] -

2124:45, 2189:24nominated [1] -

2086:46nominating [1] -

2123:41non [8] - 2143:35,

2143:36, 2143:39,2147:20, 2149:5,2149:40, 2150:7,2192:24

non-compliance [3]

- 2143:35, 2143:36,2143:39

non-immediate [1] -2149:5

non-installation [1] -2147:20

non-prescriptive [1]

- 2192:24non-reinstallation

[2] - 2149:40, 2150:7none [5] - 2113:28,

2184:13, 2185:6,2193:24, 2216:36

NOPSA's [1] -2187:17

normal [1] - 2136:38normally [3] -

2104:9, 2109:30,

2150:17Northern [42] -

2084:45, 2134:18,2134:34, 2135:37,2136:11, 2139:44,2140:3, 2145:1,2147:18, 2147:43,2151:20, 2166:7,2166:10, 2167:17,2168:17, 2169:34,2169:46, 2172:22,2172:33, 2172:45,2173:27, 2175:44,2176:25, 2179:21,2182:31, 2185:45,2186:23, 2186:46,2186:47, 2187:18,2190:18, 2191:39,2193:25, 2193:46,2194:11, 2195:24,2195:46, 2196:4,2201:6, 2203:24,2203:31, 2211:42

notation [1] -2199:46

note [3] - 2153:14,2162:18, 2216:33

noted [1] - 2162:22notes [1] - 2153:15nothing [8] -

2088:27, 2094:21,2122:4, 2138:23,2154:15, 2160:40,2162:37, 2195:16

notice [2] - 2142:24,2161:30

notification [5] -2143:40, 2213:18,2213:28, 2214:46,2215:1

notified [9] -2143:31, 2143:37,2150:10, 2150:12,2150:13, 2150:36,2151:14, 2151:29,2213:32

notify [3] - 2151:20,2151:23, 2215:16

notifying [1] -2212:24

November [2] -2161:21, 2161:27

NT [2] - 2147:38,2191:44

NTG.0001.0002.0224 [1] - 2174:22

NTG.0001.0004.0144 [1] - 2201:13

NTG.0001.0004.0145 [2] - 2200:11,

2205:26NTG.0001.0005.

0032 [1] - 2120:15NTG.0001.0007.

0005 [1] - 2209:30NTG.0001.0007.

0010 [1] - 2210:14number [9] -

2099:20, 2104:22,2107:30, 2121:15,2145:4, 2213:12,2215:2, 2215:9,2215:47

numbers [1] -2204:39

nutshell [1] -2153:40

O

o'clock [7] - 2152:4,2157:10, 2157:15,2157:34, 2158:10,2158:20, 2158:42

O'Shea [1] - 2145:11objective [1] -

2085:10obligation [3] -

2189:2, 2209:23,2213:20

observe [1] -2084:10

observer [1] -2191:38

obvious [2] -2158:21, 2180:7

obviously [6] -2085:7, 2107:43,2126:44, 2139:40,2162:33, 2202:28

occasionally [1] -2204:38

occasions [4] -2205:5, 2205:19,2205:41, 2216:1

occupy [1] - 2209:35occur [11] - 2093:28,

2116:1, 2116:16,2116:37, 2125:38,2136:32, 2137:27,2178:24, 2187:39,2189:18, 2199:5

occurred [18] -2112:25, 2114:1,2118:4, 2126:26,2126:32, 2133:17,2138:20, 2139:17,2153:11, 2155:7,2162:29, 2165:4,

2180:20, 2180:30,2189:32, 2200:43,2202:4, 2212:18

occurring [6] -2120:42, 2121:1,2146:35, 2148:1,2148:34, 2212:25

October [1] -2191:10

OF [1] - 2082:20offer [4] - 2157:40,

2175:43, 2176:25,2214:12

offered [3] - 2155:35,2162:19, 2204:12

offers [1] - 2097:46offhand [1] - 2197:23Office [1] - 2190:44office [4] - 2160:22,

2199:2, 2199:7,2199:34

officer [1] - 2202:29officers [5] - 2153:5,

2155:5, 2184:10,2202:29, 2202:35

offices [2] - 2153:6,2190:46

official [1] - 2197:2offline [6] - 2107:24,

2187:28, 2187:45,2188:9, 2188:19,2188:29

offset [1] - 2109:30offshore [18] -

2095:37, 2159:44,2173:28, 2175:31,2188:45, 2191:18,2196:12, 2196:38,2196:40, 2202:32,2202:42, 2203:3,2203:16, 2203:35,2208:5, 2209:19,2216:13, 2216:18

Offshore [3] -2190:42, 2191:7,2191:11

often [2] - 2089:47,2206:36

Oil [1] - 2190:42oilfield [22] -

2098:31, 2111:20,2115:21, 2119:39,2119:46, 2120:3,2127:33, 2133:13,2135:22, 2135:33,2135:42, 2136:18,2136:39, 2162:20,2174:6, 2178:19,2180:39, 2181:33,2192:18, 2208:38,

2208:46, 2209:6OK [1] - 2092:25on-site [1] - 2184:42on-the-job [1] -

2196:27onboard [1] - 2195:4once [3] - 2099:38,

2108:8one [78] - 2083:4,

2083:28, 2084:33,2085:19, 2086:44,2087:10, 2088:18,2088:26, 2089:20,2091:36, 2092:41,2093:17, 2093:26,2094:21, 2104:45,2105:17, 2113:29,2115:12, 2115:14,2121:37, 2122:32,2122:37, 2122:47,2123:22, 2123:29,2123:31, 2124:36,2125:34, 2127:34,2127:37, 2127:47,2128:3, 2128:14,2128:15, 2128:20,2128:28, 2128:47,2129:2, 2129:3,2129:4, 2129:15,2136:26, 2136:33,2137:6, 2137:21,2140:17, 2140:24,2150:2, 2150:16,2159:43, 2162:9,2162:14, 2162:18,2168:13, 2169:17,2172:18, 2172:22,2173:11, 2173:15,2177:9, 2177:24,2179:4, 2181:31,2182:42, 2185:25,2187:14, 2187:27,2188:45, 2189:6,2194:40, 2200:36,2201:18, 2205:23,2207:47, 2209:10,2209:46

one-well [1] -2088:18

onerous [4] - 2189:2,2189:9, 2189:14

ones [3] - 2212:40,2214:12, 2214:36

ongoing [1] -2182:33

onshore [4] -2090:35, 2188:44,2189:45, 2196:40

open [8] - 2086:47,2127:46, 2128:15,


19

2135:28, 2136:25,2137:21, 2150:32,2182:32

opened [1] - 2158:25operate [1] - 2131:29operated [1] -

2088:40operating [21] -

2083:29, 2084:6,2091:26, 2102:43,2103:10, 2103:15,2110:28, 2112:5,2114:41, 2115:15,2127:39, 2130:14,2130:21, 2131:35,2135:29, 2138:41,2139:10, 2165:22,2191:9, 2207:38,2214:42

operation [15] -2095:39, 2115:21,2121:19, 2121:41,2123:7, 2127:13,2127:19, 2127:23,2127:30, 2132:45,2161:10, 2161:11,2165:3, 2181:5,2188:29

operational [11] -2153:15, 2153:44,2156:38, 2156:44,2158:7, 2183:18,2188:22, 2188:24,2189:4, 2189:5,2192:45

Operations [2] -2191:6, 2204:37

operations [33] -2087:8, 2089:7,2119:25, 2119:30,2124:1, 2126:7,2144:1, 2145:22,2148:35, 2149:11,2153:31, 2153:42,2155:20, 2161:32,2162:20, 2168:26,2173:40, 2174:35,2180:32, 2184:2,2190:2, 2190:4,2202:3, 2202:12,2202:37, 2203:11,2203:37, 2203:42,2207:13, 2209:10,2210:26, 2216:31

operator [95] -2085:21, 2089:1,2089:5, 2089:37,2090:16, 2090:34,2090:46, 2091:1,2091:8, 2091:40,

2092:4, 2093:46,2096:20, 2099:15,2104:10, 2104:16,2109:45, 2111:41,2111:46, 2117:8,2117:13, 2119:10,2120:39, 2120:46,2129:33, 2131:10,2131:21, 2132:25,2132:31, 2132:37,2132:45, 2133:13,2134:12, 2134:15,2134:27, 2136:4,2136:15, 2136:22,2137:8, 2137:19,2137:25, 2137:36,2138:29, 2138:46,2140:32, 2141:31,2141:34, 2141:42,2143:46, 2147:14,2149:18, 2149:30,2149:31, 2154:43,2156:3, 2156:28,2163:29, 2163:34,2164:2, 2164:41,2166:9, 2166:14,2170:6, 2173:46,2174:33, 2174:39,2175:35, 2176:1,2176:13, 2176:19,2178:8, 2178:17,2179:46, 2185:36,2187:41, 2190:3,2190:37, 2191:22,2191:35, 2191:46,2192:13, 2200:10,2200:14, 2200:27,2201:1, 2201:13,2206:3, 2208:25,2209:29, 2209:30,2210:9, 2210:13,2213:29, 2213:42,2214:3

operator's [4] -2192:41, 2204:47,2205:42, 2207:13

operators [14] -2184:9, 2184:10,2193:25, 2208:45,2213:12, 2213:32,2214:2, 2214:47,2215:1, 2215:10,2215:17, 2215:36,2215:43, 2216:3

opinion [2] -2194:36, 2204:11

opportunity [7] -2083:12, 2084:21,2103:36, 2107:43,2107:47, 2108:5,2108:11

opposed [4] -2115:12, 2145:34,2157:43, 2202:21

optical [1] - 2093:41option [2] - 2083:42,

2084:38order [11] - 2087:37,

2123:12, 2127:12,2133:22, 2156:8,2159:20, 2164:16,2164:17, 2171:16,2171:40

organisation [1] -2183:33

originally [1] -2083:40

otherwise [1] -2115:47

outcome [3] -2087:25, 2150:24,2159:28

outcomes [1] -2190:24

outline [1] - 2196:20outlined [2] -

2083:46, 2198:21outside [2] -

2109:35, 2191:38overarching [2] -

2177:37, 2181:44overbalance [7] -

2131:10, 2131:18,2132:10, 2132:14,2132:29, 2132:39,2133:8

overdisplaced [1] -2094:23

overdisplacement[6] - 2112:25, 2117:28,2118:4, 2118:11,2118:24, 2163:2

overlooked [3] -2109:37, 2111:18,2114:27

overnight [1] -2103:36

overseas [1] -2177:8

overseeing [1] -2189:4

oversight [3] -2109:17, 2109:39,2143:19

own [6] - 2096:5,2111:19, 2151:2,2180:21, 2184:45,2216:13

P

packer [2] - 2126:41page [46] - 2092:1,

2092:3, 2093:35,2093:37, 2093:47,2094:8, 2094:9,2096:21, 2104:24,2104:25, 2106:8,2106:36, 2106:38,2108:37, 2108:42,2109:45, 2109:47,2117:13, 2120:41,2120:47, 2129:34,2134:16, 2134:28,2137:36, 2138:29,2139:4, 2139:5,2146:24, 2146:31,2146:34, 2147:15,2148:33, 2148:39,2149:19, 2149:20,2149:21, 2149:31,2149:33, 2156:35,2156:36, 2167:16,2175:19, 2200:14,2200:28, 2206:10,2210:45

pages [9] - 2104:12,2108:42, 2172:9,2172:41, 2188:37,2189:11, 2189:13,2205:16

paragraph [37] -2085:22, 2085:30,2119:35, 2119:42,2130:29, 2130:43,2134:17, 2134:32,2134:47, 2135:16,2135:20, 2135:37,2137:37, 2138:5,2138:8, 2138:30,2140:37, 2145:19,2146:25, 2146:30,2148:10, 2156:13,2156:28, 2166:14,2166:34, 2166:36,2166:38, 2166:43,2167:17, 2167:34,2168:17, 2168:19,2170:6, 2171:1,2205:12, 2206:7,2210:21

paragraphs [11] -2085:24, 2119:13,2119:14, 2129:35,2146:3, 2146:7,2146:19, 2156:5,2167:5, 2167:6,2167:16

pardon [1] - 2186:10

part [41] - 2101:14,2103:3, 2104:9,2104:21, 2106:36,2109:17, 2109:23,2109:39, 2109:47,2111:29, 2111:32,2117:39, 2118:47,2119:3, 2119:38,2119:43, 2119:45,2121:9, 2122:25,2131:9, 2131:23,2134:33, 2134:39,2136:1, 2142:25,2148:23, 2155:31,2164:31, 2166:39,2169:41, 2171:29,2176:5, 2177:18,2182:15, 2189:2,2200:42, 2202:15,2207:12, 2208:25,2209:26, 2210:37

particular [17] -2114:5, 2117:2,2118:1, 2120:5,2126:8, 2130:16,2132:38, 2135:24,2154:28, 2155:4,2204:27, 2204:32,2205:2, 2206:11,2212:27, 2212:33,2214:3

particularly [9] -2098:8, 2098:21,2098:35, 2105:45,2127:37, 2130:23,2202:4, 2204:28,2212:15

parties [13] - 2083:5,2083:10, 2083:17,2083:20, 2083:30,2083:34, 2084:3,2084:16, 2084:19,2084:25, 2084:38,2084:41, 2085:6

parts [5] - 2113:31,2134:45, 2179:5,2187:8, 2212:31

pass [1] - 2084:5passage [2] -

2094:17, 2158:23passive [4] -

2193:36, 2193:47,2194:3, 2194:6

past [9] - 2087:24,2090:27, 2174:3,2183:43, 2189:32,2200:7, 2204:20,2205:21, 2207:33

paste [1] - 2176:17Paul [1] - 2195:41


20

PAUL [1] - 2195:37pause [2] - 2137:26,

2215:20pausing [7] -

2093:47, 2166:22,2167:39, 2192:2,2194:40, 2201:12,2209:31

pay [2] - 2102:18,2189:36

PCC [24] - 2104:1,2106:17, 2106:20,2106:26, 2106:32,2107:34, 2108:34,2123:23, 2123:42,2124:45, 2141:1,2145:20, 2146:20,2147:20, 2147:22,2147:24, 2148:42,2149:39, 2150:7,2158:41, 2163:36,2170:34, 2170:35

PCCC [3] - 2104:44,2108:1, 2108:6

PCCCs [3] -2106:43, 2106:46,2107:23

PCCs [1] - 2107:7Peace [1] - 2188:36Peachey [1] -

2084:47penned [1] - 2166:35people [12] -

2095:37, 2095:44,2135:12, 2160:13,2166:40, 2175:30,2183:12, 2183:18,2186:30, 2195:4,2202:2, 2202:25

per [2] - 2121:32,2126:9

perceived [4] -2089:8, 2089:32,2089:34, 2176:30

performance [3] -2184:8, 2193:15,2193:37

performance-based [1] - 2193:37

perhaps [30] -2083:35, 2088:36,2093:2, 2093:14,2102:4, 2104:7,2104:15, 2110:34,2117:4, 2131:2,2134:27, 2142:47,2150:34, 2156:34,2159:23, 2161:28,2163:34, 2171:42,2173:6, 2173:35,

2174:1, 2174:13,2174:40, 2186:3,2194:7, 2200:10,2205:1, 2205:12,2206:37

period [26] - 2106:6,2108:47, 2110:6,2111:13, 2122:32,2122:36, 2122:46,2123:21, 2123:29,2124:29, 2127:34,2128:16, 2130:13,2130:22, 2133:6,2135:30, 2137:6,2140:17, 2147:1,2148:18, 2150:33,2159:8, 2161:17,2183:10, 2197:7,2199:7

permanent [5] -2112:12, 2130:46,2131:36, 2131:44,2132:11

permissible [1] -2137:38

permit [1] - 2136:25persevere [1] -

2095:32person [13] - 2114:9,

2150:7, 2174:11,2190:20, 2190:40,2191:4, 2201:42,2202:8, 2203:21,2203:24, 2203:35,2203:37, 2208:4

person's [1] -2203:44

personal [1] - 2177:7personnel [1] -

2154:28perspective [1] -

2212:43persuasion [1] -

2083:25pertaining [1] -

2102:9pertinent [1] -

2196:42Petroleum [4] -

2136:6, 2136:17,2204:36, 2213:36

petroleum [11] -2173:28, 2174:35,2175:31, 2196:33,2196:39, 2196:40,2202:43, 2203:11,2208:5, 2216:13,2216:18

petroleum-focused[1] - 2196:33

phase [5] - 2088:43,2088:47, 2095:38,2124:12, 2164:18

phases [1] - 2123:6philosophy [1] -

2208:20phone [3] - 2110:14,

2155:5, 2155:7phrase [4] - 2092:24,

2099:3, 2204:23,2204:46

pick [6] - 2094:24,2107:4, 2118:23,2118:29, 2118:35

picked [2] - 2110:14,2126:40

piece [2] - 2170:11,2170:16

pieces [4] - 2169:10,2171:14, 2171:22,2172:40

pinpoint [1] - 2118:1Pioneer [1] - 2191:12pipe [3] - 2107:4,

2108:10, 2108:33place [45] - 2095:19,

2096:16, 2109:17,2110:1, 2110:8,2111:10, 2114:40,2122:8, 2122:20,2123:22, 2123:29,2125:9, 2125:22,2125:35, 2127:47,2128:28, 2128:29,2128:40, 2132:36,2133:18, 2134:1,2135:29, 2136:27,2136:34, 2137:22,2138:1, 2138:23,2141:32, 2147:44,2162:30, 2162:37,2162:41, 2164:21,2164:33, 2165:18,2167:24, 2168:46,2177:26, 2177:47,2178:4, 2183:17,2194:46, 2206:35,2214:36, 2216:28

placed [2] - 2083:10,2134:12

plain [1] - 2211:13plan [10] - 2090:4,

2090:7, 2148:14,2155:20, 2193:15,2207:6, 2207:7,2207:11, 2207:13,2209:11

plane [1] - 2195:27planned [2] -

2122:47, 2148:19

plans [3] - 2187:38,2206:36, 2206:38

platform [2] -2156:39, 2184:14

platforms [1] -2209:19

players [1] - 2182:33playing [1] - 2101:13plenty [2] - 2108:11,

2131:13plug [7] - 2098:44,

2106:17, 2107:41,2108:1, 2108:6,2108:10, 2108:12

plugging [1] -2168:25

plugs [22] - 2085:40,2086:3, 2086:4,2086:13, 2087:23,2088:3, 2088:5,2089:46, 2090:3,2090:7, 2090:14,2090:20, 2090:23,2092:20, 2098:36,2098:42, 2099:1,2106:43, 2107:1,2107:9, 2107:20,2108:19

plus [1] - 2155:4point [48] - 2085:7,

2086:22, 2087:32,2088:29, 2089:15,2089:18, 2090:7,2090:36, 2092:22,2092:29, 2096:1,2098:3, 2106:11,2106:16, 2107:19,2108:35, 2114:12,2117:2, 2127:26,2134:1, 2143:45,2154:15, 2163:2,2163:4, 2163:6,2163:10, 2163:35,2164:43, 2166:32,2171:44, 2173:13,2173:32, 2177:28,2179:41, 2184:23,2186:6, 2192:7,2194:8, 2198:31,2202:1, 2205:7,2212:5, 2214:19,2214:25, 2215:22,2216:15, 2216:37

pointed [2] -2169:34, 2182:34

pointing [1] -2091:29

points [3] - 2172:36,2179:20, 2182:27

pollution [1] - 2191:8

poor [1] - 2139:16poorly [1] - 2182:6pore [5] - 2131:13,

2131:19, 2132:16,2132:29, 2132:46

position [22] -2095:1, 2101:16,2108:34, 2108:45,2114:10, 2116:36,2118:40, 2136:37,2151:32, 2159:9,2169:29, 2173:22,2182:20, 2194:46,2196:8, 2197:11,2197:14, 2197:16,2197:18, 2209:33,2209:35, 2213:31

positions [2] -2150:6, 2150:47

possibilities [1] -2091:20

possibility [1] -2097:21

possible [13] -2084:31, 2114:46,2127:5, 2130:18,2156:36, 2162:40,2167:21, 2168:3,2168:22, 2178:36,2181:18, 2183:44,2189:30

possibly [10] -2089:3, 2110:7,2126:10, 2143:8,2159:28, 2169:26,2181:29, 2187:5,2187:7

potential [1] - 2084:5potentially [1] -

2165:22Power [1] - 2203:29power [1] - 2213:37practicable [1] -

2115:16practice [46] -

2083:5, 2096:10,2098:31, 2100:43,2111:20, 2113:24,2115:21, 2119:39,2119:46, 2120:3,2120:10, 2120:12,2127:33, 2127:44,2128:14, 2130:22,2135:23, 2135:33,2135:43, 2136:18,2136:38, 2136:39,2139:9, 2139:16,2140:17, 2153:19,2155:40, 2155:46,2162:20, 2173:39,


21

2173:43, 2174:7,2178:19, 2179:13,2180:39, 2181:33,2192:18, 2198:9,2198:19, 2198:22,2198:30, 2204:8,2208:39, 2208:47,2209:7, 2214:33

practices [5] -2119:34, 2119:44,2139:44, 2153:37,2200:35

precautions [2] -2091:12, 2099:15

preceding [1] -2132:45

precise [1] - 2151:42precisely [1] -

2103:41predecessor [1] -

2210:25predominantly [2] -

2180:1, 2190:25prefer [1] - 2092:44preferred [1] -

2151:2preliminary [11] -

2083:19, 2083:24,2084:4, 2084:25,2084:27, 2198:9,2198:28, 2198:32,2198:40, 2199:2,2199:3

premature [1] -2191:40

preparation [2] -2160:45, 2160:47

prepare [2] - 2083:9,2203:10

prepared [6] -2109:30, 2156:38,2192:14, 2197:47,2202:30, 2204:16

preparing [2] -2083:14, 2170:17

prescriptive [3] -2192:24, 2193:38,2208:23

presence [1] -2127:11

present [5] -2126:26, 2127:1,2127:31, 2137:31,2176:42

presented [1] -2139:27

presently [3] -2167:20, 2168:2,2168:21

press [1] - 2118:7

pressure [99] -2085:34, 2085:39,2085:47, 2086:12,2086:39, 2086:46,2087:14, 2088:4,2088:12, 2089:20,2090:15, 2092:19,2096:40, 2097:37,2098:26, 2098:30,2098:37, 2098:40,2098:43, 2099:16,2102:37, 2103:29,2103:42, 2107:18,2108:19, 2110:8,2110:28, 2111:3,2111:47, 2115:47,2122:5, 2122:12,2122:19, 2124:43,2124:44, 2125:3,2125:5, 2125:10,2125:18, 2125:23,2125:39, 2130:33,2130:34, 2131:13,2131:19, 2132:17,2132:22, 2132:30,2132:46, 2133:6,2133:9, 2141:10,2142:6, 2142:19,2142:27, 2143:25,2144:25, 2144:31,2144:32, 2145:27,2145:33, 2147:8,2149:4, 2149:12,2150:30, 2151:7,2151:36, 2156:8,2157:23, 2157:28,2157:33, 2157:42,2158:9, 2158:11,2158:19, 2158:30,2158:35, 2159:4,2159:5, 2159:8,2159:21, 2159:26,2162:42, 2162:43,2163:11, 2163:21,2164:4, 2164:9,2164:21, 2164:33,2165:12, 2165:17,2168:44, 2168:45,2185:23, 2185:27

Pressure [2] -2167:46, 2168:24

pressure-containing [54] -2102:37, 2103:29,2103:42, 2107:18,2108:19, 2110:8,2110:28, 2111:3,2122:5, 2122:12,2122:19, 2125:3,2125:10, 2125:23,2125:39, 2130:33,

2130:34, 2141:10,2142:6, 2142:19,2142:27, 2143:25,2144:25, 2144:31,2144:32, 2145:27,2145:33, 2149:4,2149:12, 2150:30,2151:7, 2156:8,2157:33, 2157:42,2158:9, 2158:19,2158:35, 2159:4,2159:21, 2159:26,2162:42, 2162:43,2163:11, 2163:21,2164:4, 2164:9,2164:21, 2164:33,2165:12, 2165:17,2168:44, 2168:45,2185:23, 2185:27

pressures [1] -2132:46

pretend [1] - 2151:37pretty [2] - 2086:17,

2161:10prevent [7] -

2100:12, 2100:23,2113:19, 2126:32,2127:6, 2165:22,2165:34

preventer [1] -2122:7

preventing [2] -2181:4, 2182:11

prevention [1] -2191:8

previous [1] -2200:28

previously [6] -2108:43, 2136:10,2144:2, 2165:45,2187:25, 2214:37

primary [25] -2088:40, 2091:26,2101:43, 2102:43,2103:22, 2105:47,2111:12, 2111:27,2111:30, 2113:47,2114:28, 2114:35,2114:40, 2115:15,2116:9, 2125:4,2125:9, 2128:46,2129:24, 2129:29,2134:7, 2136:26,2136:33, 2169:16,2178:23

Primary [4] -2137:12, 2139:1,2155:25, 2155:35

prime [2] - 2174:11,2203:38

principal [1] -2174:34

principle [1] -2115:21

principles [6] -2119:34, 2119:44,2120:12, 2128:5,2128:8, 2171:36

priorities [1] -2177:21

privately [1] -2083:38

problem [17] -2092:18, 2093:20,2094:31, 2095:31,2095:39, 2096:3,2096:35, 2098:36,2098:42, 2126:33,2127:2, 2173:6,2173:10, 2173:47,2182:41, 2184:27,2185:12

problems [13] -2089:8, 2090:13,2097:41, 2112:28,2113:10, 2117:20,2117:27, 2129:6,2129:10, 2129:14,2129:36, 2130:23,2165:47

procedure [2] -2083:16, 2083:34

procedures [2] -2090:28, 2090:37

proceed [3] -2083:39, 2084:40,2195:21

proceeded [1] -2122:47

proceeding [1] -2084:27

proceedings [1] -2084:29

process [13] -2086:16, 2088:16,2105:2, 2105:4,2161:8, 2177:38,2181:36, 2185:1,2189:26, 2198:21,2199:24, 2209:26

processes [1] -2216:16

production [3] -2122:7, 2182:39,2196:16

professional [1] -2183:42

proffered [1] -2208:46

profound [1] -

2169:41profoundly [1] -

2186:45program [121] -

2086:20, 2088:18,2091:11, 2091:24,2103:34, 2103:37,2103:44, 2104:4,2104:18, 2104:24,2105:10, 2105:14,2105:21, 2105:28,2105:32, 2106:5,2106:42, 2106:44,2107:1, 2107:9,2107:19, 2108:18,2108:21, 2108:30,2110:34, 2119:6,2119:14, 2120:43,2121:10, 2122:4,2122:6, 2122:11,2122:26, 2122:31,2122:46, 2123:7,2123:28, 2123:41,2124:6, 2124:35,2124:41, 2125:2,2125:6, 2125:12,2125:15, 2125:24,2127:45, 2130:13,2130:38, 2130:42,2131:7, 2131:17,2131:28, 2132:8,2133:31, 2133:36,2134:6, 2135:20,2135:42, 2135:47,2137:3, 2137:32,2138:25, 2138:34,2138:43, 2139:27,2139:33, 2140:4,2140:9, 2140:13,2143:36, 2143:40,2144:33, 2145:23,2145:29, 2145:35,2145:36, 2145:45,2148:16, 2148:45,2150:13, 2150:15,2150:32, 2151:8,2151:13, 2151:19,2151:23, 2151:28,2151:41, 2151:43,2155:47, 2156:7,2157:41, 2157:44,2158:4, 2158:5,2158:8, 2158:9,2158:33, 2158:36,2158:37, 2159:16,2162:1, 2164:18,2176:4, 2177:40,2177:41, 2181:6,2181:11, 2181:19,2181:34, 2181:38,2181:40, 2182:5,


22

2182:17, 2182:25,2185:6, 2190:16,2193:14, 2197:42

Program [4] -2168:5, 2175:5,2175:13, 2190:42

programmed [3] -2093:22, 2101:14,2109:42

Programs [1] -2191:7

programs [5] -2100:16, 2104:8,2184:45, 2185:37,2191:10

progress [3] -2106:41, 2185:10,2185:11

progressed [2] -2095:38, 2096:11

project [4] - 2181:37,2187:28, 2197:5,2197:26

promoted [1] -2183:38

prompt [2] - 2130:7,2176:20

prompting [1] -2129:47

proper [2] - 2140:19,2171:47

properly [12] -2100:13, 2100:24,2105:31, 2171:46,2173:36, 2180:33,2181:8, 2189:15,2193:7, 2194:15,2194:23, 2201:43

properties [1] -2132:12

proportion [1] -2127:32

proposal [4] -2084:8, 2084:22,2136:28, 2140:32

proposed [2] -2120:8, 2207:7

proposing [1] -2182:17

proposition [2] -2100:22, 2151:31

prospect [1] - 2085:1proven [1] - 2127:38provide [10] -

2089:18, 2124:41,2132:10, 2138:11,2139:21, 2154:19,2160:26, 2160:27,2174:36, 2204:3

provided [38] -

2083:21, 2093:16,2093:25, 2114:19,2134:34, 2134:44,2139:25, 2139:35,2141:31, 2146:6,2154:46, 2155:26,2157:41, 2158:9,2159:10, 2163:17,2163:39, 2167:7,2169:28, 2169:47,2170:31, 2171:20,2171:40, 2172:22,2172:34, 2173:23,2178:38, 2185:18,2185:30, 2185:36,2188:5, 2189:30,2194:44, 2199:3,2200:6, 2201:19,2204:24, 2206:1

provides [3] -2132:13, 2144:19,2204:17

providing [5] -2114:23, 2136:17,2137:20, 2170:12,2172:39

provision [4] -2083:18, 2084:32,2205:31, 2213:35

provoked [2] -2166:39, 2166:41

provokes [1] -2155:31

PTT [60] - 2091:23,2100:39, 2100:46,2101:14, 2101:22,2109:41, 2111:18,2131:17, 2132:36,2132:42, 2133:6,2140:32, 2142:18,2143:22, 2145:1,2145:12, 2146:39,2148:5, 2149:24,2149:38, 2150:47,2151:10, 2151:20,2151:44, 2153:5,2153:24, 2153:41,2154:4, 2154:11,2154:16, 2154:28,2154:37, 2154:42,2155:2, 2155:5,2155:19, 2156:6,2156:39, 2159:2,2160:24, 2161:14,2169:6, 2174:6,2174:28, 2176:31,2181:20, 2181:27,2181:29, 2182:19,2182:34, 2184:11,2184:41, 2185:7,

2185:19, 2196:16,2199:13, 2200:23,2206:3, 2210:25,2212:17

PTT's [8] - 2140:47,2155:13, 2162:4,2162:8, 2170:32,2174:36, 2189:6,2204:46

PTT.9000.0002.0005 [1] - 2120:39

PTT.9000.0002.0043 [1] - 2120:46

PTT.9000.0005.0025 [1] - 2109:46

PTT.9000.0005.0026 [2] - 2111:42,2141:5

PTT.9000.0005.0233 [1] - 2104:17

PTT.9000.0005.0291 [1] - 2109:21

PTT.9001.0007.0346 [2] - 2095:5,2117:8

PTT.9001.0018.0043 [2] - 2163:30,2164:42

PTT.9002.0010.0038 [1] - 2156:29

PTT.9003.0070.0321 [1] - 2164:2

PTT.9006.0001.0003 [1] - 2091:41

PTTEP [3] - 2156:15,2167:37, 2182:33

PTTEP's [1] -2214:22

PTTEPAA [1] -2183:2

public [5] - 2083:8,2083:36, 2084:44,2085:3, 2208:4

publicly [1] -2083:21

publishing [1] -2215:12

pump [1] - 2090:24purely [1] - 2131:23purple [2] - 2095:6,

2101:8purported [1] -

2213:6purports [2] -

2174:36, 2210:7purposes [3] -

2088:11, 2101:39,2155:29

pursuant [4] -2107:1, 2137:32,

2138:25, 2145:28pursue [2] - 2085:20,

2128:24put [16] - 2083:12,

2083:26, 2087:2,2116:33, 2117:41,2145:27, 2158:1,2163:22, 2169:10,2171:14, 2171:22,2172:24, 2174:28,2183:29, 2185:42,2208:40

putting [2] - 2150:18,2173:45

Q

qualifications [4] -2191:13, 2196:21,2196:22, 2203:2

questionable [4] -2089:11, 2090:1,2090:31, 2090:32

questioning [2] -2083:4, 2190:32

questions [14] -2088:34, 2090:41,2090:45, 2095:42,2110:39, 2115:32,2116:47, 2119:5,2139:23, 2145:43,2153:4, 2195:9,2195:11, 2195:13

quickly [3] -2092:45, 2105:12,2181:17

quite [6] - 2133:31,2133:36, 2151:21,2161:24, 2171:42,2202:6

quote [2] - 2160:36,2204:39

R

R/D [1] - 2095:34raise [5] - 2083:4,

2100:38, 2100:46,2101:21, 2187:34

raised [3] - 2083:37,2105:46, 2166:39

raising [1] - 2173:9ramifications [1] -

2173:37rapidly [1] - 2097:37rather [16] - 2083:23,

2083:40, 2089:7,2094:9, 2094:11,2105:31, 2106:43,

2127:10, 2127:22,2150:1, 2150:34,2150:42, 2155:13,2157:34, 2185:35,2194:24

re [12] - 2116:5,2116:16, 2116:31,2116:38, 2125:41,2127:25, 2136:28,2143:22, 2144:32,2144:41, 2156:40,2156:46

re-entering [1] -2116:5

re-entry [10] -2116:16, 2116:31,2116:38, 2127:25,2136:28, 2143:22,2144:32, 2144:41,2156:40, 2156:46

re-evaluation [1] -2125:41

reached [1] -2116:39

read [50] - 2086:7,2088:33, 2092:2,2093:16, 2093:35,2094:39, 2095:9,2095:25, 2096:28,2105:28, 2118:10,2118:15, 2118:25,2118:30, 2118:40,2118:47, 2119:12,2121:1, 2121:3,2135:6, 2138:30,2139:5, 2139:22,2142:25, 2142:41,2146:3, 2146:9,2149:19, 2149:33,2149:35, 2166:36,2166:38, 2166:43,2166:46, 2174:41,2176:3, 2176:5,2176:7, 2176:8,2176:14, 2176:21,2176:22, 2188:4,2188:8, 2188:18,2188:27, 2189:2,2210:37, 2212:31,2212:32

reader [1] - 2093:41reading [13] -

2092:24, 2095:24,2102:21, 2118:7,2129:43, 2138:35,2142:23, 2146:28,2149:27, 2163:7,2165:16, 2165:25,2211:13

reads [1] - 2142:19


23

ready [2] - 2176:10,2181:21

real [6] - 2097:4,2099:36, 2124:9,2173:26, 2174:5,2180:31

realisation [1] -2144:24

realise [1] - 2102:26realised [4] -

2085:38, 2101:12,2110:5, 2143:22

realises [1] -2090:34

realising [2] -2102:25, 2173:10

really [31] - 2089:40,2099:13, 2099:40,2106:33, 2107:34,2109:31, 2115:5,2116:33, 2120:32,2131:36, 2131:37,2133:27, 2135:3,2140:1, 2143:12,2150:43, 2162:27,2162:33, 2164:35,2171:31, 2172:4,2179:30, 2186:32,2186:34, 2186:37,2192:9, 2198:31,2207:23, 2207:36,2207:39

reason [20] - 2084:7,2086:10, 2089:22,2089:45, 2090:1,2090:2, 2090:21,2090:30, 2090:38,2091:1, 2094:29,2100:46, 2112:9,2128:13, 2159:15,2172:20, 2181:34,2184:27, 2199:10

reasonable [3] -2102:18, 2121:42,2121:44

reasonably [2] -2124:8, 2175:43

reasons [3] - 2091:8,2128:3, 2172:23

rebumped [2] -2088:3, 2088:6

receipt [1] - 2154:44receive [9] -

2188:41, 2200:47,2201:5, 2201:23,2201:26, 2201:29,2201:31, 2201:35,2201:39

received [19] -2091:35, 2092:8,

2094:30, 2094:44,2096:44, 2100:30,2102:29, 2102:30,2119:1, 2120:25,2120:36, 2130:2,2140:7, 2141:20,2154:26, 2164:25,2164:29, 2201:27,2212:15

receiving [4] -2092:5, 2103:20,2119:2, 2174:46

recently [3] -2085:42, 2112:23,2205:23

recognise [24] -2091:44, 2092:8,2095:14, 2104:17,2111:42, 2117:10,2118:44, 2120:16,2120:42, 2121:9,2134:17, 2134:23,2134:28, 2135:1,2135:3, 2141:6,2141:38, 2143:47,2166:10, 2170:7,2174:1, 2174:23,2200:11, 2210:14

recognised [1] -2101:17

recognising [1] -2102:6

recollection [8] -2093:31, 2122:40,2129:47, 2176:20,2179:40, 2199:23,2199:25, 2202:36

recommend [1] -2116:8

recommendation [9]

- 2112:17, 2113:18,2119:19, 2156:18,2201:9, 2206:10,2206:11, 2206:20,2206:24

recommendations[3] - 2113:39, 2203:10,2204:16

recommended [6] -2103:23, 2110:11,2127:44, 2151:9,2156:16, 2206:13

recommending [4] -2130:12, 2135:47,2155:46, 2207:1

record [15] - 2090:9,2092:36, 2102:47,2144:46, 2151:24,2153:30, 2153:40,2153:43, 2182:35,

2182:46, 2183:11,2183:35, 2200:3,2214:20, 2214:22

recorded [2] -2153:23, 2153:35

recording [1] -2154:28

records [9] - 2145:2,2154:3, 2154:10,2154:15, 2154:19,2154:27, 2199:40,2199:45

Recover [1] -2106:13

recover [1] - 2157:5recovered [2] -

2108:33, 2108:44recruit [1] - 2188:5rectify [1] - 2089:32redacted [1] -

2091:42redid [1] - 2088:7reduce [4] - 2110:21,

2110:22, 2110:33,2110:47

reduced [1] -2156:34

redundancy [2] -2128:5, 2128:9

refer [6] - 2119:28,2119:33, 2119:38,2119:42, 2142:45,2207:3

reference [15] -2089:30, 2094:14,2095:12, 2104:12,2104:22, 2108:39,2109:18, 2111:47,2134:41, 2134:43,2148:25, 2149:3,2165:11, 2186:33,2211:26

referenced [1] -2178:38

referred [9] -2092:32, 2121:19,2122:6, 2124:15,2130:43, 2172:29,2203:20, 2204:38,2206:2

referring [14] -2091:34, 2104:28,2119:7, 2143:13,2164:43, 2164:47,2168:10, 2183:2,2187:8, 2192:4,2192:10, 2204:28,2205:21, 2206:42

refers [3] - 2121:6,2142:43, 2207:2

refinement [1] -2083:29

reflect [8] - 2105:28,2111:32, 2114:33,2127:25, 2128:33,2153:19, 2153:36,2216:30

reflected [8] -2096:37, 2103:4,2113:43, 2118:44,2140:20, 2163:16,2173:22, 2205:10

reflecting [2] -2187:20, 2216:12

reflection [6] -2114:16, 2114:18,2154:47, 2173:34,2180:10, 2205:40

reflective [2] -2173:1, 2173:3

reflects [8] -2106:44, 2114:36,2156:45, 2158:7,2171:13, 2177:37,2186:37, 2187:29

regard [10] -2094:20, 2101:42,2111:25, 2112:7,2112:9, 2112:11,2119:33, 2139:24,2157:39, 2177:24

regarded [4] -2101:38, 2130:45,2131:36, 2132:11

regarding [1] -2156:21

regardless [3] -2151:17, 2151:43,2198:44

regime [14] -2177:26, 2177:32,2177:47, 2186:4,2186:9, 2186:13,2192:43, 2193:37,2208:17, 2208:23,2208:24, 2208:34,2208:42, 2216:17

regulation [4] -2144:1, 2144:27,2150:8, 2176:14

Regulations [1] -2204:37

regulations [20] -2119:21, 2119:29,2119:30, 2135:21,2143:43, 2173:5,2174:15, 2176:8,2176:14, 2176:38,2178:9, 2178:35,2185:2, 2185:14,

2188:11, 2191:9,2192:24, 2192:34,2204:42, 2206:35

regulator [39] -2098:15, 2099:43,2136:24, 2137:8,2137:15, 2137:38,2137:42, 2138:31,2138:40, 2139:8,2139:45, 2140:3,2140:12, 2140:24,2143:3, 2143:4,2143:17, 2143:37,2143:41, 2145:1,2147:19, 2150:11,2150:37, 2151:11,2151:14, 2169:42,2176:26, 2176:37,2178:18, 2178:24,2185:45, 2187:14,2191:18, 2191:47,2192:43, 2193:36,2193:47, 2194:6

regulators [9] -2139:26, 2139:32,2139:46, 2140:25,2140:31, 2186:17,2186:22, 2186:31,2194:7

regulatory [16] -2100:43, 2113:24,2127:44, 2155:40,2155:46, 2173:27,2177:26, 2177:32,2179:13, 2186:4,2186:13, 2187:17,2187:26, 2192:42,2208:16, 2209:16

Regulatory [1] -2191:7

reinforced [1] -2101:10

reinstall [1] -2149:13

reinstallation [4] -2147:23, 2149:5,2149:40, 2150:7

reinstalled [3] -2144:38, 2159:26,2164:14

reinstalling [1] -2165:11

reinvent [1] -2182:21

relate [1] - 2094:11related [3] - 2093:17,

2094:17, 2115:32relating [10] -

2092:9, 2094:47,2121:10, 2141:38,


24

2153:31, 2153:42,2160:43, 2201:44,2203:2, 2206:43

relation [58] -2091:6, 2112:23,2120:4, 2121:41,2127:24, 2128:38,2128:39, 2132:28,2133:5, 2134:43,2135:15, 2136:18,2136:19, 2137:4,2137:20, 2137:31,2138:25, 2139:33,2140:26, 2144:11,2144:13, 2150:26,2155:41, 2156:39,2157:23, 2171:29,2173:28, 2174:6,2174:28, 2174:29,2175:31, 2176:44,2179:42, 2180:24,2180:30, 2181:42,2184:5, 2184:41,2185:22, 2185:45,2186:3, 2193:25,2197:41, 2199:12,2200:6, 2202:15,2202:20, 2202:32,2203:15, 2203:35,2204:25, 2204:41,2209:16, 2209:22,2209:41, 2210:26,2212:24

relationship [2] -2182:33, 2184:9

relationships [1] -2186:30

relative [2] - 2194:5,2194:7

relatively [1] -2194:2

release [3] -2160:28, 2162:36,2169:32

Release [5] -2166:30, 2167:26,2168:7, 2168:28,2170:43

released [2] -2083:21, 2215:43

relevant [29] -2098:22, 2104:18,2106:4, 2112:42,2112:46, 2113:5,2133:32, 2135:12,2136:32, 2145:12,2166:17, 2166:19,2166:40, 2173:20,2176:38, 2178:31,2178:33, 2178:36,

2178:45, 2179:4,2186:30, 2196:35,2196:37, 2205:31,2205:37, 2206:34,2206:39, 2213:35,2216:14

reliability [1] -2105:47

reliable [1] - 2132:2reliant [1] - 2185:18relied [3] - 2094:32,

2110:26, 2112:13relief [16] - 2161:11,

2161:32, 2162:12,2162:14, 2174:29,2176:39, 2180:13,2180:15, 2180:24,2180:29, 2181:1,2181:5, 2181:26,2181:32, 2182:10,2182:12

relieve [1] - 2085:5relieved [1] -

2213:20rely [4] - 2139:9,

2139:16, 2140:17,2204:41

relying [3] - 2127:10,2130:20, 2185:35

remain [1] - 2114:40remained [1] -

2124:26remains [1] -

2090:29remedial [5] -

2089:38, 2089:42,2091:10, 2112:33,2112:38

remediate [5] -2089:8, 2089:10,2089:13, 2089:25,2090:18

remediation [1] -2089:31

remember [6] -2153:11, 2153:16,2177:2, 2183:4,2186:32, 2187:40

reminded [1] -2181:23

removal [18] -2122:19, 2125:10,2144:37, 2145:20,2145:28, 2145:35,2146:20, 2148:11,2148:12, 2149:3,2149:12, 2149:39,2150:6, 2158:15,2165:5, 2167:45,2167:47, 2189:46

remove [5] -2124:45, 2147:21,2156:8, 2159:3,2159:20

removed [21] -2122:13, 2122:17,2123:17, 2123:23,2123:42, 2125:3,2125:39, 2144:33,2145:36, 2151:35,2157:15, 2157:25,2157:33, 2157:42,2158:10, 2158:27,2158:28, 2158:36,2158:41, 2158:42,2164:13

removing [5] -2108:10, 2150:30,2151:7, 2158:19,2158:20

repeat [17] -2089:28, 2093:38,2098:38, 2103:6,2108:3, 2115:43,2119:26, 2122:16,2128:41, 2129:8,2133:34, 2134:4,2145:30, 2149:7,2164:26, 2170:19,2180:27

repeated [1] - 2181:5rephrase [1] -

2205:45replacement [1] -

2189:45replied [1] - 2179:31report [49] - 2083:14,

2083:19, 2084:28,2084:32, 2085:16,2086:7, 2088:37,2094:21, 2094:30,2094:32, 2094:39,2095:1, 2095:4,2095:14, 2095:18,2096:21, 2096:37,2096:45, 2098:26,2100:6, 2100:30,2101:17, 2102:19,2102:30, 2115:32,2117:9, 2117:14,2118:7, 2118:21,2118:30, 2118:41,2119:2, 2129:33,2130:2, 2141:38,2142:29, 2142:33,2143:3, 2143:25,2165:42, 2167:7,2172:5, 2172:19,2172:21, 2173:36,2185:10, 2188:8,

2188:19, 2188:28reported [3] -

2142:36, 2148:45,2188:9

reports [7] -2102:23, 2154:45,2161:36, 2187:45,2188:4, 2188:36,2188:41

representation [1] -2190:5

representatives [2] -2083:11, 2084:15

represented [3] -2141:17, 2175:42,2208:38

represents [2] -2117:19, 2185:39

reputation [1] -2184:24

request [2] -2163:17, 2198:39

requested [6] -2120:25, 2120:30,2120:35, 2154:7,2216:2

require [11] - 2087:3,2120:10, 2126:10,2127:12, 2128:5,2128:8, 2138:11,2185:2, 2187:44,2192:34, 2206:38

required [11] -2103:15, 2145:22,2151:19, 2165:28,2173:5, 2175:38,2175:44, 2190:26,2204:42, 2206:33,2214:35

requirement [4] -2138:33, 2179:8,2214:16, 2215:44

requirements [69] -2119:20, 2119:28,2127:23, 2127:25,2135:21, 2166:19,2174:15, 2177:38,2178:34, 2187:17,2204:19, 2205:1,2205:2, 2205:44,2206:6, 2206:30,2206:43, 2206:45,2208:23, 2208:29,2208:33, 2209:16,2209:18, 2209:23,2209:24, 2209:26,2210:9, 2210:28,2210:36, 2210:41,2211:15, 2211:38,2211:44, 2212:16,

2212:23, 2212:30,2212:31, 2212:36,2212:39, 2213:1,2213:7, 2213:14,2213:19, 2213:22,2213:30, 2213:33,2213:43, 2213:47,2214:4, 2214:9,2214:29, 2214:35,2214:38, 2214:42,2215:3, 2215:6,2215:10, 2215:17,2215:23, 2215:33,2215:34, 2215:36,2215:42, 2215:46,2215:47, 2216:2,2216:4, 2216:21

Requirements [3] -2210:39, 2211:4,2211:8

requires [4] -2143:40, 2173:40,2194:35, 2212:32

requisitions [1] -2199:41

research [2] -2191:9, 2197:30

researched [1] -2129:26

reservoir [5] -2098:7, 2098:12,2098:17, 2131:13,2132:46

resile [1] - 2186:8resource [1] -

2196:43resourced [12] -

2174:14, 2189:17,2189:24, 2190:19,2190:24, 2190:30,2192:34, 2193:7,2193:29, 2194:12,2194:27, 2194:30

Resources [17] -2136:12, 2153:6,2159:39, 2190:19,2191:40, 2196:5,2203:25, 2210:8,2210:24, 2211:37,2211:44, 2212:37,2213:6, 2213:12,2213:42, 2214:10,2214:29

resources [10] -2188:11, 2188:15,2188:18, 2188:34,2189:29, 2190:14,2194:14, 2194:16,2194:17, 2194:45

resourcing [2] -


25

2174:17, 2189:27respect [4] -

2115:41, 2148:24,2186:47, 2216:31

respond [3] -2083:12, 2083:45,2194:14

responded [1] -2147:33

responding [1] -2176:26

response [10] -2120:36, 2161:3,2163:16, 2163:27,2163:30, 2167:37,2167:39, 2179:24,2179:28, 2180:1

responses [1] -2084:36

responsibilities [1] -2191:8

responsibility [2] -2180:8, 2192:41

responsible [6] -2174:11, 2189:26,2190:20, 2208:4,2208:6, 2214:27

rest [2] - 2156:36,2195:24

result [2] - 2083:28,2135:1

resume [2] -2115:27, 2152:4

resumes [1] - 2083:3RESUMPTION [1] -

2153:1RET [3] - 2160:34,

2215:14, 2216:25RET's [1] - 2216:21return [4] - 2090:11,

2141:5, 2164:41,2187:25

returned [2] -2093:2, 2160:21

returning [2] -2117:9, 2206:28

review [3] - 2103:36,2161:36, 2161:39

reviewed [3] -2096:26, 2187:21,2202:29

reviewing [2] -2104:36, 2184:46

reviews [1] - 2193:15revised [1] - 2148:28revisited [1] - 2117:4revocation [8] -

2208:29, 2208:32,2209:24, 2214:41,2215:8, 2215:9,

2215:28, 2215:42revocations [3] -

2215:2, 2216:22,2216:30

revoke [1] - 2215:33revoked [15] -

2178:9, 2178:13,2213:14, 2213:23,2214:1, 2214:13,2214:16, 2214:37,2214:39, 2215:18,2215:26, 2215:27,2215:34, 2215:36,2216:1

rid [1] - 2156:35rig [33] - 2095:34,

2095:36, 2102:26,2111:30, 2114:29,2114:34, 2114:37,2114:39, 2115:7,2115:12, 2115:14,2126:3, 2126:22,2126:26, 2126:30,2126:38, 2126:40,2126:46, 2127:1,2127:11, 2129:1,2137:38, 2137:45,2145:11, 2145:14,2149:11, 2165:3,2181:21, 2189:44,2194:37, 2195:6,2202:46

rigorous [4] -2185:1, 2185:5,2189:25, 2194:34

risk [15] - 2097:4,2097:6, 2097:25,2097:35, 2126:31,2136:44, 2137:4,2138:12, 2138:20,2140:19, 2144:13,2201:36, 2201:38,2208:11, 2209:4

risks [3] - 2209:3,2209:7, 2209:11

roadmap [1] - 2177:6robust [2] - 2185:1,

2194:34rocket [2] - 2169:9,

2180:37role [11] - 2099:45,

2114:24, 2155:18,2202:16, 2202:35,2203:38, 2207:38,2207:46, 2208:3,2208:10, 2214:27

root [2] - 2166:32,2169:36

rough [2] - 2124:8,2124:10

round [1] - 2088:22RTTS [2] - 2126:41rule [2] - 2084:39,

2090:26run [6] - 2087:22,

2107:4, 2107:5,2108:9, 2108:11,2108:32

rung [1] - 2110:31running [1] - 2107:5rusted [1] - 2159:18

S

S-A-J-D-A-K [1] -2204:1

safely [2] - 2107:17,2181:32

safer [1] - 2128:28safety [2] - 2191:8,

2209:19Sajdak [3] - 2203:45,

2204:3, 2204:11sake [1] - 2110:22salutary [1] -

2127:17Santa [1] - 2190:46satisfied [8] -

2094:45, 2095:40,2095:44, 2135:41,2192:19, 2192:20,2197:46, 2205:43

satisfies [1] -2178:17

satisfy [7] - 2178:24,2184:24, 2204:19,2205:1, 2206:5,2206:29, 2209:18

saw [1] - 2091:28scenario [1] - 2138:3scenarios [3] -

2137:27, 2137:28,2137:31

schedule [8] -2210:28, 2211:3,2211:8, 2211:14,2211:22, 2211:27,2215:46, 2216:20

scheduled [3] -2145:28, 2145:34,2145:45

schematics [1] -2160:26

schools [1] -2176:43

science [1] - 2169:9screen [5] - 2149:34,

2178:29, 2190:38,2205:23, 2209:43

scroll [39] - 2085:22,2091:41, 2091:43,2092:4, 2093:46,2096:20, 2109:26,2109:46, 2111:46,2119:36, 2120:16,2120:21, 2120:40,2120:47, 2134:19,2134:27, 2136:23,2137:25, 2141:42,2147:14, 2148:40,2149:30, 2149:31,2163:34, 2164:42,2170:6, 2174:33,2174:40, 2175:35,2176:2, 2176:13,2191:22, 2191:35,2200:14, 2201:14,2205:27, 2209:30,2209:44, 2210:9

scrolling [2] -2174:39, 2176:19

scrolls [1] - 2137:19scrutinise [5] -

2094:46, 2130:17,2134:12, 2172:25,2192:16

scrutinised [4] -2173:7, 2173:12,2173:21, 2181:19

scrutinising [2] -2098:22, 2189:14

scrutiny [12] -2118:37, 2118:38,2155:21, 2169:43,2171:43, 2173:39,2173:43, 2174:5,2187:44, 2190:26

search [1] - 2154:26searches [2] -

2154:7, 2212:1seated [1] - 2186:38seawater [13] -

2112:1, 2112:5,2130:32, 2130:44,2131:5, 2131:19,2131:34, 2132:9,2132:22, 2132:29,2133:8, 2148:21,2148:25

second [11] - 2092:3,2093:36, 2094:42,2096:21, 2105:16,2105:27, 2113:11,2128:10, 2140:37,2165:1, 2210:21

second-last [1] -2140:37

secondary [4] -2089:41, 2091:12,

2101:36, 2101:38seconded [1] -

2197:26secondly [1] -

2147:21Section [1] - 2190:44section [8] - 2106:8,

2108:37, 2109:19,2109:26, 2206:37,2207:2, 2212:33,2213:36

sections [4] -2178:31, 2178:33,2204:27, 2204:30

secure [1] - 2106:39security [3] - 2149:6,

2149:14, 2167:8see [110] - 2088:27,

2090:20, 2090:25,2092:38, 2093:47,2095:34, 2096:22,2111:27, 2111:46,2120:21, 2120:27,2125:44, 2136:5,2136:7, 2136:16,2136:20, 2136:23,2136:29, 2136:31,2136:35, 2136:39,2136:40, 2136:47,2137:1, 2137:10,2137:13, 2137:19,2137:23, 2137:26,2137:29, 2137:37,2138:6, 2138:8,2138:17, 2138:47,2139:6, 2141:42,2142:3, 2142:10,2144:5, 2144:19,2145:5, 2145:23,2145:24, 2146:26,2146:43, 2147:12,2147:14, 2147:26,2147:27, 2147:40,2147:42, 2147:45,2148:41, 2148:46,2148:47, 2149:21,2151:34, 2154:2,2156:5, 2156:24,2156:34, 2156:36,2157:2, 2157:9,2159:13, 2162:25,2166:15, 2167:6,2167:16, 2167:28,2167:34, 2168:9,2168:17, 2168:30,2168:31, 2170:35,2171:25, 2174:34,2174:37, 2174:41,2174:44, 2175:2,2175:16, 2175:17,


26

2175:24, 2175:36,2175:40, 2176:3,2182:20, 2185:11,2191:23, 2191:29,2191:36, 2192:38,2192:47, 2193:18,2193:40, 2199:46,2200:15, 2205:27,2206:11, 2206:17,2210:7, 2210:21,2210:31, 2210:42,2210:45, 2211:10,2211:11

seeing [3] - 2133:16,2200:5, 2204:20

seek [4] - 2091:11,2126:31, 2137:8,2196:32

seeking [11] -2086:46, 2091:6,2174:27, 2201:5,2204:25, 2204:33,2205:11, 2205:15,2206:2, 2206:4

seem [5] - 2114:11,2142:21, 2186:32,2190:31, 2207:24

seminars [1] -2196:28

send [1] - 2184:46sending [2] -

2174:42, 2214:10sense [2] - 2084:4,

2201:18sensible [1] -

2133:12sent [6] - 2091:45,

2102:47, 2174:26,2175:22, 2197:12,2213:13

sentence [5] -2165:1, 2170:38,2178:28, 2205:10,2206:25

sentences [1] -2205:13

September [3] -2174:42, 2196:8,2209:36

sequence [11] -2087:10, 2088:22,2145:21, 2146:27,2148:12, 2149:40,2158:44, 2164:17,2164:39, 2184:21,2216:4

sequencing [1] -2115:7

serious [1] - 2182:45served [1] - 2191:7

Service [2] -2190:46, 2191:17

set [5] - 2083:9,2108:10, 2109:24,2182:5, 2210:28

seven [3] - 2099:32,2156:38, 2158:7

seven-day [2] -2156:38, 2158:7

several [5] -2146:47, 2196:22,2196:38, 2205:12,2216:8

shall [1] - 2211:5shape [1] - 2183:28shared [2] - 2160:8,

2160:12sharing [1] - 2186:36sharper [1] - 2084:25sharply [1] - 2083:31shaved [1] - 2109:33shed [1] - 2172:23ships [1] - 2084:5shoe [113] - 2086:1,

2086:8, 2086:19,2086:43, 2087:1,2087:7, 2087:19,2087:29, 2087:32,2087:38, 2087:42,2087:46, 2087:47,2088:10, 2088:39,2089:2, 2089:6,2089:8, 2089:26,2089:32, 2089:38,2090:8, 2090:14,2090:19, 2090:27,2090:29, 2090:36,2090:47, 2091:2,2091:9, 2091:25,2092:10, 2092:21,2093:27, 2094:23,2095:45, 2096:15,2096:40, 2096:47,2097:10, 2097:41,2098:7, 2098:11,2098:16, 2100:11,2100:23, 2101:19,2101:43, 2102:36,2102:42, 2103:9,2110:9, 2110:10,2110:24, 2110:27,2110:36, 2111:2,2112:18, 2112:22,2112:29, 2114:29,2115:42, 2115:47,2116:3, 2116:30,2116:37, 2117:29,2117:33, 2117:38,2117:44, 2118:11,2118:12, 2118:17,

2118:25, 2123:31,2124:37, 2124:42,2125:8, 2125:22,2125:34, 2125:35,2129:7, 2129:11,2129:15, 2129:28,2129:37, 2130:14,2130:21, 2130:24,2130:32, 2133:39,2134:1, 2134:8,2135:29, 2135:32,2139:10, 2139:11,2148:20, 2150:33,2157:24, 2157:29,2158:14, 2159:7,2162:41, 2163:1,2163:2, 2165:23,2165:33, 2166:2,2167:22, 2182:10,2212:26

short [3] - 2095:42,2114:27, 2199:7

SHORT [1] - 2115:29shorten [1] - 2084:29shortly [8] - 2124:44,

2125:2, 2125:9,2125:36, 2125:38,2157:24, 2158:12,2161:30

show [5] - 2133:16,2145:4, 2163:38,2164:10, 2190:36

showed [1] -2163:17

shown [4] - 2092:47,2093:4, 2093:7,2205:23

shows [7] - 2096:35,2096:39, 2100:6,2129:33, 2141:9,2164:4, 2164:8

sift [1] - 2171:47sighting [1] -

2178:31sign [1] - 2210:3signatory [1] -

2209:27signature [1] -

2197:36signed [6] - 2175:36,

2197:43, 2197:46,2200:15, 2200:19,2201:19

significance [7] -2106:38, 2113:29,2150:9, 2150:36,2150:42, 2158:22,2158:25

significant [21] -2096:39, 2099:12,

2101:18, 2112:22,2113:23, 2127:32,2132:28, 2132:35,2133:7, 2143:19,2144:12, 2146:39,2147:37, 2148:5,2149:5, 2149:13,2159:31, 2159:38,2180:44, 2208:16,2208:19

significantly [1] -2185:44

signified [4] -2117:18, 2143:23,2197:47, 2199:3

signifies [3] -2098:44, 2127:10,2158:46

signify [6] - 2092:28,2106:15, 2142:5,2142:18, 2198:40,2200:22

signing [4] -2170:30, 2189:45,2206:14, 2207:17

signs [1] - 2197:13similar [3] - 2124:1,

2189:44, 2205:23simple [1] - 2187:37simply [1] - 2206:11single [2] - 2113:19,

2162:30sit [5] - 2117:3,

2122:40, 2135:19,2135:46, 2195:24

site [3] - 2184:42,2216:21, 2216:25

sitting [3] - 2126:17,2169:40, 2207:28

situ [2] - 2101:38,2113:13

situation [30] -2088:5, 2088:20,2088:25, 2089:20,2098:16, 2099:25,2102:9, 2102:16,2111:37, 2113:17,2113:39, 2129:1,2129:2, 2132:37,2137:27, 2137:44,2141:30, 2150:41,2150:43, 2151:17,2151:30, 2171:13,2173:30, 2174:10,2183:41, 2184:18,2189:44, 2204:14,2207:37, 2207:43

situations [2] -2102:21, 2135:30

six [4] - 2096:7,

2111:13, 2188:47,2189:5

size [3] - 2142:43,2156:34, 2185:25

skidded [1] -2157:10

skills [5] - 2118:23,2195:5, 2201:43,2202:9, 2203:15

skimming [1] -2095:33

slight [3] - 2092:18,2093:20, 2145:21

slightly [5] -2091:41, 2091:44,2092:4, 2111:46,2205:27

slowly [7] - 2093:46,2120:47, 2136:23,2137:25, 2163:34,2174:41, 2176:2

slurry [1] - 2097:14smaller [1] - 2201:29Smith [1] - 2195:46solely [3] - 2185:18,

2185:36, 2190:20Solicitor [1] -

2154:34Solicitor-General [1]

- 2154:34someone [10] -

2118:23, 2125:41,2146:39, 2148:5,2174:10, 2188:5,2188:32, 2194:35,2195:5, 2204:4

sometimes [6] -2188:45, 2201:31,2201:32, 2202:25,2204:27, 2205:36

somewhat [1] -2126:6

soon [8] - 2102:3,2114:45, 2115:16,2125:29, 2147:5,2181:22, 2181:28

sorry [45] - 2087:43,2089:28, 2090:43,2093:38, 2094:14,2096:37, 2103:6,2106:11, 2106:35,2108:3, 2111:34,2119:26, 2119:40,2122:16, 2123:17,2123:24, 2123:39,2126:24, 2126:34,2128:41, 2129:8,2131:30, 2133:34,2134:4, 2135:24,2137:40, 2138:35,


27

2138:37, 2138:38,2142:8, 2145:30,2148:30, 2148:37,2149:7, 2149:27,2150:43, 2157:28,2164:23, 2164:26,2170:14, 2170:19,2186:10, 2189:45,2215:45

sort [3] - 2084:8,2107:31, 2200:46

sorted [1] - 2131:11sorts [4] - 2084:12,

2132:24, 2181:2,2208:12

sought [7] - 2159:3,2198:10, 2198:29,2199:2, 2199:13,2199:17, 2200:23

sound [7] - 2091:26,2119:33, 2119:43,2120:11, 2128:4,2128:8, 2183:6

sounds [1] - 2183:8speaking [4] -

2115:1, 2163:31,2178:1, 2184:47

spear" [1] - 2106:13special [1] - 2097:40Specific [3] -

2210:39, 2211:4,2211:8

specific [58] -2103:28, 2103:31,2103:33, 2103:37,2114:20, 2132:34,2177:38, 2192:11,2197:28, 2200:32,2208:29, 2208:33,2209:15, 2209:23,2209:24, 2209:25,2209:46, 2210:9,2210:41, 2211:15,2211:37, 2211:44,2212:16, 2212:23,2212:29, 2212:31,2212:36, 2212:39,2212:47, 2213:3,2213:7, 2213:14,2213:19, 2213:22,2213:30, 2213:33,2213:43, 2213:47,2214:4, 2214:9,2214:16, 2214:28,2214:34, 2214:38,2214:41, 2215:2,2215:6, 2215:9,2215:17, 2215:23,2215:33, 2215:34,2215:42, 2215:46,

2216:3, 2216:12,2216:20, 2216:28

specifically [12] -2091:36, 2114:3,2118:21, 2119:18,2126:14, 2129:40,2134:47, 2143:42,2160:40, 2164:12,2164:47, 2166:35

specifics [2] -2181:35, 2181:37

speculate [2] -2191:41, 2192:9

speculating [1] -2110:18

spell [1] - 2203:47spoken [3] - 2144:2,

2161:40, 2204:46spud [1] - 2181:21squeeze [6] -

2089:16, 2089:30,2091:30, 2091:37,2092:33

Squire [1] - 2160:34ST1 [1] - 2165:4staff [2] - 2190:42,

2200:3stage [26] - 2083:41,

2084:28, 2086:19,2089:10, 2089:13,2095:45, 2102:31,2102:33, 2102:35,2102:41, 2103:1,2103:4, 2104:43,2105:9, 2107:34,2108:20, 2108:25,2110:1, 2110:11,2111:43, 2112:16,2113:6, 2115:39,2115:45, 2190:8,2194:19

stages [1] - 2090:17stand [2] - 2182:28,

2182:30standard [5] -

2090:26, 2139:36,2139:39, 2139:40,2139:41

standards [16] -2111:19, 2111:22,2111:26, 2111:28,2162:5, 2162:21,2178:46, 2179:15,2179:16, 2180:21,2183:38, 2184:45,2185:38, 2189:37,2192:17, 2207:11

stands [1] - 2175:27start [7] - 2104:41,

2106:18, 2106:36,

2164:43, 2170:6,2175:19, 2208:18

started [10] -2085:15, 2106:33,2106:35, 2108:43,2147:7, 2160:33,2161:4, 2161:7,2182:20, 2198:28

starting [1] - 2108:35starts [1] - 2106:8state [7] - 2102:17,

2111:17, 2113:34,2113:38, 2114:9,2124:25, 2137:5

statement [37] -2085:19, 2085:23,2085:30, 2095:11,2103:14, 2113:28,2113:30, 2113:32,2113:43, 2114:2,2114:17, 2119:11,2128:4, 2130:29,2130:43, 2145:10,2145:19, 2146:5,2146:25, 2148:9,2148:24, 2148:28,2148:43, 2156:27,2157:46, 2164:47,2166:23, 2170:7,2171:1, 2171:20,2178:29, 2178:42,2182:37, 2193:3,2193:43, 2198:35,2212:20

statements [4] -2083:36, 2166:7,2168:13, 2168:38

states [2] - 2144:5,2179:14

States [2] - 2190:41,2191:18

static [1] - 2097:9status [8] - 2130:42,

2131:4, 2131:40,2132:2, 2132:8,2133:32, 2160:26,2198:5

statutory [8] -2146:19, 2170:12,2170:17, 2170:21,2170:26, 2170:30,2170:38, 2171:11

step [7] - 2084:33,2106:13, 2108:32,2108:35, 2108:44,2108:47, 2109:1

steps [23] - 2088:38,2089:25, 2090:18,2099:17, 2100:38,2101:5, 2105:10,

2105:15, 2109:7,2109:11, 2110:12,2121:10, 2124:11,2126:30, 2126:38,2155:17, 2158:23,2160:18, 2160:31,2181:46, 2182:4,2187:24, 2215:41

still [21] - 2087:25,2096:3, 2107:17,2109:33, 2115:15,2123:4, 2147:35,2162:24, 2169:29,2171:22, 2172:23,2172:24, 2173:21,2182:34, 2183:40,2198:39, 2199:8,2203:11, 2213:31,2214:2

stop [10] - 2126:39,2138:1, 2138:14,2138:24, 2162:31,2162:37, 2162:41,2163:35, 2164:42,2206:6

Storrie [1] - 2084:47story [2] - 2102:20,

2167:12straight [1] - 2104:22Street [2] - 2082:26,

2195:46strength [1] -

2086:35stretch [1] - 2111:20stretching [1] -

2099:40string [3] - 2108:33,

2124:44, 2174:33strings [1] - 2147:8Struck [5] - 2202:37,

2202:42, 2203:14,2203:20, 2204:4

structure [1] -2183:17

struggle [3] -2158:13, 2189:34,2190:25

studied [1] - 2196:37stuff [2] - 2161:41,

2180:8style [1] - 2182:19subconsciously [1] -

2086:23subject [8] - 2083:7,

2083:24, 2084:37,2094:47, 2107:38,2128:43, 2170:34,2204:32

SUBM.4000.0001.0001 [3] - 2134:16,

2166:9, 2167:15Submerged [2] -

2204:36, 2213:36submission [23] -

2134:18, 2134:25,2134:34, 2134:39,2135:11, 2135:37,2136:5, 2138:47,2166:8, 2166:10,2166:15, 2166:26,2167:6, 2167:43,2169:28, 2169:35,2169:47, 2172:22,2172:29, 2172:34,2172:39, 2201:8,2212:19

submissions [8] -2083:9, 2083:12,2083:13, 2083:26,2084:2, 2084:12,2202:30, 2212:15

submit [2] - 2151:23,2182:19

submitted [10] -2154:44, 2162:12,2166:11, 2167:18,2168:18, 2176:30,2201:6, 2201:45,2207:12, 2207:20

submitting [1] -2083:14

subsequently [5] -2099:2, 2105:20,2124:17, 2124:18,2148:24

substance [2] -2146:27, 2150:1

successfully [2] -2161:14

sudden [2] -2096:39, 2112:29

sufficient [11] -2101:20, 2161:4,2167:8, 2170:32,2173:35, 2176:20,2176:36, 2194:16,2194:17, 2194:44,2202:9

sufficiently [1] -2176:15

suggest [63] -2086:34, 2087:13,2096:2, 2098:20,2098:35, 2098:41,2103:3, 2105:37,2106:6, 2108:15,2111:1, 2114:39,2115:14, 2116:14,2119:44, 2120:3,2121:36, 2122:4,


28

2122:5, 2122:11,2127:33, 2128:3,2130:20, 2135:27,2139:31, 2142:21,2143:14, 2144:47,2148:16, 2150:27,2153:30, 2165:28,2165:40, 2167:6,2168:36, 2169:9,2169:15, 2171:7,2172:20, 2172:44,2173:38, 2174:3,2174:26, 2175:42,2177:17, 2177:23,2181:25, 2181:31,2183:6, 2185:35,2186:12, 2186:29,2186:32, 2187:39,2188:13, 2189:17,2192:21, 2192:27,2194:5, 2197:37,2200:29, 2200:36,2200:41

suggested [10] -2100:47, 2106:5,2116:24, 2143:24,2144:26, 2149:2,2157:14, 2192:28,2205:36, 2216:7

suggesting [16] -2135:36, 2140:30,2142:34, 2143:2,2148:11, 2149:39,2156:41, 2157:36,2171:2, 2176:35,2178:45, 2183:31,2187:40, 2189:13,2192:13, 2207:36

suggestion [4] -2098:43, 2159:29,2176:3, 2177:31

suggestions [1] -2179:33

suggests [19] -2094:9, 2098:26,2103:9, 2105:31,2127:22, 2140:8,2140:12, 2143:14,2156:38, 2157:13,2162:36, 2169:46,2171:35, 2174:4,2185:30, 2185:43,2186:22, 2200:42,2211:13

suitable [1] -2216:34

sum [1] - 2155:3summarising [1] -

2095:18summary [5] -

2149:37, 2149:41,2149:46, 2192:26,2192:32

summation [1] -2153:45

Sunday [2] -2091:35, 2092:2

supervisor [7] -2099:16, 2173:17,2179:35, 2181:10,2181:23, 2182:25,2187:34

Supervisor [1] -2190:45

supervisors [1] -2189:27

supplement [1] -2094:42

support [3] -2175:21, 2189:45,2191:9

supports [1] -2186:28

supposed [3] -2096:46, 2097:4,2185:8

supposition [1] -2214:12

suppositions [1] -2088:33

surely [2] - 2182:15,2192:7

surface [1] - 2106:13surname [1] -

2203:47surprise [2] -

2129:19, 2130:4surprised [1] -

2186:27surrounding [1] -

2168:47Survey [1] - 2190:45survey [2] - 2188:23,

2196:23surveying [1] -

2196:24suspect [1] -

2202:13suspend [8] -

2102:35, 2103:43,2105:41, 2106:8,2106:12, 2141:11,2141:21, 2141:25

suspended [11] -2096:8, 2101:44,2103:17, 2106:1,2110:2, 2113:18,2116:21, 2126:3,2141:16, 2141:26,2164:36

suspending [3] -2096:6, 2125:43,2126:1

suspension [48] -2088:11, 2088:25,2096:17, 2101:39,2102:11, 2102:31,2102:42, 2103:1,2103:5, 2103:23,2104:43, 2105:9,2106:42, 2108:25,2110:1, 2110:11,2111:27, 2111:42,2112:16, 2113:6,2113:47, 2115:39,2115:45, 2116:5,2116:8, 2127:24,2137:45, 2138:9,2138:32, 2141:6,2141:9, 2141:14,2141:20, 2141:32,2143:24, 2155:8,2155:41, 2161:39,2161:44, 2163:41,2164:3, 2164:8,2164:30, 2168:26,2199:47, 2200:7,2200:23, 2206:14

sworn [1] - 2195:37system [5] -

2133:28, 2133:38,2133:43, 2134:3,2134:10

systems [2] -2178:37, 2192:45

T

tagging [1] - 2087:14target [2] - 2089:46,

2090:24task [3] - 2175:45,

2194:17, 2206:46taught [2] - 2090:27,

2112:11technical [7] -

2185:41, 2190:20,2201:35, 2201:39,2201:43, 2202:10,2202:21

Technical [1] -2190:43

Technology [1] -2191:12

telephone [2] -2085:37, 2085:44

template [1] -2205:22

temporary [11] -2113:46, 2126:41,

2131:1, 2131:28,2131:34, 2131:40,2132:2, 2132:9,2132:11, 2137:44,2138:9

ten [2] - 2110:33,2110:47

tenet [3] - 2192:42,2208:34, 2208:41

tentative [1] -2083:24

term [4] - 2088:15,2133:8, 2134:41,2134:43

terms [21] - 2097:45,2102:5, 2102:25,2128:44, 2131:5,2138:23, 2150:17,2150:20, 2151:32,2159:32, 2162:19,2173:39, 2185:6,2185:9, 2196:37,2196:47, 2204:39,2208:11, 2208:19,2209:25, 2215:26

territory [7] -2166:28, 2167:21,2167:36, 2168:3,2168:22, 2196:12,2215:15

Territory [38] -2084:45, 2134:18,2134:34, 2136:11,2139:44, 2140:3,2145:1, 2147:19,2147:43, 2151:20,2166:11, 2167:17,2168:18, 2169:34,2169:46, 2172:22,2172:33, 2172:45,2173:27, 2175:44,2176:25, 2179:21,2182:32, 2185:45,2186:23, 2186:46,2186:47, 2190:18,2191:39, 2193:25,2193:46, 2194:11,2195:46, 2196:5,2201:6, 2203:24,2203:31, 2211:43

Territory's [4] -2135:37, 2166:8,2187:18, 2195:25

test [48] - 2085:34,2085:47, 2086:12,2086:21, 2086:34,2086:38, 2086:45,2086:47, 2087:6,2087:26, 2087:37,2087:38, 2088:4,

2088:5, 2088:6,2088:12, 2088:20,2089:15, 2089:21,2090:15, 2090:22,2091:37, 2093:22,2094:10, 2095:12,2098:27, 2098:30,2098:37, 2098:40,2098:43, 2101:13,2116:3, 2124:43,2124:44, 2125:5,2125:18, 2147:8,2157:23, 2157:28,2158:11, 2158:30,2159:5, 2159:8,2189:26

tested [19] - 2092:20,2096:15, 2100:8,2100:13, 2100:24,2101:37, 2101:44,2102:15, 2103:10,2111:10, 2111:11,2111:12, 2111:26,2111:47, 2113:13,2113:19, 2113:47,2127:38, 2129:4

testimony [4] -2101:42, 2114:8,2114:12, 2191:43

testing [5] - 2086:31,2087:15, 2115:47,2139:12

tests [2] - 2086:34,2086:42

text [3] - 2164:15,2164:38

THE [39] - 2084:24,2088:24, 2088:32,2093:43, 2094:20,2094:36, 2096:5,2099:28, 2100:19,2100:34, 2101:34,2104:27, 2110:38,2111:7, 2113:27,2115:26, 2128:19,2140:36, 2143:10,2148:23, 2148:30,2152:3, 2154:31,2184:13, 2186:43,2190:29, 2191:16,2192:26, 2194:10,2194:26, 2195:16,2195:21, 2195:27,2195:30, 2195:32,2215:20, 2216:6,2216:36, 2216:40

themselves [1] -2114:10

theory [3] - 2193:1,2193:4, 2193:6


29

thereabouts [1] -2144:42

thereafter [1] -2125:36

thereby [2] -2150:32, 2197:47

therefore [11] -2083:30, 2088:43,2108:34, 2118:12,2124:24, 2135:36,2151:6, 2151:43,2166:2, 2170:25,2184:11

they've [4] - 2158:25,2182:42, 2184:33,2215:26

thinking [2] - 2084:4,2205:35

third [7] - 2103:28,2105:17, 2105:27,2112:47, 2113:11,2137:37, 2138:5

thirdly [1] - 2147:22threads [2] -

2159:19, 2159:27three [20] - 2099:30,

2099:32, 2099:34,2099:44, 2102:15,2103:15, 2109:33,2110:19, 2110:29,2110:34, 2110:46,2111:4, 2111:8,2125:44, 2157:26,2172:9, 2172:40,2188:37, 2196:39

three-day [1] -2111:8

throughout [2] -2155:19, 2197:21

throw [1] - 2187:16thumb [1] - 2090:26Thursday [4] -

2199:26, 2199:31,2199:32

THURSDAY [1] -2216:41

tick [2] - 2179:13,2181:13

ticking [1] - 2179:10tie [13] - 2108:8,

2108:9, 2108:11,2108:44, 2122:14,2122:22, 2123:13,2123:16, 2124:2,2124:12, 2133:45,2156:9

tie-back [9] - 2108:8,2108:9, 2108:11,2108:44, 2122:14,2122:22, 2123:16,

2124:12, 2156:9tie-backs [2] -

2123:13, 2124:2tied [1] - 2161:10timing [2] - 2150:2,

2150:9title [3] - 2156:37,

2196:38, 2197:10titleholder [2] -

2144:7, 2144:19Titles [1] - 2196:4titles [1] - 2209:27TO [1] - 2216:41today [11] - 2084:16,

2101:12, 2101:42,2113:34, 2114:8,2122:41, 2122:45,2135:46, 2161:40,2169:40, 2207:28

today's [1] - 2191:43together [9] -

2087:2, 2116:34,2169:10, 2171:15,2171:23, 2172:10,2172:14, 2172:25,2172:36

tomorrow [2] -2084:46, 2216:38

took [13] - 2095:19,2095:28, 2101:5,2101:35, 2109:17,2112:47, 2147:22,2155:17, 2160:19,2172:32, 2182:26,2187:11, 2215:41

tool [5] - 2087:21,2087:22, 2087:24,2107:5, 2107:31

top [11] - 2085:40,2086:3, 2086:13,2094:9, 2098:44,2147:15, 2149:20,2149:30, 2149:32,2174:40, 2179:46

topic [1] - 2085:20total [1] - 2172:41totally [2] - 2109:37,

2135:39towards [3] -

2085:10, 2208:26,2208:33

town [1] - 2148:45track [12] - 2090:27,

2090:29, 2091:13,2114:47, 2117:38,2118:11, 2151:24,2163:2, 2182:35,2182:46, 2183:11,2183:35

tracking [1] -

2084:43trainee [1] - 2090:26training [2] -

2196:27, 2203:34transcript [7] -

2118:7, 2118:8,2146:34, 2148:33,2149:18, 2149:19,2155:29

transcripts [1] -2163:7

trash [3] - 2141:47,2142:13, 2165:6

Trash [1] - 2168:1travel [1] - 2199:41tree [1] - 2122:7Triton [1] - 2181:20trouble [2] - 2142:42,

2149:8true [4] - 2090:2,

2172:15, 2184:35,2188:39

trusted [2] - 2133:7,2192:18

try [7] - 2089:7,2089:10, 2089:13,2116:47, 2161:4,2185:12, 2198:10

trying [14] - 2087:2,2088:29, 2088:32,2114:4, 2142:42,2150:44, 2161:2,2177:39, 2179:20,2183:29, 2192:23,2192:31, 2216:15,2216:16

turn [5] - 2116:32,2116:33, 2145:9,2174:22, 2205:26

turned [4] - 2116:39,2116:44, 2126:12,2126:18

turns [1] - 2113:21two [37] - 2092:34,

2102:36, 2104:46,2105:16, 2109:1,2109:8, 2109:36,2110:19, 2110:29,2110:33, 2110:46,2111:3, 2111:8,2113:1, 2113:44,2116:13, 2116:33,2116:34, 2128:20,2128:27, 2129:35,2137:28, 2150:6,2150:20, 2158:26,2169:10, 2172:24,2176:43, 2183:43,2184:25, 2188:37,2197:26, 2205:10,

2205:16, 2206:25,2216:1

two-day [1] - 2111:8tying [2] - 2121:10,

2121:14type [4] - 2154:39,

2193:37, 2196:44,2204:23

types [1] - 2200:3typically [6] -

2155:7, 2188:37,2200:47, 2201:24,2206:2, 2206:20

U

ultimate [1] -2084:32

ultimately [3] -2083:29, 2084:39,2141:33

unable [1] - 2178:32uncommon [3] -

2099:29, 2129:7,2129:11

uncontrolled [3] -2160:28, 2162:36,2169:31

Uncontrolled [5] -2166:30, 2167:26,2168:6, 2168:27,2170:43

uncovered [1] -2154:11

undepleted [1] -2136:25

under [13] - 2094:1,2107:9, 2120:22,2137:27, 2138:30,2141:43, 2145:35,2145:45, 2158:13,2166:19, 2188:10,2205:24, 2207:1

undergone [1] -2196:27

understood [18] -2086:12, 2088:37,2088:39, 2096:44,2097:8, 2097:13,2097:18, 2116:15,2122:33, 2123:27,2129:28, 2130:30,2130:37, 2134:38,2150:46, 2170:2,2173:44, 2207:1

undertake [5] -2086:20, 2087:26,2178:13, 2202:9,2203:6

undertaken [4] -2154:7, 2154:27,2158:30, 2187:30

undertaking [2] -2125:18, 2175:44

unhelpful [1] -2186:28

unimportant [2] -2105:42, 2212:11

unit [1] - 2194:14United [2] - 2190:41,

2191:18units [1] - 2196:38unknowns [1] -

2175:11unless [10] -

2140:18, 2180:43,2187:40, 2189:29,2197:16, 2198:33,2199:9, 2211:5,2213:28, 2215:24

unlikely [2] - 2138:2,2139:26

unusual [2] -2084:11, 2197:7

unverified [1] -2110:27

up [56] - 2085:21,2091:40, 2091:43,2093:40, 2094:24,2095:4, 2095:12,2104:15, 2104:16,2104:33, 2107:4,2109:24, 2109:46,2110:14, 2111:41,2118:23, 2118:29,2118:35, 2121:10,2124:12, 2126:40,2129:35, 2133:28,2133:37, 2133:42,2134:2, 2134:9,2134:19, 2134:27,2149:18, 2156:3,2156:28, 2158:25,2160:35, 2161:10,2161:41, 2163:29,2163:43, 2164:2,2174:33, 2174:39,2182:42, 2186:35,2187:21, 2188:47,2189:5, 2190:15,2190:22, 2190:38,2191:22, 2200:10,2201:13, 2209:29,2209:41, 2209:44

update [4] - 2091:29,2091:38, 2095:25,2118:32

updated [1] -2216:21


30

updates [1] -2154:46

UPON [1] - 2153:1urgent [1] - 2199:10US [2] - 2190:45,

2191:1useful [3] - 2098:32,

2189:24, 2189:43usual [2] - 2087:8,

2087:13utterly [1] - 2170:47

V

v" [1] - 2138:35valid [4] - 2088:6,

2177:18, 2177:20,2177:23

validate [4] - 2096:1,2096:3, 2110:24,2110:35

validated [13] -2086:12, 2086:28,2089:44, 2090:2,2090:9, 2090:32,2090:36, 2092:21,2096:2, 2096:8,2100:31, 2100:32,2158:15

validating [2] -2086:14, 2111:29

validation [5] -2086:22, 2090:22,2093:21, 2093:26,2125:28

value [2] - 2085:5,2085:7

valve [2] - 2096:36,2167:23

valves [3] - 2096:45,2097:3, 2117:21

variant [1] - 2213:2variation [1] -

2156:22various [5] -

2105:10, 2178:32,2197:22, 2209:27,2216:1

vary [3] - 2156:7,2188:45, 2188:46

verification [11] -2114:28, 2115:41,2115:46, 2116:16,2116:37, 2124:41,2125:8, 2125:21,2125:37, 2135:32,2139:17

verified [25] -2096:15, 2100:13,

2100:24, 2101:37,2101:44, 2102:15,2102:43, 2103:10,2111:10, 2111:11,2111:12, 2111:26,2112:19, 2113:13,2113:19, 2113:47,2114:35, 2116:9,2116:31, 2125:4,2125:36, 2127:38,2128:47, 2131:28,2131:34

verify [5] - 2114:40,2114:45, 2115:15,2125:18, 2192:43

verifying [1] - 2185:7vernacular [1] -

2159:43version [2] - 2091:42Vic [1] - 2186:28Victoria [4] -

2186:23, 2186:44,2186:45, 2187:15

Victorian [13] -2137:12, 2137:15,2138:40, 2139:1,2139:8, 2139:25,2139:46, 2140:12,2140:37, 2155:35,2174:27, 2174:35,2185:44

view [57] - 2083:13,2084:25, 2085:7,2091:19, 2092:13,2092:17, 2093:15,2093:19, 2094:16,2095:23, 2100:25,2100:27, 2100:29,2105:16, 2105:25,2107:13, 2107:17,2112:4, 2112:37,2112:47, 2116:39,2118:2, 2122:41,2122:45, 2125:24,2125:33, 2133:4,2136:37, 2136:45,2140:19, 2143:39,2144:24, 2150:5,2150:20, 2151:2,2151:33, 2151:42,2157:40, 2160:8,2160:12, 2165:28,2169:11, 2170:41,2176:37, 2176:39,2177:7, 2177:8,2177:18, 2177:20,2177:23, 2177:24,2194:45, 2203:17,2207:18, 2214:34

viewer [1] - 2190:38

views [8] - 2083:22,2108:31, 2137:20,2139:45, 2142:33,2142:39, 2143:45,2174:28

virtually [1] -2193:24

virtue [1] - 2083:28visible [1] - 2107:44volume [1] - 2117:38

W

wait [6] - 2088:12,2098:27, 2098:31,2098:41, 2114:46,2115:16

waiting [1] - 2181:20walk [4] - 2104:5,

2104:13, 2104:39,2108:39

wants [1] - 2083:41War [1] - 2188:36warm [1] - 2093:22WAS [1] - 2216:40watch [3] - 2160:1,

2173:16Water [1] - 2203:29watered [1] -

2192:30ways [2] - 2087:11,

2087:18website [1] -

2083:10Wednesday [2] -

2082:37, 2156:35week [3] - 2085:4,

2085:6, 2156:46weeks [5] - 2095:9,

2096:27, 2114:46,2161:17, 2216:8

weeks' [1] - 2197:25weight [1] - 2112:13wellbore [9] -

2097:42, 2100:2,2100:12, 2100:24,2136:27, 2141:32,2149:6, 2149:14,2169:18

wellhead [1] -2184:14

wells [23] - 2088:26,2093:18, 2121:15,2121:24, 2121:28,2121:37, 2121:42,2122:13, 2122:21,2129:16, 2129:24,2132:45, 2143:14,2156:10, 2160:27,

2163:44, 2180:42,2182:40, 2184:14,2184:19, 2188:44,2188:45

West [1] - 2181:20Western [9] - 2136:6,

2136:11, 2136:16,2136:24, 2139:26,2139:45, 2140:8,2186:46, 2187:15

wet [4] - 2117:33,2117:44, 2118:12,2166:2

whatsoever [7] -2114:18, 2147:17,2174:5, 2181:46,2182:4, 2184:41,2185:6

wheel [1] - 2182:21whereas [1] -

2216:10whereby [1] -

2181:17whilst [8] - 2093:14,

2099:1, 2099:21,2124:35, 2193:6,2198:4, 2198:28,2200:40

Whitfield [22] -2103:1, 2112:16,2113:40, 2114:22,2119:20, 2120:17,2120:35, 2160:13,2195:34, 2195:42,2201:12, 2201:15,2202:6, 2204:9,2209:32, 2210:15,2211:16, 2211:33,2214:26, 2214:43,2215:22, 2215:38

WHITFIELD [1] -2195:37

whole [4] - 2088:22,2115:11, 2121:3,2202:13

wide [1] - 2110:20willing [1] - 2102:4Wilson [11] -

2091:29, 2091:34,2091:45, 2110:14,2110:17, 2110:31,2110:45, 2146:5,2146:12, 2146:15,2183:21

Wilson's [3] -2094:20, 2095:37,2146:25

window [5] -2110:21, 2110:23,2110:47, 2180:6,

2181:3window-dressing

[1] - 2181:3wish [9] - 2083:35,

2083:36, 2104:5,2109:15, 2109:21,2115:35, 2186:8,2186:12, 2192:9

wished [7] -2085:29, 2170:11,2170:16, 2170:25,2170:29, 2171:11,2213:43

wishes [1] - 2084:40WIT.1000.0001.

0156 [1] - 2145:9WIT.1000.0001.

0237 [1] - 2146:3WIT.1000.0004.

0027 [1] - 2147:47WIT.4000.0002.

0009 [1] - 2119:10WIT.4000.0002.

0014 [1] - 2085:22WIT.4000.0002.

0015 [1] - 2130:28WIT.4000.0002.

0016 [1] - 2156:4WIT.4000.0002.

0019 [1] - 2170:5WITHDREW [1] -

2195:32witness [4] -

2095:11, 2102:21,2117:3, 2195:22

WITNESS [2] -2195:27, 2195:32

witness's [1] -2191:44

witnesses [5] -2084:45, 2085:1,2149:38, 2150:47,2194:23

WOMP [40] -2140:41, 2162:8,2162:11, 2162:12,2174:28, 2174:36,2175:12, 2176:3,2176:15, 2176:30,2176:36, 2176:39,2177:25, 2177:28,2177:32, 2177:45,2177:46, 2178:3,2178:4, 2178:9,2178:13, 2178:20,2178:21, 2178:35,2178:40, 2178:47,2179:5, 2179:10,2179:14, 2179:42,2180:25, 2180:29,


31

2181:35, 2181:41,2182:19, 2186:9,2208:33, 2208:40,2208:45, 2209:17

WOMPs [7] -2176:44, 2185:46,2186:12, 2186:18,2186:44, 2187:37,2208:38

Wong [11] - 2174:27,2174:34, 2174:42,2175:43, 2176:24,2177:14, 2177:18,2179:20, 2179:30,2179:31, 2185:42

Wong's [3] -2178:29, 2179:41,2179:47

word [11] - 2085:38,2088:17, 2088:21,2088:29, 2171:42,2177:3, 2177:36,2184:4, 2184:6,2186:5, 2211:29

wording [1] -2179:26

words [8] - 2085:29,2110:45, 2168:9,2168:43, 2200:19,2205:41, 2211:2,2211:11

works [1] - 2203:12world [2] - 2129:25,

2214:42worldwide [1] -

2129:16wormholes [1] -

2097:19worst [3] - 2159:43,

2173:11, 2173:15worth [1] - 2084:13write [2] - 2166:34,

2166:44writing [3] - 2113:32,

2134:44, 2167:31written [6] - 2094:13,

2135:2, 2135:4,2137:40, 2167:32,2194:1

wrote [5] - 2167:30,2168:33, 2168:43,2184:4, 2216:2

Y

year [57] - 2085:26,2085:36, 2085:46,2086:6, 2091:7,2091:19, 2095:24,


32

2097:23, 2097:34,2099:38, 2100:26,2101:16, 2104:30,2105:32, 2106:6,2107:13, 2108:25,2108:31, 2109:7,2110:5, 2112:15,2115:3, 2115:46,2116:30, 2122:1,2122:30, 2122:36,2122:41, 2123:27,2124:6, 2124:15,2126:13, 2126:23,2129:6, 2129:10,2129:14, 2129:23,2131:7, 2131:17,2132:7, 2139:28,2153:10, 2153:20,2154:4, 2159:39,2161:21, 2161:40,2171:21, 2197:4,2197:21, 2197:24,2197:25, 2197:29,2197:33, 2197:42,2198:19

years [9] - 2099:26,2099:32, 2099:34,2099:44, 2183:43,2183:47, 2184:25,2190:42, 2203:41

yesterday [20] -2085:15, 2085:23,2094:31, 2094:38,2101:35, 2103:15,2120:2, 2153:3,2153:46, 2174:13,2181:40, 2182:34,2182:38, 2185:12,2190:23, 2191:29,2192:27, 2192:29,2198:8, 2199:25

yesterday's [1] -2191:30

yourself [5] - 2135:1,2161:28, 2184:24,2204:35, 2210:3

Z

zero [2] - 2188:46

MONTARA COMMISSION OF INQUIRY · Q. Well, a cement bond log can determine the integrity of cement...

Documents

Transcript of MONTARA COMMISSION OF INQUIRY · Q. Well, a cement bond log can determine the integrity of cement...