Stevick, Glen Expert Report Only

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Expert Report of Glen Stevick Ph.D P.E

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERNDISTRICT

OFLOUISIANA

IN RE OIL SPILL by the OIL RIG

DEEPWATER HORIZON in the

GULF OF MEXICO MDL No 2179

on APRIL20 2010

SectionJ

Applies to

The Honorable Judge Barbier

ALL CASES and Mag Judge Shushan210-cv-02771

____________________________________________________________________________

AMENDED EXPERT REPORT OF GLEN STEVICK Ph.D P.E

II


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TABLE OF CONTENTS

FINDINGS

II THE BLOWOUT PREVENTER PURPOSE

STRUCTURE AND DESIGN

The BOP Purpose

BOP Structure

BOP Control 10

Communicating with the BOP 10

Activating the BSR 11

BOP Design 13

Ill THE BOP DESIGN WAS DEFECTIVE BECAUSE

IT RELIED ON SINGLE BSR 15

The BSR was Single Point of Failure for the

DWHBOP 15

The Potential for Off-Center Drill Pipe was

Well Known to BP and Transocean 16

IV TRANSOCEAN USED FLAWED CONDITION-

BASED MAINTENANCE 17

Transocean Failed to Recertify the BOP Every

3-5 Years as Specified by API and Cameron 17

Transoceans Condition-Based Maintenance

is Flawed Because Only Equipment With

Measured Problems or Failures Gets Fixed or

Replaced 19

Problems that cannot be measured are

not considered 19

Need for improved equipment is not

considered 20

21


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Implementing BAST is discouraged 21

BP FAILED TO IMPLEMENT BAST IN THE BOP 21

BP Failed to Implement BAST for the BSR 21

BP and Transocean Failed to Upgrade the

BOP to Include Second BSR 24

BP and Transocean Failed to Upgrade to

Camerons Mark Ill BOP Control Pod 24

BP Failed to Implement BAST by Relying

Solely on MUX Cablesfor EDS 25

BP and Transocean Failed to Implement

BAST by Using EDS-1 Instead of EDS-2 25

VI THE UNDERCHARGED BLUE CONTROL POD

BATTERIES AND INCORRECTLY WIRED

YELLOW CONTROL POD SOLENOID 103Y MAY

HAVE BEEN CONTRIBUTING CAUSES OF THE

BOPS INABILITY TO STOP THE BLOWOUT 26

Undercharged Blue Control Pod Batteries 27

Incorrectly Wired Yellow Control Pod Solenoid

103Y 27

The AMF/Deadman Likely Failed to Actuate

the BSR because of Low Blue Pod Battery

and the Incorrectly Wired Yellow Pod Solenoid 28

The BSR Likely Would Have Completely

Sheared the Drill Pipe and Sealed the Well if

the BSR had been Activated when the Drill

Pipe was Centered 28


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LIST OF FIGURES

Figure The DWH BOP showing the position of annulars and valves

Figure The Cameron BSR used in the DWH BOP

Figure Model of the DWH BOP BSR from the Det Norske Veritas

DNV report

Figure Model of the DWH and BOP from the DNV report

41


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INTRODUCTION

Berkeley Engineering And Research Inc was retained by Halliburton

Energy Services Inc to assess the design of the blowout preventerBOP used at the Deepwater Horizon DWH and the BOPscontribution to the well blowout explosion fire and spill on April 20 2010

At the time of the incident the DWH was in the process of temporarily

abandoning BPs Macondo deepwater well after reaching depth of

approximately 18360 ft 12360 ft below the seafloor in the Gulf of

Mexico G0M

My opinions are based upon the materials and information have

reviewed my analysis of that information my education training

experience and knowledge in the areas of mechanical engineering failure

analysis and design and material behavior and my knowledge of oilfield

and offshore equipment e.g offshore platforms BOPs casings and drill

strings

My opinions are also based upon the engineering standard of care

standards recommended practices and regulations relevant to

offshore oil and gas exploration and drilling and production activities

have not been asked to make any assumptions nor have presumed

anyfacts

beyondthose which are cited as material relied

uponin this

Reportand its attachments

FINDINGS

Based upon my education training experience in hydraulics electronic

controls and offshore mechanical engineering design review of Phase

and Phase II forensic testing and examination of the DWH BOP my review

of supporting documents testimony and other evidence including the

materials identified in Appendix and the calculations shown in this report

and itsappendixes

have found thefollowing

to be true

British Petroleum BP and Vastar Resources Inc Vastarwhich BP acquired specified the design and configuration of the

DWH BOP which was constructed by Cameron International

Corp Cameron

The BOP relied upon single blind shear ram BSR to be ableto shear drill pipe and seal the well in the case of an emergency

51


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This made the BSR single point of failure for the entire BOP of

which BP was aware

Transocean implemented flawed condition-based maintenance

system that did not identify the need for technology upgrades to

account for past design deficiencies and the issues associated

with drilling in deeper and deeper water This condition-based

maintenance program did not allow Transocean to ensure proper

maintenance and certification of the existing BOP and its

components

BP and Transocean failed to implement the best available and

safest technologyBAST

in theBOP

SpecificallyBP

andTransocean failed to use

BSR Double Shear rams that would have sheared and

sealed off-center drill pipe

two BSRs--one to shear the pipe and the other to seal the well

an Emergency Disconnect Sequence EDS that activated theCasing Shear Rams CSR5 to center the pipe before

activating the BSR to shear and seal the pipe

an Acoustic Control System ACS as redundant means ofcommunication between the DWH rig and the BOP and

Camerons Mark Ill control pod system that used rechargeable

BOP control pod batteries and enabled battery lev els to be

monitored remotely

The undercharged batteries in the blue BOP control pod and

incorrectly wired solenoid 103Y were the result of Transoceans

flawed condition-based maintenance program and the failure of

BP and Transocean to implement BAST The undercharged

batteries and incorrectly wired solenoid may have beencontributing causes of the blowout if they prevented the Automatic

Mode Function AMF/Deadman from activating the BSR at

time when the drill pipe was centered and could have been

sheared and closed by the BSR

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II THE BLOWOUT PREVENTER PURPOSE STRUCTURE AND

DESIGN

The BOP Purpose

The primary purpose of the BOP is to prevent uncontrolled oil and gas from

reaching the DWH i.e to prevent blowout As in any mobile offshore

drilling unit MODU the DWH BOP is critical subsea component usedto seal control and monitor the well during drilling operations As stated in

BPs internal documents

Blowout equipment is the final l ine of defense

agains t catastrophic event which may include

fatalities uncontrollable release of oil and gas and

evacuation of entire communities.1

Indeed BPs CEO considered BOP to be fail-safe piece of equipment

that was the last line of defense against blowout.2 Similarly

Transocean recognized the BOP as critical piece of equipment.3

BP-Wells Engineer OJT Module BP-HZN-2179MDL01342044-01342052 Exhibit

2096

Deposition of Tony Hayward June and 2011 23510-19

Deposition of William Stringfellow April 11-12 2011 2036-9

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BOP Structure

As shown to the right in figure

the BOP on the DWH consists of

two main parts an upper

portion called the Lower Marine

Riser Package LMRP andLower BOP Stack sitting below

the LMRP The LMPR contains

two annulars while the lower

BOP package includes single

BSR single CSR two variable

shear rams VBR5 and TestRam an inverted VBR to resist

downward pressure

till

________H_LowerBOP Stack

Fig The DWH BOP showing the position of annulars and valves.4

The BSR used in the BOP is of particular importance because the BSR is

the device ultimately responsible for shearing the drill pipe and sealing thewell in the case of an emergency The single BSR in the DWH BOP was

Cameron shearing blind ram as shown below

Perkin CS Expert Report August 26 2011 Cited image source EngineeringPartners International LLC

Upper Annular

Lower Annular

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SF-E4A11Q FLIND FA

Fig The Cameron BSR used in the DWH BOP

The shearing blind ram includes lower ram with straight blade and an

upper ram with shaped blade The shearing blind ram is designed to

shear drill pipe located within the cutting blades and seal the wellbore The

BOP has bore of 18-3/4 inches and the cutting blades are only 17-7/8

inches for the lower straight blade and 15-1/4 inches for the upper V-shaped

blade This leaves gaps within the wellbore that are outside of the cutting area

of the shearing blind ram blades as shown below in figure

Fig Model of the DWH BOP BSR from the Det Norske Veritas

DNV report.6

Cameron EB 852D Exhibit 7001 The shaded areas represent elastomeric sealing

elements


91


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BOP Control

Communicating with the BOP

The DWH BOP was controlled by Cameron Mark II electro-hydraulic

multiplex UX control system.7

As shown in the modified

version of figure to the

right the LMRP portion of

the BOP contains two

redundant control pods

referred to as the blue and

yellow pods The control

pods provided control

functionality and

communication between

the BOP and the DWH rig

via wired MUX cables that

ran from the control pods

through the water up to

the DWH where the crewcould control the BOP

using control panels

Because control

commands from the DWH

could only be transmitted

via the MUX cables the

ability of the DWH crew to

directly control the BOP

was completely contingent

upon properly functioning

MUX cables

Lwr AnrijIa

Det Norske Veritas Final Report for United States Department of the Interior Bureau

of Ocean Energy Management Regulation and Enforcement Forensic Examination of

Deepwater Horizon Blowout Preventer Contract Award No M10PX00335 Volume

Final Report Report No EP030842 20 March 2011 DNV Report Vol Figure 132

Deposition of Jack Erwin June 6-7 2011 36715-17

Yellow Coritol Pod

iue Control

4-Ipp .nriuia

Lor BOF

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Fig The DWH BOP including identification of the blue and yellow control

pods.8

Figure below shows model of the DWH rig and BOP including

identification of various BOP components the MUX cables the

accumulators that provide hydraulic pressure to activate the BOP rams

images of BOP control panels and an image of BOP control pod

Fig Model of the DWH and BOP from the DNV report.9

Activating the BSR

There were several different methods of controlling the BOP and activating

the BSR including

Perkin CS Expert Report August 26 2011 Cited image source EngineeringPartners International LLC Image modified to identify the blue and yellow control

pods

DNV Report Vol Appendix Figure

LMAP

M.tI

4- i1 li.W

III


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Activation of the BOP high pressure BSR function from

either of two control panels located on theDWH

Thismethod requires MUX line communication to an operational

control pod

Activation of the Emergency Disconnect Sequence

EDS which is also activated from either of the two controlpanels on the DWH and requires MUX line communication to

an operational control pod The primary function of the EDS

is to allow the rig to disconnect from the BOP if the dynamic

positioning system that holds the rig in position fails

Activation of the AMF/Deadman circuits located in the

Subsea Electronic Modules SEM5 within either of the blueor yellow control pods mounted on the LMRP The AMF is

designed to activate automatically i.e without requiring

initiation by user when the BOP loses hydraulic pressureelectrical power or electronic communication with the DWH

Remotely Operated Vehicle ROy initiation of the AMFby cutting the MUX and hydraulic lines on the BOP

ROV initiation of the Autoshear function by severing the

autoshear activation rod that connects the LMRP to the BOP

stack intended to activate if the LMRP and BOP are

separated

ROV hot stab connection to the BOP hydraulics The

ROV can use onboard hydraulic pumping to power the BOP

hydraulics

The AMF is based on Cameron circuit board that implements the AMFfunctionality The AMF requires at least one functional control pod i.eeither the blue or yellow control pod to initiate and complete its sequence

including to activate the BSR Each of the two control pods contains two

SEMs i.e SEM and SEM and each SEM contains an AMF card To

power the AMF cards each SEM contains dedicated volt battery i.eone per SEM two for each of the blue and yellow control pods and four

total for the BOP Each control pod also contains single 27 volt DCbattery pack to power the two SEMs in that pod Each control pod also

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contains high-pressure shear circuit that activates the BSR The high-

pressure shear circuit is energized by solenoid 103 in that pod i.e 103B

forthe blue pod and 103Y

forthe yellow pod which activates

for

30seconds when the AMF is triggered Each solenoid 103 contains two coils

with one coil connected to each of SEM and SEM in that solenoids

pod Each of the 103 solenoids is powered by the 27 volt battery packfrom its respective pod.11

BOP Design

According to information reviewed by BPs Vice President of Engineeringand Quality for the Drilling Systems Division12 BP was involved in the

configuration ofDWH BOP from the beginning13 and BP played an

active role in specifying DWH BOP stack.14

The DWH was built in 2000 at the Hyundai Heavy Industries Shipyard in

South Korea for cost of approximately $350 million It was originally built

for and commissioned by Falcon Drilling Co Falcon which later

became part of Transocean The DWH was originally contracted to Vastar

which was later acquired by BP The DWH BOP was first contemplated in

1998 Drilling Contract between Vastar and Falcon Drilling Contract.5

Under the Drilling Contract Falcon was to furnish and pay for the B0P16

and to ensure that the BOP was adequately maintained and in such

condition as to permit continuous and efficient operation.7

10

Deposition of Edward Gaude September 19 2011 12414-25

Deposition of William LeNormand June 20-21 2011 15822 1593

12

Deposition of David McWhorter July 7-8 2011 1316-18

13


14

Depositionof David McWhorter

July7-8 2011 33023-3313

15BP-HZN-21 79MDL00056656-936

16BP-HZN-2 79MDL00056656-936 at BP-HZN-21 79MDL00056768 Blowout

preventers are to be furnished and paid for by the CONTRACTOR i.e Falcon under

Exhibit B-3 paragraph .20 of the Drilling Contract

17BP-HZN-21 79MDL00056656-936 at BP-HZN-21 79MDL00056674 Under section

14.1.1 of the Drilling Contract CONTRACTOR i.e Falcon agrees to maintain all

equipment and materials furnished by CONTRACTOR which i ncludes t he BOP as

noted in Exhibit B-3 paragraph .20 of the Drilling Contract

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Although the BOP was manufactured and sold by Cameron and purchased

by Falcon Vastar was heavily involvedin

theBOP

design configurationchoice of components and controls.18 Vastar chose the configuration

of the BOP Stack and the type of rams for each cavity19 the routing of

the MUX lines20 that there would be no acoustic communications21

factory adjustments by Cameron prior to acceptance22 and the EDS

program mode EDS-1 23

Furthermore for BOP designs BP decides what the BOP stack

configuration will be and instructs its drilling contractors including

Transocean regarding what types of rams should be used and where the

rams will be located in the BOP.24 Here BP specified the configuration of

the BOP in its original contract with Transocean and re-specified the

configuration in September 2009 in contract amendment.25 As Operator

of the Macondo well site BP is also ultimately responsible for the BOP

under the Code of Federal Regulations CFR5 and the AmericanPetroleum Institute API Recommended Practices RP26

18

Exhibit

5094BP-HZNBLYOO294O35

19Exhibit 4112 deposition of Michael Byrd July 13-14 2011 48812-49418

20 BP-HZNBLY00294826

21

BP-HZNBLYOO29435O

22BP-HZNBLY00294352

23BP-HZNCECO30029 As discussed further below EDS-1 closes only the BSR

whereas the other available EDS mode EDS-2 first closes the CSR and then the BSR

Had this mode been selected it likely would have centered the drill pipe before attempt

attempting to shear the pipe which likely would have sealed the well

24Deposition of Tony Hayward June and 2011 5731-14

25 Amendment 38 to Contract No 980249 September 28 2009 BP-HZN-CECO4 1476Exhibit 1488

26Code of Federal Regulations Title 30 Part 250 Oil and Gas and Sulphur Operations in

the Outer Continental Shelf Subpart 30 CFR 250 Section 250.400 et seqAmerican Petroleum Institution Recommended Practice 53 Recommended Practices

for Blowout Prevention Equipment Systems for Drilling Wells API RP 53

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Ill THE BOP DESIGN WAS DEFECTIVE BECAUSE IT RELIED ON

SINGLE BSR

After the Macondo blowout BP acknowledged that it had relied on the BOP

as the ultimate form of containment in the event of blowout.27 BP also

recognized that in the case of blowout the BSR was the most critical well

control device within the BOP.28 Despite the importance of the BSR and its

crucial role in the operation of the BOP and overall well safety BP failed to

design and implement within the BOP BSR that could reliably shear the

drill pipe and seal the well under foreseeable operating conditions

The BSR was Single Point of Failure for the DWH BOP

Although there are several ways to activate the BSR all of the DWH

emergency systems relied upon the BOPs single BSR to be able to shear

the drill pipe and seal the well in the case of an emergency making the

BSR single point of failure for the entire BOP safety system Failure of

the BSR to shear the drill pipe and seal the well for whatever reason

would result in total failure of the entire BOP to perform its intended

function of preventing blowout Indeed 2001 Risk Assessment of the

DWH BOP identified the risks inherent to the BOP stack configuration with

single BSR

The major contributor to the failure likelihood

associated with the BOP control system results from

the selected stack configuration With only one

shear ram capable of sealing the well in it is

extremely difficult to remove all of the single failure

points from the system.29

27Deposition of Tony Hayward June and 820112351-92777-103017-10

28Deposition of Tony Hayward June and 820112897-14

29Risk Assessment of the Deepwater Horizon Blowout Preventer BOP Control

System Final Report April 2000 CAM-CIV-0019032 CAM-CIV-0019076 at CAM-CIV

0019070 Exhibit 4120 at 37

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The Risk Assessment further noted that the BSR including the final shuttle

valve that supplies hydraulic pressure to the BSR accounts for 56% of the

failurelikelihood of the system to successfully perform

its EDSoperation.3

The Potential for Off-Center Drill Pipe was Well Known to

BP and Transocean

BOP with single BSR is particularly deficient For example in

situations when the EDS system requires activation BPs VP of

Technology for Global Wells Organization noted that EDS pipe is alwaysoff center.31 As discussed above EDS is primarily designed for use in

scenarioswhere some aspect

of therigs dynamic positioning system has

failed and the rig has drifted from its intended location

those scenarios for which EDS has been

designed the pipe is likely to be off center because

of the huge tension that is on the pipe.32

Potential causes of off-center drill pipe include pipe distortion or bowing

from internal pressure loss of rig control and drift debris pushing the pipe

off-center ram pushing the drill pipe off-center multiple pipes in the riser

and elastic buckling.33 Of the potential causes elastic buckling is the most

likely to have forced the drill pipe off-center.34 Additionally helical buckling

is particular type of elastic buckling that has been well known for many

years in the drilling context.35 It does not appear that Transocean or BP

ever conducted any testing or analysis of the BSRs ability to shear off-

center drill pipe

30

Risk Assessment of the Deepwater Horizon Blowout Preventer BOP ControlSystem Final Report April 2000 CAM-CIV-0019032 CAM-CIV-0019076 at CAM-CIV

0019072 Exhibit 4120at

3931

Deposition of Fereidoun Abbassian May 3-4 2011 502-3

32Deposition of Fereidoun Abbassian May 3-4 2011 5010-13

DNV Report Addendum p.6-8 section 2.2.1

DNV Report Addendum 6-11 section 2.2

Lubinski Althouse W.S and Logan J.L Helical Buckling of Tubing Sealed in

Packers JPT 655-70 June 1962

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IV TRANSOCEAN USED FLAWED CONDITION-BASED

MAINTENANCE

As noted above under the Drilling Contract between BP through its

predecessor Vastar and Transocean through its predecessor Falcon

Transocean had primary responsibility for maintenance of the BOP.36

Transocean Failed to Recertify the BOP Every 3-5 Years as

Specified by API and Cameron

Transocean failed to follow the testing and maintenance guidelines

specified in 30 CFR 250 and API RP 5337 In particular Transocean

ignored the requirement that

After every 3-5 years of sen/ice the BOP stack

choke manifold and diverter components should be

disassembled and inspected in accordance with the

manufacturers guidellnes.38

36

BP-HZN-21 79MDL00056656-936 at BP-HZN-21 79MDL00056674 Under section

14.1.1 of the Drilling Contract CONTRACTOR i.e Falcon agrees to maintain all

equipment and materials furnished by CONTRACTOR which i ncludes t he BOP as

noted in Exhibit B-3 paragraph .20 of the Drilling Contract

See 30 CFR 250 et seq API RP 53

38API RP 53 section 17.10.3 see also 30 CFR 250.446 requiring that BOP

maintenance and inspections must meet or exceed the provisions described in API

RP 53

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The recurring disassembly and inspection of the entire BOP as outlined in

API RP 53 occurs at the surface and is important to maintaining safe and

effective BOP The advantages of regularly scheduled recertification areas follows

Consistent with the API the BOP manufacturer Cameron also

recommends that the BOP stack be recertified every 3-5 years.39 In

contrast an independent inspection of DWH two weeks before the blowout

found that for the BOP upon review of certification documentation it was

noted that the date of last manufacturers certification was 13 December

2000 and this is beyond the yearly inspection overhaul and re

certification requirement.4 Although Transocean recognized that both the

API and Cameron recommended disassembly inspection and

recertification of the entire BOP every 3-5 years Transocean knowinglychose not to follow this recommendation.41

Deposition of Mark Hay June 29-30 2011 1197-12011

40 MODU Condition Assessment DEEPWATER HORIZON ModuSpec USA Inc 4/1-

14/2010 TRN-USCG_

MMS-00038652

41

Deposition of William Stringfellow April 11-12 2011 21625-21713

Advantages of API/Cameron BOP

Recertification

Provides periodic opportunities to examine

individual BOP components for corrosion wear

and other flaws and to replace components when

necessary

Provides periodic opportunities to evaluate the

BOP design and replace deficient or outdated

components with BAST components and

technology

Ensures

components

every 3-5 years

that the entire BOP and its

are inspected at least as often as

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Transoceans Condition-Based Maintenance is Flawed

Because Only Equipment With Measured Problems or

Failures Gets Fixedor Replaced

When the piece of equipment falls we replace it or make

repairs to it.42

Instead of complying with the API and Camerons maintenance guidelines

for the BOP Transocean followed its own condition-based maintenance

program.43 Under this condition-based maintenance program BOP

components are not automatically removed from operation and inspected

every 3-5 years.44 Rather Transocean personnel would take

measurements and test BOP equipment45 and when piece of equipment

s tarted to create problems or fail Transocean fixed it.46 This type of

condition-based maintenance is subject to numerous flaws

Problems with Transoceans Condition-Based

Maintenance

Equipment deterior at ion that cannot be

measured is not considered

Need for improved equipment based on design

flaws new industry experience or operation in

more difficult environment is not considered

Replacement of otherwise functioning

equipment with BAST is discouraged

Problems that cannot be measured are not considered

Transoceans condition-based maintenance program failed to detect

several problems with the DWH including the low charge on the blue

42Deposition of Mark Hay June 29-30 2011 12018-19



Deposition of Pharr Smith June 27-28 2011 157-1

46

Deposition of Pharr Smith June 27-28 2011 157-13 deposition of Mark Hay June

29-30 2011 12018-1 12117-19

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pod batteries and the incorrect wiring on yellow pod solenoid 103Y in

the DWH BOP These types of equipment problems are undetectable by

condition-based maintenance because theBOP

d id no t have sensors thatindicated pod battery levels and physical inspection and testing was

needed to evaluate the wiring on yellow pod solenoid 103Y But it cannot

be debated that properly functioning pod batteries and solenoids are highly

important to the safe and effective operation of the BOP and should

therefore be regularly tested and evaluated under any maintenance

program Transoceans condition-based maintenance is flawed because it

fails to consider equipment that cannot be measured whereas such

equipment is evaluated under the recertification process found in API and

Camerons guidelines

As discussed further below the undercharged blue pod batteries and

incorrectly wired yellow pod solenoid 103Y may have prevented the

AMF/Deadman from activating the BSR at the time of the incident and

ultimately lead to the blowout But regardless of whether these battery and

solenoid problems were direct cause of the blowout these problems do

highlight flaws in Transoceans condition-based maintenance program

The working condition of critical components was not evaluated by

Transocean because it could not be measured

Need for improved equipment is not considered

Another flaw wi th Transoceans condition-based maintenance program is

that it does not detect the need to improve existing equipment that is

otherwise functioning properly Equipment measurements during

condition-based maintenance are not going to identify design flaws

improvements in industry knowledge and practices or increased system

requirements due to operation in more difficult environment Under

condition-based maintenance if equipment measurements are in line with

expectations that equipment will not be considered further for potentially

necessary upgrades For example had Transocean disassembled and

inspected the DWH BOP for recertification and performed perfunctory

engineering review or industry comparison at any time since 2006Transocean would have found that the DWH di d n ot have Camerons most

up to date BOP control system Mark Ill which as described below

provides numerous safety benefits over the Mark II system used for the

DWH BOP recurring BOP recertification process that involves BOP

disassembly and inspection as part of an engineering review is superior to

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Transoceans condition-based process because recurring recertification

provides an opportunity to identify changing requirements for equipment

thatis

otherwisein

perfect working order

Implementing BAST is discouraged

Transoceans condition-based maintenance program discourages the

implementation of BAST because it focuses on replacing equipment only in

the event of measurable problems or failures as opposed to periodically

evaluating whether improved equipment exists that should replace

otherwise functional existing equipment Transoceans condition-based

maintenance program further discourages the implementation of BAST by

failing to provide the opportunity to implement BAST equipment and

technology which typically must occur at the surface In contrast

maintenance programs based on engineering review i.e recertification at

the surface encourage the implementation of BAST by providing the

opportunity to evaluate BAST for all equipment and the opportunity to

implement BAST when available The many failures to implement BAST in

the DWH BOP discussed below are unsurprising in light of the flaws of

Transoceans condition-based maintenance program

BP FAILED TO IMPLEMENT BAST IN THE BOP

The CFR requires that BP as Operator of the Macondo well site must use

the best available and safest technology BAST whenever practical on all

exploration development and production operations.47 But BP failed to

implement BAST in numerous areas of the BOP including the single BSR

that was ultimately unable to perform its intended function of severing the

drill pipe and sealing the well

BP Failed to ImplementBAST for the BSR

Implementing BAST in the single BSR was particularly critical due to the

BSR being single point of failure and the device that was ultimately relied

upon to seal the well in the case of an emergency BP knew the BSR was

the most important piece of equipment for preventing blowout48 and yet

BP still failed to implement BAST in the BSR and preferably add second

30 C.F.R 250.107c

48

Deposition of Tony Hayward June and 820112897-14

211


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BSR.49 Indeed the BSRs on the DWH BOP had not been upgraded since

the rig was first ordered in ggg50

BSRs with double shaped cutting blades and wider blades were

available when the BOP was designed For example Camerons Double

Shear DVS Rams featured shaped cutting blades on both the

upper and lower blocks.51 The double design provided the benefits of

helping to center the drill pipe during activation and also improving shearing

efficiency by reducing the necessary shearing force.52 Accordingly using

DVS ram block instead of the shearing blind ram block for the BSR in the

DWH BOP would have allowed the BSR to shear greater range of pipe

with the maximum 4000 psi available to the emergency system.53

The improved shearing efficiency of double rams was further

demonstrated by testing by West Engineering Services in 2004 for MMS

that showed double blades lower the required shear force and

therefore required hydraulic pressure by factor of approximately 20%

when compared to BSRs with single blade and straight blade.54 For

the DWH BOP Camerons DVS was also superior to the shearing blind

ram because the DVS blade length was maximized to increase shearing

capabilities.55 BP must have known about these advantages of the DVS

over the shearing blind ram which Cameron touted inits

product literature

as shown below.56

BP-HZN-BLY00294352-59

50Deposition of Jack Erwin June 6-7 2011 6524 661

51

Cameron EB 852D Exhibit 7001

52 Cameron EB 852D Exhibit 7001 deposition of Jack Erwin June 6-7 2011

4616-19


West Engineering Services Shear Ram Capabilities Study for U.S Minerals

Management Service Requisition No 3-4025-1001 page 3-5 September 2004

Cameron EB 852D Exhibit 7001

56Cameron EB 852D 13 Exhibit 7001

22


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5Rs -vs- DYS

5hearin BLindRams

Dcuble ShearRams

Longer packer fatigue Life Require Less shear force

CapabLe of shearing Larger

diameters

No toss of fatigue life

Fig Comparison of Shearing Blind Ram versus DVS rams from

Cameron Product Literature.57

DVS rams and blades for an 18-3/4 inch wellbore 15000 psi TL BOP

which could have been used in the DWH BOP were available from

Cameron at least as early as 2002.58 Cameron sales representative also

acknowledged that by 2009 or 2010 DVS was much more used ram

than the SBR and the DVS ram was considered to be the best in practice

at that time.59

BP also did not implement Camerons tandem boosters which feature

two-part piston that increases shearing force without additional wear on the

packers.6 The tandem boosters were available at least as early as 199861

and use of tandem boosters would have increased the shear force of the

BSR on the DWH BOP If BP had used DVS rams with blades that

covered the entire well bore the BSR most likely would have successfully

sheared the off center drill pipe and sealed the well preventing the

blowout

Cameron EB 852D 13 Exhibit 7001

58Cameron 2002 Replacement Parts Catalog pg 108 BP-HZN

BLY0036641




23


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BP and Transocean Failed to Upgrade the BOP to Include

Second BSR

second BSR installed below the CSR would provide redundancy and

significantly improve the reliability of both shearing pipe in the BOP and

sealing the well If drill string is suspended and sheared first with the

CSR i.e Super Shears during an emergency the drill pipe should fall

clearing the BSR located below the casing ram This allows the lower BSR

to close and seal without pipe interference in its bore Moreover

Cameron sales representative testified that by 2009 or 2010 most of the

rigs had double BSRs.62

BP and Transocean Failed to Upgrade to Camerons MarkIll BOP Control Pod

The DWH BOP used Cameron Mark II BOP control pods63 with double coil

solenoids and batteries that were not rechargeable and the charge of which

could not be monitored from the rig.64 As discussed above properly

functioning control pod solenoids and batteries are needed to operate the

AMF system and are critical components for safe and effective BOP BP

and Transocean failed to upgrade to Mark Ill control pods that have been

available since 2006.65

62


63


64


65Deposition of David McWhorter July 7-8 2011 28917-20

24


25/121


Mark Ill control pods have rechargeable batteries66 and the charge on the

batteries can be monitored from the rig.67 Mark Ill control pods also have

improved singlecoil

solenoids with higher pulling force68 which eliminatesthe potential incorrect wiring problem of the dual coil solenoids used in

Mark II control pods and found in yellow pod solenoid 103Y of the DWH

BOP Moreover Cameron corporate representative has testified that

Cameron made its customers aware of the new Mark Ill system and its

improvements over the Mark II system and that Transocean was aware of

the Mark Ill system in 2006.69

BP Failed to Implement BAST by Relying Solely on MUX

Cables for EDS

All methods of activating the DWH EDS relied on communications

transmitted by MUX cables from the rig down to the BOP DWH rig crew

members testified that they attempted to activate the EDS system after the

explosion but were unsuccessful The EDS may have failed to activate due

to physical damage to the MUX cables caused by the explosion An ACS

could have been used as redundant means of communication between

the DWH rig and the BOP Cameron had ACS available when the DWH

was being configured.7 redundant ACS system could provide BOP

communications and control in the case of an emergency even if MUX

cables were damaged

BP and Transocean Failed to Implement BAST by Using

EDS-1 Instead of EDS-2

Cameron could program various EDS sequences into the DWH BOP

depending on what was requested by BP and Transocean.71 The DWH

BOP implemented an EDS program called EDS-1 that specifies

predetermined sequence of emergency disconnect events such that if the

66


67


68

Deposition of Jack Erwin June 6-7 2011 37014 3716

69

Deposition of David McWhorter July 7-8 2011 3587 3606

70


71


25


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EDSI- button is pushed the predetermined sequence of events will

occur.72 EDS-1 for the DWH was programmed to close the BSR and then

disconnect theLMRP.73

AnotherEDS

sequence was available onDWH

called EDS-2 whereby the CSR closed before the BSR closed.74 Because

EDS-2 first applies the CSR which has capabilities the BSR does not

activation of EDS-2 is more likely to successfully shear the pipe and seal

the well.75 Although the CSR is not designed to seal the wellbore

activation of the CSR first would have centered the drill pipe for the BSR

making it much more likely that the BSR would completely shear the drill

pipe and seal the well BP and Transocean failed to implement BAST by

having Cameron program the EDS-1 sequence as the primary disconnect

sequence for the DWH BOP instead of EDS-2 which was more likely to

successfully seal the well if activated

VI THE UNDERCHARGED BLUE CONTROL POD BATTERIES AND

INCORRECTLY WIRED YELLOW CONTROL POD SOLENOID

103Y MAY HAVE BEEN CONTRIBUTING CAUSES OF THE BOPS

INABILITY TO STOP THE BLOWOUT

As discussed above when the AMF/Deadman is activated it causes the

BSR to fire But the AMF/Deadman can only be activated if at least one of

the control pods is functioning properly which requires charged batteries

and working solenoids Based on my review of the post-incident testing of

the BOP and related deposition testimony76 it appears that neither was

true

72

Deposition of Jack Erwin June 6-7 2011 2714 -2810




76Deposition of Robert Turlak July 28-29 2011 22817 2295 deposition of Edward

Gaude September 19 2011 13011-22 testifying that if two coils in single solenoid

are wired in opposite directions the electromagnetic fields would oppose each other

and cancel out and the solenoid valve would not operate 2103-8 testifying that if

solenoid is not wired correctly it will not function correctly

26


27/121


Undercharged Blue Control Pod Batteries

During post incident forensic testing by DNV of the blue control pod

batteries the 27 volt battery registered low charge as shown below.77

Blue P01 VoLts Yellow Pod Volts

Batten- Test Test Test Test

SEMA9V 8.9 8.9 3.7 8.7

SEMB9V 8.7 8.7 8.4 8.4

Solenoid TransclucerC7V 1.1 1.0 2S.2 28.2

Fig BOP Control Pod Battery Measurements from the DNV

report.78

Due these to low charge in the 27 volt battery it is very unlikely that the

blue control pod would have had sufficient power to activate the

AMF/Deadman at the time of the incident

Incorrectly Wired Yellow Control Pod Solenoid 103Y

Post incident forensic testing by DNV also showed that one of the two coils

from yellow control pod solenoid 03Y had been incorrectly wired and 03Y

failed to activate either yellow control pod SEM during bench testing.79 As

result of 103Y being incorrectly wired the two coils had opposite

polarities and the electromagnetic fields generated by the two coils would

largely cancel each other out and could prevent 03Y actuating the BSR in

response to the AMF/Deadman circuit in the yellow pod

DNV Report Vol page 42

78DNV Report Vol Table page 42

DNV Report Vol page 44 The results of solenoid 103Y testing are inconclusive

because 03Y worked properly when connected to and operated by SEM and SEM

as would have occurred in the field Laboratory Notes from DNV testing of 103Y

016862 Exhibit 3130

27


28/121


The AMF/Deadman Likely Failed to Actuate the BSR

because of Low Blue Pod Battery and the Incorrectly Wired

Yellow Pod Solenoid

Even though the BOP had redundant mechanisms for actuating the BSR in

response to the AMF/Deadman conditions it appears likely that both

mechanisms failed The low battery charge measurements for the blue pod

27 volt battery pack suggest that it did not have enough charge to power

the two blue pod SEMs at the time of the incident which would prevent the

blue pod from activating the BSR The incorrect wiring on solenoid 103Y

suggests that because each coil received the same voltage80 and the two

coils were activated simultaneously as is the normal operation during AMF

activation81 the magnetic fields from the two coils would cancel each other

out and would prevent the yellow pod from activating the BSR.82 It is

therefore likely that the AMF/Deadman failed to activate the BSR as

result of the low charge on the 27 volt blue pod battery and the incorrectly

wired yellow pod solenoid O3Y

The BSR Likely Would Have Completely Sheared the Drill

Pipe and Sealed the Well if the BSR had been Activated

when the Drill Pipe was Centered

The undercharged blue pod batteries and incorrectly wired solenoid 03Y

may have prevented the AMF/Deadman from properly functioning at the

time of the incident and activating the BSR.84 If the drill pipe was centered

at the time of the incident and did not become off-center until later then

activating the BSR probably would have completely sheared the drill pipe

and sealed the well preventing the blowout

80

Deposition of Edward Gaude September 19 2011 1387-12

81

Deposition of Edward Gaude September 19 2011 131 9-16

82Deposition of Edward Gaude September 19 2011 131 23 1323

83As discussed above there is evidence that suggests the AMF/Deadman function did

not activate the BSR but overall the evidence is inconclusive on this point There is

also evidence that suggests the AMF/Deadman may have act ivat ed t he BSR

84It is possible for example that the BSR was activated at later time by the ROy

28


29/121


As discussed above undercharged blue pod batteries would have been

avoided if BP and Transocean had implemented Camerons Mark Ill BOP

control system that uses rechargeable control pod batteries and allowsremote monitoring of battery charge from the rig maintenance program

based on recurring disassembly inspection and recertification as opposed

to Transoceans condition-based maintenance probably would have also

detected the undercharged blue pod batteries and would have provided an

opportunity to replace them will fully charge and functional batteries

Similarly implementation of Camerons Mark Ill BOP control system with

single coil solenoids would have prevented the problem of incorrectly wired

solenoids as found in 03Y recurring recertification based maintenance

program probably would have detected that 103Y was incorrectly wired

and would provided an opportunity to replace 103Y with properly

functioning solenoid

reserve the right to modify this report and to supplement my opinions if

additional data becomes available and in response to reports served by

other parties

Dated January 17 2012

Dr Glen St vick P.E

29


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APPENDIX


31/121

MDL

NO

2179

In

re

OilSpillby

the

OilRig

DeepwaterHorizoninthe

GulfofMexico

onApril20

2010

DR

GLEN

STEVICK

SOURCE

RELIANCE

APPENDIX

BP-HZN-21

79MDL00056656-56936

BP-HZN-BLYOO1

24026

BP-HZN-BLYOO1

24588-124698

ProDerties

ofPart

01366513

of65

Pages


32/121

BP-HZN-BLYOO1

78528-1

78530

Properties

ofPart01366516

Collar

Float

BP-HZN-BLY00294035-294036

5/31/2010

Wong

email

to

Abbassian

re

MBI

HearingTranscripts

BP-HZN-BLY00294350-294351

6/8/2010

Diasemailto

Abbassian

re

Assignment/Paul

DiasBOPsystems

BP-HZN-BLY00294352-294359

5/27/2010

Questionsfrom

Fereidoun

Abbasian

May

27th

BP-HZN-BLY00346210-346212

7/1/2010

DeepwaterH

orizon

Incident

Investigation

--

CF1-NTF1O

FloatCollarFailure

BP-HZN-BLYOO35O1

58-3

50159

5/13/2010

DeepwaterH

orizon

Incident

Investigation

--

Preliminary

F

actual

Critical

FactorOutcome

Form

BP-HZN-BLY00366307-366448

00/00/2002

Cameron

2002

Replacement

Parts

Catalog

BP-HZN-CECO1

1425

7M45AP

Float

CollarDrawing

BP-HZN-CEC030029-30030

10/11/2004

Letter

Agreem

ent

forConversion

ofVBR

to

TestRam

b

etween

Transocean

and

BP

BP-HZN-CEC030137

Spreadsheet

re

Casing

Thread

Damage

BP-HZN-MBI00061

305-6

1

403

4/14/2009

IntermoorMODU

Mooring

AnalysisReportforBP

BP-HZN-MB100128436-128438

4/16/2010

Paikattu

ema

iltoMorelre

Actual

vs

model

9-7

/8

in

liner

run

BP-HZN-MBIOO1

28489-128490

4/17/2010

Gagliano

em

ailto

Moreletalre

Revised

OptiCem

Reportwith

additional

Centralizers

BP-HZN-MB10012961

6-129619

4/28/2010

Bob

KaluzaInterview

Notes

BP-HZN-MBIOO1

34806-1

34834

DeepwaterH

orizon

--

HAZOP

ofWellControl

Systems

BP-HZN-MBIOO1

37364-1

37377

4/20/2010

Halliburton

9

.875

Foamed

Production

Casing

PostJ

ob

Report

BP-HZN-MB100294826-294833

1/1

4/2010

BP

Application

for

Revised

New

Well

CAM_

CIV_

001

9664-1

9819

00/00/2006

Cameron

2006

Drilling

Replacement

Parts

Catalog

CAM_

CIV_

0370157-370165

6/28/2006

Engineering

Bulletin

Errata

Sheet

re

ShearingCapabilities

ofCameron

Shear

Rams

CAM_

DIV_

03701

00-3

701

16

7/9/2010

Cameron

En

gineering

Bulletin

re

Shearing

Capabilities

of

Cameron

Shear

Rams

DECO77-006509-6528

1/21/2008

Cameron

En

gineering

Bulletin

re

Shearing

Capabilities

of

Cameron

Shear

Rams

1M5054-0

16139-1

6143

1/27/2004

Engineering

Bulletin

Errata

Sheet

re


ofCameron

Shear

Rams

TRN-INV-00580489-580497

3/23/2007

Engineering

Bulletin

Errata

Sheet

re


ofCameron

Shear

Rams

TRN-INV-03489834-3489863

NASA/DNV

Summary

ofTestPreparation

Sheet

BOP-Ol

TestSolenoid

at

Deep

Sea

Temperture

and

Pressure

TRN-MDL-00286767

3/31/2009

Transocean

WellControl

Hand

book

TRN-MDL00607699-607707

8/6/2007

Cameron

En

gineering

Bulletin

Revision

Ex

257

02/00/2011

ChiefCouns

elsReportto

National

Commissionon

the

BP

Deepwater

Horizon

OilSpill

01/00/2011

FinalReport

tothe

Presidentre

Deepwater

The

GulfOil

Disaster

and

the

Futureof

Offshore

Drilling

11/16/2010

National

Academy

ofSciences

Interim

Reporton

Causes

ofBlowout

Republicofthe

Marshall

Islands

Office

ofthe

MaritimeAdministratorDeepwater

Horizon

MarineCasua

ltylnvestigaton

Report

of65

Pages


33/121

9/14/2011

The

Bureau

ofOcean

Energy

Management

Regulationand

Enforcement--

Report

Regarding

th

e

Causes

ofthe

April20

2010

Macondo

WellblowoutJITReport

4/22/2011

United

States

Coast

Guard

ReportofInvestigation

intothe

Circumstances

Surrounding

the

Explosion

Fire

Sinking

and

Loss

ofEleven

Crew

Mem

bers

Aboard

the

MobilOffshore

DrillUnitDeepwater

Horizon

in

the

GulfofMexico

April2

0-222010

3/20/2011

DNV

Report

EP030842

forBOEMRE

Volumes

and

II

6/22/2011

Transocean

Investigation

ReportVolumes

and

II

9/8/2010

BP

Deepwate

r

HorizonAccidentInvestigation

ReportBly

Report

6/8/2011

Transoceans

Response

to

USCG

DraftReport

6/6/20

Erwin

Jack

CarterDeposition

Transcript

6/7/20

Erwin

Jack

CarterDeposition

Transcript

6/29/2011

Hay

MarkDavid

Deposition

Transcript

7/6/2011

Kenney

Gary

Deposition

Transcript

6/20/2011

LeNormand

William

Deposition

Transcript

6/21/2011

LeNormand

William

Deposition

Transcript

7/7/2011

McWtiorter

David

Deposition

Transcript

7/8/2011

McWtiorter

David

Deposition

Transcript

3/14/2011

PleasantCh

ristopher

Deposition

Transcript

3/15/2011

PleasantCh

ristopher

Deposition

Transcript

7/5/2011

Thompson

NeilDeposition

Transcript

7/20/2011

McWtiorter

James

Owen

Deposition

Transcript

7/21/2011

McWtiorter

James

Owen

Deposition

Transcript

7/18/2011

WhitbyMelvy

Deposition

Transcript

7/19/2011

WhitbyMelvy

Deposition

Transcript

6/30/2011

Hay

MarkDavid

Deposition

Transcript

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HBRA

Flow

and

Force

Calculation-Odmund

HBRA

Thermal

Expansion

Calculation

BOP

Data

F

iles

04182011

through

06232011

DNV

daily

notebook

entries

testing

spreadsheets

laserscanning

data

BOP

Image

files

04182011

throough

06212011

DNV

daily

pictures

taken

ofinvestigation

BOP

Video

file

listing

04182011

through

06222011

DNV

inventoryof

videofiles

taken

of

investigation

8/27/2010

DNV

Report

No

201

0-1

220

G0M

vs

Norway

from

OLF/NOFO

Summary

ofdifferences

between

offshore

drilling

regulations

in

Norway

and

U.S

GulfofMexico

9/1/2004

API

Recomme

nded

Practice

63

Third

Edition

March

199

7

Reaffirmed

September

2004

Recommended

Practices

for

Blowout

Prevention

Equipment

SystemsforDrilling

Wells

3/1/2011

DHSG

Final

Report

9/1/2010

BP

Reportre

Deepwater

Horizon

Containment

and

Respo

nse

and

Lessons

Learned

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Bea-G

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Ex

pertReportPis

8/26/20

George

Birch

ExpertReportPis

8/26/2011

Andrew

Hurs

t

ExpertReportP15

8/26/2011

Gregg

Perkin

ExpertReportP15

8/26/2011

David

Pritchard

ExpertReportP15

8/26/2011

GeoffWebste

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ExpertReportPis

BP

Macondo

Bypass

Plot

Range

4-1

9-1

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Review.x

ls

12/00/2002

West

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8/31/2011

Benge

Glen

ExpertReportUSA

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DrRory

ExpertReportUSA

8/31/2011

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Hu

ffman

Dr

Alan

Expert

ReportUSA

6/29/2011

Cow

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Jame

s

Deposition

Transcript

6/30/2011

Cow

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Jame

s

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Transcript

7/21/2011

Kasal

KalD

eposition

Transcript

4/6/2011

Sims

David

Deposition

Transcript

4/7/2011

Sims

David

Deposition

Transcript

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Casing

Run

Torque

Data

9/19/2011

Gaude

EdD

eposition

Transcript

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3/30/20

Vargo

Richa

rd

Deposition

Transcript

3/31/2011

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Richa

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Deposition

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4/21/2011

Wa

lz

Gregory

Deposition

Transcript

4/22/20

Wa

lz

Gregory

Deposition

Transcript

5/11/2011

Gagliano

Jesse

Deposition

Transcript

9/27/2011

Childs

Greg

Expert

Report

Transocean

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39

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