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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
IN RE: OIL SPILL BY THE OIL RIG * Docket 10-MD-2179DEEPWATER HORIZONIN THE *GULF OF MEXICO ON APRIL 20, 2010 * Section J
*Applies to: * New Orleans, Louisiana
*Docket 10-CV-02771, * April 15, 2013IN RE: THE COMPLAINT AND *PETITION OF TRITON ASSET *LEASING GmbH, et al *
*Docket 10-CV-4536, *UNITED STATES OF AMERICA v. *BP EXPLORATION & PRODUCTION, *INC., et al *
** * * * * * * * * * * * * * * * * *
DAY 27, MORNING SESSIONTRANSCRIPT OF NONJURY TRIAL
BEFORE THE HONORABLE CARL J. BARBIER
UNITED STATES DISTRICT JUDGE
Appearances:
For the Plaintiffs: Domengeaux Wright Roy& Edwards, LLC
BY: JAMES P. ROY, ESQ.556 Jefferson Street, Suite 500Post Office Box 3668Lafayette, Louisiana 70502
For the Plaintiffs: Herman Herman & Katz, LLCBY: STEPHEN J. HERMAN, ESQ.820 O'Keefe AvenueNew Orleans, Louisiana 70113
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Appearances:
For the Plaintiffs: Cunningham Bounds, LLCBY: ROBERT T. CUNNINGHAM, ESQ.1601 Dauphin StreetMobile, Alabama 36604
For the Plaintiffs: Lewis Kullman Sterbcow & AbramsonBY: PAUL M. STERBCOW, ESQ.601 Poydras Street, Suite 2615New Orleans, Louisiana 70130
For the Plaintiffs: Breit Drescher Imprevento
& Walker, PCBY: JEFFREY A. BREIT, ESQ.600 22nd Street, Suite 402Virginia Beach, Virginia 23451
For the Plaintiffs: Leger & ShawBY: WALTER J. LEGER JR., ESQ.600 Carondelet Street, 9th FloorNew Orleans, Louisiana 70130
For the Plaintiffs: Williams Law Group, LLC
BY: CONRAD "DUKE" WILLIAMS, ESQ.435 Corporate Drive, Suite 101Houma, Louisiana 70360
For the Plaintiffs: Thornhill Law FirmBY: TOM THORNHILL, ESQ.1308 Ninth StreetSlidell, Louisiana 70458
For the Plaintiffs: deGravelles Palmintier Holthaus& Frug, LLP
BY: JOHN W. DEGRAVELLES, ESQ.618 Main StreetBaton Rouge, Louisiana 70801
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Appearances:
For the Plaintiffs: Williamson & RusnakBY: JIMMY WILLIAMSON, ESQ.4310 Yoakum BoulevardHouston, Texas 77006
For the Plaintiffs: Irpino Law FirmBY: ANTHONY IRPINO, ESQ.2216 Magazine StreetNew Orleans, Louisiana 70130
For the United States U.S. Department of Justice
of America: Torts Branch, Civil DivisionBY: R. MICHAEL UNDERHILL, ESQ.450 Golden Gate Avenue7-5395 Federal Bldg., Box 36028San Francisco, California 94102
For the United States U.S. Department of Justiceof America: Environment & Natural Resources
Environmental Enforcement SectionBY: STEVEN O'ROURKE, ESQ.
SCOTT CERNICH, ESQ.DEANNA CHANG, ESQ.
RACHEL HANKEY, ESQ.A. NATHANIEL CHAKERES, ESQ.Post Office Box 7611Washington, D.C. 20044
For the United States U.S. Department of Justiceof America: Torts Branch, Civil Division
BY: JESSICA McCLELLAN, ESQ.MICHELLE DELEMARRE, ESQ.JESSICA SULLIVAN, ESQ.SHARON SHUTLER, ESQ.MALINDA LAWRENCE, ESQ.
Post Office Box 14271Washington, D.C. 20004
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Appearances:
For the United States U.S. Department of Justiceof America: Fraud Section
Commercial Litigation BranchBY: DANIEL SPIRO, ESQ.
KELLEY HAUSER, ESQ.ELIZABETH YOUNG, ESQ.
Ben Franklin StationWashington, D.C. 20044
For the State of Attorney General of AlabamaAlabama: BY: LUTHER STRANGE, ESQ.
COREY L. MAZE, ESQ.
WINFIELD J. SINCLAIR, ESQ.500 Dexter AvenueMontgomery, Alabama 36130
For the State of Attorney General of LouisianaLouisiana: BY: JAMES D. CALDWELL, ESQ.
1885 North Third StreetPost Office Box 94005Baton Rouge, Louisiana 70804
For the State of Kanner & Whiteley, LLC
Louisiana: BY: ALLAN KANNER, ESQ.DOUGLAS R. KRAUS, ESQ.701 Camp StreetNew Orleans, Louisiana 70130
For BP Exploration & Liskow & Lewis, APLCProduction Inc., BY: DON K. HAYCRAFT, ESQ.BP America Production 701 Poydras Street, Suite 5000Company, BP PLC: New Orleans, Louisiana 70139
For BP Exploration & Kirkland & Ellis, LLP
Production Inc., BY: J. ANDREW LANGAN, ESQ.BP America Production HARIKLIA "CARRIE" KARIS, ESQ.Company, BP PLC: MATTHEW T. REGAN, ESQ.
300 N. LasalleChicago, Illinois 60654
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Appearances:
For BP Exploration & Covington & Burling, LLPProduction Inc., BY: ROBERT C. "MIKE" BROCK, ESQ.BP America Production 1201 Pennsylvania Avenue, NWCompany, BP PLC: Washington, D.C. 20004
For Transocean Holdings Frilot, LLCLLC, Transocean Offshore BY: KERRY J. MILLER, ESQ.Deepwater Drilling Inc., 1100 Poydras Street, Suite 3700Transocean Deepwater Inc.: New Orleans, Louisiana 70163
For Transocean Holdings Sutherland Asbill & Brennan, LLPLLC, Transocean Offshore BY: STEVEN L. ROBERTS, ESQ.Deepwater Drilling Inc., RACHEL G. CLINGMAN, ESQ.Transocean Deepwater Inc.: 1001 Fannin Street, Suite 3700
Houston, Texas 77002
For Transocean Holdings Munger Tolles & Olson, LLPLLC, Transocean Offshore BY: MICHAEL R. DOYEN, ESQ.Deepwater Drilling Inc., BRAD D. BRIAN, ESQ.Transocean Deepwater Inc.: LUIS LI, ESQ.
355 S. Grand Avenue, 35th FloorLos Angeles, California 90071
For Transocean Holdings Mahtook & LafleurLLC, Transocean Offshore BY: RICHARD J. HYMEL, ESQ.Deepwater Drilling Inc., 600 Jefferson Street, Suite 1000Transocean Deepwater Inc.: Post Office Box 3089
Lafayette, Louisiana 70501
For Transocean Holdings Hughes Arrell Kinchen, LLPLLC, Transocean Offshore BY: JOHN KINCHEN, ESQ.Deepwater Drilling Inc., 2211 Norfolk, Suite 1110Transocean Deepwater Inc.: Houston, Texas 77098
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Appearances:
For Halliburton Energy Godwin Lewis, PCServices, Inc.: BY: DONALD E. GODWIN, ESQ.
BRUCE W. BOWMAN JR., ESQ.FLOYD R. HARTLEY JR., ESQ.GAVIN HILL, ESQ.
1201 Elm Street, Suite 1700Dallas, Texas 75270
For Halliburton Energy: Godwin Lewis, PCServices, Inc.: BY: JERRY C. VON STERNBERG, ESQ.
1331 Lamar, Suite 1665Houston, Texas 77010
Official Court Reporter: Jodi Simcox, RMR, FCRR500 Poydras Street, Room HB-406New Orleans, Louisiana 70130(504) [email protected]
Proceedings recorded by mechanical stenography usingcomputer-aided transcription software.
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I N D E X
Page
Alexander John GuideDirect Examination By Ms. Karis: 8574
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THE DEPUTY CLERK: All rise.
THE COURT: Good morning, every one.
All right. Before we resume BP's case in chief,
do we have any preliminary matters?
MR. BRIAN: Yes, Your Honor. Brad Brian for
Transocean.
We've circulated a list of a single exhibit
call-out that we wanted to offer on behalf of Transocean on our
cross-examination of Lee Lambert. It's been distributed tocounsel with no objections, so I would offer this exhibit to be
admitted.
THE COURT: All right. Without objection, those are
admitted.
MR. REGAN: Good morning, Your Honor. Matt Regan on
behalf of BP.
I have exhibits for four witnesses. They're the
exhibits that were offered for Mr. Lambert, Mr. Lirette,
Mr. Lewis, all last Wednesday, and then Mr. Zatarain on
Thursday.
THE COURT: Okay. Are there any remaining objections
to these exhibits by BP?
Hearing none, those are admitted.
MR. REGAN: Thank you, Your Honor.
THE COURT: Sure.
MS. ANDRE: Good morning, Your Honor, Abby Andre for
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the United States.
We have a list of exhibits and call-outs used
during our cross-examination of Mr. Zatarain. We exchanged
them with the parties, and there were no objections. We'd like
it offer them into evidence.
THE COURT: Are there any remaining objections to the
United States' exhibits?
Without objection, those are admitted.
MS. KARIS: Good morning, Your Honor, Hariklia Karison behalf of BP.
I have a list of exhibits that we circulated for
Mr. Shaw. We received no objections, so we would offer them to
the Court at this time.
THE COURT: Any remaining objections to BP's
exhibits?
Without objection, those are admitted.
MS. KARIS: Thank you, Your Honor.
MR. IRPINO: Good morning, Your Honor, Anthony Irpino
for the PSC.
I have two lists of exhibits, one in connection
with the examination of Neil Shaw, the second in connection
with the examination of Mr. Zatarain. We have sent both of
those lists around to all of the parties. We have received no
objections, so we offer, file, and introduce those documents
and exhibits into evidence.
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THE COURT: All right. Any objections?
Hearing none, those are admitted.
MR. IRPINO: Thank you, Your Honor.
THE COURT: Sure.
MR. BROCK: Good morning, Your Honor, Mike Brock for
BP.
Just one administrative matter. I have -- BP
has circulated its list of videotape that it intends to play
during its case in chief. We, of course, have already playedthree tapes. And in the remaining portion of our case in
chief, we will play the depositions of Mr. McMahan, Mr. Patton,
Mr. Lindner, Mr. Garrison, and Mr. Gardner. There are no
objections to those depositions, other than the Garrison and
Gardner matter which the Court resolved late last week.
The remaining witness that was on our list was
Mr. Sabins, and we do not intend to play his tape. I think
there was a letter brief filed late last night, but the Court
need not address that issue. We will not play his tape.
THE COURT: So that's moot?
MR. BROCK: Yes, sir, that's moot.
THE COURT: Okay. Very well.
MS. KARIS: I'm back, Your Honor.
THE COURT: Okay.
MS. KARIS: I'm going to be conducting Mr. Guide's
examination.
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ALEXANDER JOHN GUIDE - DIRECT
THE COURT: All right.
MS. KARIS: BP calls Mr. Guide as our next witness.
(WHEREUPON, ALEXANDER JOHN GUIDE, having been duly
sworn, testified as follows.)
THE DEPUTY CLERK: Please state your full name and
correct spelling for the record.
THE WITNESS: Alexander John Guide,
A-L-E-X-A-N-D-E-R, J-O-H-N, G-U-I-D-E.
MS. KARIS: May I proceed, Your Honor?THE COURT: Yes.
MS. KARIS: Thank you.
DIRECT EXAMINATION
BY MS. KARIS:
Q. Good morning, Mr. Guide.
A. Good morning.
Q. Which company do you currently work for?
A. BP.
Q. What position did you hold on April 20th of 2010?
A. Wells team leader for the Deepwater Horizon.
Q. And as the wells team leader for the Deepwater Horizon,
were you the supervisor for the well site leaders who were
actually on the rig?
A. I was.
Q. And how long did you hold that position?
A. Three years.
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ALEXANDER JOHN GUIDE - DIRECT
Q. Okay. And we're going to go back to your job as the wells
team leader, but before we do that, I'd like to talk a little
bit about your background.
Can you tell the Court, where did you grow up?
A. Pittsburgh, Pennsylvania.
THE COURT: Excuse me, one second.
(Discussion off the record.)
MS. KARIS: May I continue?
THE COURT: Yes, go ahead.BY MS. KARIS:
Q. Do you have any college degrees, Mr. Guide?
A. Yes.
Q. Can you tell us what degrees you have.
A. I have a Bachelor of Science in chemical engineering with
a petroleum option.
Q. And what do you mean by having a "petroleum option"?
A. In addition to my chemical engineering degree, I took six
courses in petroleum engineering.
Q. When did you obtain your degree?
A. 1980.
Q. All right. And what did you do upon graduating with a
degree in 1980?
A. I went to work for Texaco in Morgan City, Louisiana.
Q. And since you've graduated in 1980, have you remained in
the oil and gas industry the entire time up through today?
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ALEXANDER JOHN GUIDE - DIRECT
A. Yes.
Q. All right. And I'll -- let's talk about some of the jobs
that you've held in the past 30-plus years. First of all, can
you tell the Court, what was your first job after graduating
with a degree in engineering?
A. I worked on a production platform in the Tiger Shoal field
in south Louisiana.
Q. And what were some of your duties?
A. Well testing, mainly.Q. How long did you remain in that position?
A. For the first six months, sort of training.
Q. Okay. And then how long did you remain in -- with Texaco
in Morgan City, Louisiana?
A. Five years.
Q. All right. And what did you do next? Can you walk us
through your employment history.
A. Yes. So at Texaco, I was a production engineer,
completion engineer, and then a drilling engineer. That was
for the first five years.
Q. So you worked for Texaco for the first five years of your
career in a variety of different engineering-related positions?
A. Yes.
Q. Then what did you do?
A. Then I worked for Conoco as a drilling engineer and a well
site leader.
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ALEXANDER JOHN GUIDE - DIRECT
Q. Where were you based when you worked for Conoco?
A. Lafayette, Louisiana.
Q. Okay. And you said you were a drilling engineer. Did
that mean you were working on designing engineering plans for
wells?
A. Yes.
Q. Okay. And was that offshore drilling as well as onshore
drilling?
A. Yes, both.Q. Okay. And then what did you do after working for Conoco
as a drilling engineer?
A. Well, I actually went from Lafayette, with Conoco, to the
Middle East. And I worked for a Conoco affiliate called Dubai
Petroleum Company for -- from '88 to '91, where I also was a
drilling engineer and a drilling well site leader.
Q. And was that also for offshore?
A. Yes.
Q. Okay. And how long did you remain with Conoco in Dubai?
A. Three years.
Q. And after finishing your duties in Dubai in offshore
drilling, what did you do next?
A. I went to work for a small independent oil company in --
oil and gas company in Pittsburgh as their chief engineer. And
in that, I did all the different engineering. I did the
reservoir engineering, the drilling engineering completions,
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ALEXANDER JOHN GUIDE - DIRECT
went to the field and fracked wells, acquisitions. We bought
fields, sold fields.
Q. And did that involve offshore work as well?
A. That did not.
Q. Did not.
Okay. And then what did you do after you worked for
Meridian?
A. I went to work for Vastar back in Lafayette, Louisiana.
Q. How long did you remain in Lafayette with Vastar?A. Until 2000.
Q. And tell us what you were doing with Vastar in Lafayette,
Louisiana.
A. I had two different positions. One was -- I was called
the principal drilling engineer where I was in charge of all
the drilling operations in the South Pass 60 field. After
that, I was called the principal production engineer of wells
in charge of all the completions workover in the production for
the eight different platforms in the Gulf of Mexico, in the
South Pass field.
Q. Okay. And then what did you do in 2000?
A. I transferred to Houston with Vastar as the lead drilling
engineer for the Horn Mountain deepwater development, which is
in the Mississippi Canyon 127. And that's when Vastar was
purchased by BP.
Q. Can you describe for the Court briefly, what is the
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ALEXANDER JOHN GUIDE - DIRECT
Horn Mountain project?
A. A deepwater development, once again, Mississippi Canyon,
127, in 5500 feet of water. It's about 50 miles off the coast.
Q. Okay. And you said you were the lead drilling engineer.
And what were your responsibilities as the lead drilling
engineer for the Horn Mountain development?
A. I designed all the wells in the field, from the drilling
aspect as well as was in charge of building of a rig that was
going to go on the platform after the semi left.So if I could explain. The field was drilled with a
semisubmersible rig, and then the platform was set. And then
after the platform was set, there was a smaller rig put on the
platform. I was in charge of the building of the rig and,
consequently, tying all the wells back from the floor to the
platform.
Q. So were you working on well design at that point?
A. Yes.
Q. And how long did you remain in that position as the lead
drilling engineer for the Horn Mountain development?
A. Three years.
Q. What did you do then, which takes us to approximately
2003?
A. I went to the Mad Dog development, which is also a
deepwater development in Green Canyon, southern Green Canyon,
part of the Gulf of Mexico, where I was the -- monitored the
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ALEXANDER JOHN GUIDE - DIRECT
finishing of the rig there, building for the platform. And
then I was the drilling superintendent for the development.
Q. Okay. And what are the -- when you say "drilling
superintendent," is that the same thing as a well team leader,
just a different title?
A. Yes, it is.
Q. All right. So what did you do as the drilling
superintendent for the Mad Dog project?
A. We implemented the drilling and completion plans that theengineering department provided to us.
Q. So did you have a similar role and responsibility for the
Mad Dog project with what you had in connection with the
Macondo project?
A. Yes.
Q. And, again, was the Mad Dog project a deepwater well
similar to the Macondo project?
A. Yes.
Q. Okay. What did you do then, after you completed your work
with the Mad Dog project?
A. Well, while I was a drilling superintendent for Mad Dog, I
also was assigned to be the drilling superintendent for
Holstein, another deepwater development in Green Canyon. They
were only about 13 miles apart, so it made sense.
So first I was the drilling superintendent for both
of these developments. Then after that, in September of 2007,
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ALEXANDER JOHN GUIDE - DIRECT
I became the wells team leader for the Deepwater Horizon.
Q. So you were the wells team leader for the
Deepwater Horizon from October of 2007?
A. The end of September.
Q. I'm sorry. September of 2007.
And did you remain in the position of drilling
superintendent or wells team leader for the Deepwater Horizon
from 2007 through the time of the incident in April of 2010?
A. Yes.Q. So by the time of this incident, you had been working with
the Deepwater Horizon for a three-year period?
A. Yes.
MS.KARIS: All right. And if we could pull up
D-4941, please.
BY MS.KARIS:
Q. Mr. Guide, does this describe -- I'm sorry. I'll let you
get your glasses there.
A. Yes.
Q. Does this accurately describe the experience that you had
had in the oil and gas industry from the time that you
graduated up through the time of the incident, 33 years of
experience in the industry with working for a variety of
companies, three companies, drilled over 35 to 40 wells? Is
that accurate?
A. Well, that would be just deepwater wells alone.
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ALEXANDER JOHN GUIDE - DIRECT
Q. Deepwater wells alone?
A. Yes.
Q. And then you have 20 -- of those 33 years, 23 years has
been spent either in drilling completions, production, or
workover work?
A. Yes.
Q. All right. And then specifically with respect to
operations, you've had ten years of experience?
A. Yes.Q. And seven of those years have been in the Gulf of Mexico
as a drilling superintendent or wells team leader, same
position?
A. Yes.
Q. And then three of those years, as we just said, were
specific to the Deepwater Horizon?
A. Yes.
Q. So at the time of this incident, you had 33 years of
experience in the industry?
A. 30.
Q. 30, I'm sorry. This takes us up to date.
A. Yes.
Q. Thank you.
MS. KARIS: We can take that down, please. Thanks.
BY MS. KARIS:
Q. Now, I'd like to discuss with you some of your
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ALEXANDER JOHN GUIDE - DIRECT
responsibilities as the wells team leader for the
Deepwater Horizon. Could you describe for the Court what that
position entailed.
A. It was the operations portion of the process. The
drilling engineering team would develop a plan, and they would
hand it over to the operations team, which is what the wells
team leader ran, and then we would implement their plan.
Q. So the drilling engineering team would design the plan and
then your team would execute the implementation of that plan;is that a fair description?
A. Yes.
Q. Okay. And you said the well site leaders reported to you?
A. Yes, they did.
Q. Tell us what your relationship with the well site leaders
was; that is, what were your responsibilities with respect to
the well site leaders?
A. Well, I was their office liaison. I was their -- the
person that, you know, gave them the direction of what they,
you know, what they needed to do. But, really, I was really
there just to make their job easier, is what it was.
Q. So the well site leaders, were they onshore or offshore?
A. They were offshore.
Q. And your position, was that onshore or offshore?
A. It was onshore.
Q. So you were onshore and they worked offshore on the rigs?
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ALEXANDER JOHN GUIDE - DIRECT
A. Yes.
Q. Now, as a wells team leader, do you have primary
responsibility for designing the well or making engineering
design decisions?
A. No.
Q. Okay. Which team does the engineering design decisions?
A. The engineering team.
Q. Now, as -- in your capacity, though, as the wells team
leader, do you have any role in the engineering process?A. Not the actual process, but I gave input, you know.
Q. And tell the Court how that works. As a wells team
leader, how do you provide input to the drilling engineers as
you're executing the design plan that has been put together by
that team?
A. So they have a -- through all BP, there's a certain
process that's followed to design a well. And then once the
well is designed, the drilling team -- I'm sorry, the drilling
engineering team and all the third-party contractors come
together with myself. And then we -- they basically implement
the plan step-by-step together.
Q. Now, the drilling process has been described by some as a
"team effort." In your experience in the industry, do you
agree with that statement?
A. Yes.
Q. Okay. And why do you agree with the statement that the
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ALEXANDER JOHN GUIDE - DIRECT
drilling process is a team effort?
A. I don't think you could do it if it wasn't.
Q. And what do you mean by that?
A. It's -- wells are -- they're challenging, they're
complicated, and there's just so many pieces -- so many pieces
to it. It would not be possible for one person or even one
group to do it. I mean, you're talking 250 people to actually
drill one well.
Q. And do you rely on a variety of different contractors aspart of that team effort?
A. Yes.
Q. All right.
MS. KARIS: If we could look up -- I'm sorry, put up
D-4316, please.
BY MS. KARIS:
Q. This is a chart of the breakdown of the employees who were
on the Deepwater Horizon on the day of the incident. And on
the right-hand column there, there are a variety of different
contractors, including Transocean, BP, M-I SWACO, Oceaneering,
Weatherford, Dril-Quip, and a variety of others. Is this
typical in drilling a deepwater well to have a number of
contractors, such as what -- the folks that were on the Horizon
on April 20th of 2010?
A. Yes.
Q. Is there anything unusual or atypical about having a
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ALEXANDER JOHN GUIDE - DIRECT
number of these contractors involved in the execution of the
well design?
A. No.
Q. All right. I'd like to talk to you about some of the
members of your team and the Macondo wells team in particular.
MS. KARIS: If we could put up D-4800, please.
BY MS. KARIS:
Q. D-4800 is entitled the "Macondo Drilling Team for
April 20th of 2010." And since you worked with these folks,I'd like to have an opportunity to speak with you about some of
them.
First of all, does this accurately reflect the
organization of the folks who worked in some capacity on the
Macondo well team?
A. Yes.
Q. Okay. We're going to start down here with the well site
leaders. These are the folks that reported to you; correct?
A. Yes.
Q. And then Mr. Cocales, the senior operations engineer, also
reported to you?
A. Yes.
Q. All right. We're going to walk through some of their
functions in a second. But, first of all, the Court has heard
from Mr. Ronnie Sepulvado. And then is Murry Sepulvado his
brother?
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ALEXANDER JOHN GUIDE - DIRECT
A. Yes.
Q. Do they both work for you?
A. Yes.
Q. Tell us how long you have known the Sepulvado brothers and
how long they have worked for you.
A. I first worked with Ronnie and Murry starting in 2000 when
we drilled all the wells at the Horn Mountain development.
Q. Okay. So you had known them at least a decade by the time
of the incident?A. Yes.
Q. And then Mr. Vidrine is listed here, Don Vidrine. How
long had you worked with Don Vidrine?
A. Since January of 2010. I knew him before, but he had
worked for other -- other well team leaders.
Q. Okay. So he came to work with you in January of 2010?
A. Yes.
Q. How did Mr. Vidrine get added to your team? Did somebody
recommend him to you?
A. Yes. He wanted to do something different. He was on a
development -- as in a development project as opposed to an
exploration program. And he wanted to get into exploration.
And so he was recommended.
Q. Okay. And then Earl Lee, is he the fourth well site
leader assigned to your team?
A. Yes.
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ALEXANDER JOHN GUIDE - DIRECT
Q. How would you describe your relationship, your overall
relationship, with the team that reported to you?
A. I think it was great.
Q. Okay. And then we have here Mr. Cocales. His title was
senior operations engineer. Can you tell us what the role of a
senior operations engineer is who reported to you?
A. He really was our main liaison with the other drilling
engineers. Every rig is different in some way or fashion, and
he would be sort of the Deepwater Horizon representativewhenever they were doing the design process for the wells, for
the whole BTB process.
Q. How long had you worked with Mr. Cocales?
A. A couple years.
Q. Okay. And how would you describe your relationship with
Mr. Cocales?
A. It was very good.
Q. Okay. And then going up, again, this is the operations
side of the Macondo wells team; is that correct?
A. Yes.
Q. By "this," I mean on the left-hand side.
A. Yes.
Q. All right. And then you reported to Mr. Sims, who was the
D & C operations manager for exploration and appraisal;
correct?
A. That's right.
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ALEXANDER JOHN GUIDE - DIRECT
Q. All right.
How long had you worked with Mr. Sims?
A. I first started working -- I actually started working for
Mr. Sims in September of 2007.
Q. Okay. And how long have you known Mr. Sims?
A. Since 1997.
Q. And you said you worked for him in September of 2007. In
what capacity did you work for him?
A. Whenever I joined the Deepwater Horizon team, the nameswere different, but he was what was called the wells program
manager and I was a drilling superintendent.
Q. Okay. And then did Mr. Sims subsequently move to a
different role and then come back to being your boss here as
the operations manager?
A. That's correct.
Q. How would you describe your relationship with Mr. Sims?
A. It was very good. He was my friend.
Q. Okay. So you had a friendship with Mr. Sims as well as
him being your boss?
A. Yes. We were friends.
Q. Okay. Now, Mr. Kaluza is one of the well site leaders
that is not on this list but was on the Deepwater Horizon on
the evening of the incident; correct?
A. That's correct.
Q. Okay. Had you known Mr. Kaluza prior to him going to the
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ALEXANDER JOHN GUIDE - DIRECT
Deepwater Horizon?
A. Well, I knew of him.
Q. Had he ever worked with you?
A. No.
Q. And then Mr. Lambert, he was the well site leader trainee
which the Court heard from -- who the Court heard from last
week. He was on the rig on the evening of the 20th as well;
correct?
A. Yes.Q. And can you tell us how you knew of Mr. Lambert?
A. He was -- he was part of the Well Site Leader of the
Future Program, and he was assigned. They -- you know, they --
I knew the guy that ran the program. His name was
Martin Breazeale and he assigned the Well Site Leaders of the
Future to different operations.
Q. And so he was then assigned to the Deepwater Horizon and
to your team?
A. Yes.
Q. Now, we've covered some of the folks on the operations
side here of the Macondo well team. I'd like to now go to some
of the engineering folks. And was this the drilling
engineering team who was assigned as to the Macondo well?
A. Yes.
Q. Now, your -- when did your team, the Deepwater Horizon
team, join the operations at the Macondo well?
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ALEXANDER JOHN GUIDE - DIRECT
A. The Marianas actually -- I'm sorry, the Transocean
Marianas rig started the well. And then we -- we joined it in
February of 2010 at a certain casing point.
Q. Now, that's the operations team.
The engineering team, do you know when they joined
the Macondo wells team?
A. Yes. They actually -- these folks actually planned the
well that the Marianas started. So they would have started
in -- on Macondo in February of 2009, February/March of 2009.Q. So while the operations team changed out, the drilling
engineering team remained with the Macondo well from the
beginning through April 20th; is that accurate?
A. That's correct.
Q. Okay. And is that typical for a well; that is, the
engineering team remains with the well even if the rig team, if
you will, changes out?
A. That's correct.
Q. Why is that?
A. It's for continuity.
Q. Okay. Let's talk about some of the folks here on the
engineering team. Let's start first with Mr. Hafle.
Was he the senior drilling engineer for the Macondo
project?
A. Yes.
Q. Do you know Mr. Hafle prior to Macondo?
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ALEXANDER JOHN GUIDE - DIRECT
A. It's a regimented program that lasts three years where you
go through certain specific development modules that you have
to actually take tests and pass. And then once you -- once you
do all the training and pass all the modules, then you would be
classified as a regular engineer.
Q. So it's a training program where you go through different
training steps before you become a regular drilling engineer;
is that accurate?
A. Yes, that's correct.Q. And by the time Mr. Morel worked on the Macondo project,
had he finished or completed that Challenger program?
A. Yes, he did.
Q. Now, Mr. Hafle and Mr. Morel reported up to Greg Walz, who
was the drilling engineering team leader; correct?
A. That's correct.
Q. First of all, tell us, did you know Mr. Walz?
A. Yes.
Q. Okay. How long had Mr. Walz been with this team?
A. Since March of 2010.
Q. Okay. So Mr. Walz was relatively new to this team?
A. Yes.
Q. Okay. Did you know Mr. Walz prior to him joining the
Macondo team?
A. Yes. I knew -- I met Greg in 2000.
Q. Had you ever worked with him prior to the Macondo team?
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ALEXANDER JOHN GUIDE - DIRECT
A. No.
Q. Now, you've described the various members of this team --
I'm sorry, we skipped Mr. Sprague. He's the drilling
engineering manager. Can you tell us what Mr. Sprague's
responsibilities would have been as the drilling engineering
manager?
A. So there were various groups in the Gulf of Mexico that
had drilling engineering team leaders, like there was
Thunder Horse, Atlantis, different developments. And thenE & A was another one. Mr. Sprague was in charge of drilling
engineering for all the groups. So he was -- so, in essence,
he was the head drilling engineer for BP in the Gulf of Mexico.
Q. Okay. And then they all reported up to Mr. O'Bryan;
correct?
A. Yes.
Q. And then Mr. O'Bryan would have reported up to the
strategic performance unit leader, who at the time was
Mr. James Dupree; correct?
A. That's correct.
Q. All right. Now, based on years of experience that you had
with a variety of these team member, how would you describe the
drilling engineers' and the well site leaders' attitude towards
safety?
A. It was a top priority.
Q. Okay. And what gave you the impression that safety was
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ALEXANDER JOHN GUIDE - DIRECT
their top priority?
A. It was instilled in everybody. It was an obvious thing
that safety was the utmost importance. Plus, it was -- it was
just part of the process. The processes that we had in place
always took safety into account.
Q. Did any of their actions at any time that you worked with
them -- with any of them indicate to you that they were
indifferent to the consequences of their actions?
A. No.Q. Did any of them ever give you the impression that they
were not concerned about the safety and well being of
themselves as well as the others who were associated with this
project?
A. No.
Q. We've talked about the BP team that worked on the Macondo
well. Now I'd like to ask you a little bit about the
Transocean team that worked on the Macondo well.
Did you have an opportunity to interact with
Transocean's crew who worked on the Macondo well once the
Deepwater Horizon arrived in late January or early February of
2010?
A. I did.
Q. Okay. And did you know that crew from your prior
involvement with them the three years that you had been the
drilling superintendent or wells team leader for that team?
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ALEXANDER JOHN GUIDE - DIRECT
A. I did.
Q. And did you have confidence in the Transocean personnel
who were assigned to the Deepwater Horizon?
A. I thought they were the best in the business.
Q. Did you also have an opportunity to interact with the
leadership team of that crew; that is, the folks that worked
onshore?
A. Yes.
Q. That would include Mr. Johnson, Mr. Winslow, and others?A. Yes.
Q. And did you have confidence in Transocean's leadership
team?
A. Absolutely.
Q. Did you believe that Transocean's personnel, both onshore
and the crew that worked on the Deepwater Horizon, cared about
safety?
A. Yes.
Q. And did you believe that they, too, cared about the
consequences of their actions?
A. Yes.
Q. You said that you were assigned to the Deepwater Horizon
for approximately three years. I want to talk about some of
the accomplishments that were achieved while you were the wells
team leader for the Deepwater Horizon.
First of all, approximately how many wells had you
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ALEXANDER JOHN GUIDE - DIRECT
drilled as the drilling superintendent on the Deepwater Horizon
in those three years?
A. Seven or eight.
Q. Okay.
MS. KARIS: And if we can pull up D-4341, please.
BY MS. KARIS:
Q. We have a chart here of all the various wells that the
Deepwater Horizon built while it was working while it was
leased to BP. And I understand you came in here late 2007; isthat correct?
A. Yes. It would have been at the Cortez Bank, which is
KC 244.
Q. And at the bottom here, we have the various numbers. And
I know they're a little difficult to read.
A. Yes. Right here.
Q. Great.
And so all the wells from KC 244 forward to the end
of 2010 were wells that were drilled with you as the drilling
superintendent?
A. That's correct.
Q. And these were all deepwater wells, as we can see from the
depth there; correct?
A. Yes.
Q. And one of them included, of course, the Tiber well which
the Court has heard a little bit about. What was the total
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ALEXANDER JOHN GUIDE - DIRECT
depth of the Tiber well?
A. 35,050 feet.
Q. Was that a record at the time that that well was drilled?
A. It was the deepest oil and gas well ever drilled in the
world.
Q. And you were the drilling superintendent for that, or the
wells team leader at the time?
A. Yes.
Q. And then the Kodiak well is also listed here, 28,760 feet?A. Yes.
Q. You were the drilling superintendent for that?
A. Yes.
Q. Were each and every one of those wells drilled
successfully?
A. Yes.
Q. There's been some testimony in this case about the
relationship of team members as well -- the BP team members as
well as the Transocean team members. And I want to ask you
first, did you have regular occasion to interact with
Transocean where they would express to you the dealings that
were taking place on the rig and then you would express to them
any issues or concerns you had with them?
A. Yes.
Q. And did that include, of course, from time to time
identifying areas where you believed there could be
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ALEXANDER JOHN GUIDE - DIRECT
improvements?
A. Oh, yes.
Q. And did that also include recognition of accomplishments
that the teams were making as they continued to work together?
A. Yes.
MS. KARIS: We can now pull up TREX-4095.1.2, please.
BY MS. KARIS:
Q. We were talking about the accomplishments and we'll walk
through this quickly. Was this -- which is an e-mail fromMr. Little dated June 18th of 2009 to a number of individuals
at BP, Mr. Lacy, Mr. Thierens, Mr. Rainey, Mr. Thorseth and
Mr. Leary and then with a carbon copy to you, and the subject
is the Tiber performance.
And Mr.-- was Mr. Little your boss at the time?
A. Yes, he was.
Q. All right. And so he was Mr. Sims' predecessor?
A. Yes.
Q. It says: "Just to let you know that the Tiber well
through the Paleo" --
Is that "-cene"?
A. Yeah, Paleocene.
Q. -- "-cene has been delivered at Top Quartile performance."
What does that mean?
A. The industry in whole keeps track of several matrix, and
its data that's shared through all the companies, and it's
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ALEXANDER JOHN GUIDE - DIRECT
broken into, you know, the four quarters of performance. And
this well was actually in the top, the top quartile.
Q. Okay. And if we can now look at further up in the e-mail,
4095.1.3. Again, part of the same string.
And then Mr. Thierens, who we've heard some about
says: "This is an outstanding performance, great work.
Sincere thanks to all."
Did you share Mr. Thierens' sentiments that this was
an outstanding performance and great work by this team?A. Yes.
Q. And then Mr. Burns writes: "Nice work, guys. Business as
usual for the Horizon A team."
Is that the team that you were leading at the time?
A. Yes.
Q. Now, in addition to accomplishments at the Tiber well, did
the Deepwater Horizon continue to have an outstanding
performance record, both safety as well as drilling performance
record?
A. Yes.
MS. KARIS: And if we could now look at
TREX-51350.2.3, please.
BY MS. KARIS:
Q. We've heard some about Mr. Johnson. Is Mr. Johnson your
counterpart at Transocean?
A. Yes, he was.
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ALEXANDER JOHN GUIDE - DIRECT
Q. Is he the person you interacted with on a daily basis?
A. Yes.
Q. Okay. And Mr. Johnson sent an e-mail to a number of
individuals, including you, and that's not highlighted there.
And what's the date of this e-mail?
A. April 2nd, 2010.
Q. So you received this e-mail just a couple weeks before
this incident; correct?
A. Yes.Q. And the subject is "Deepwater Horizon, one year recordable
free." Tell us what this e-mail was about.
A. The industry as well as BP keeps track of injuries, and
depending on the severity of the injury, some of them need to
be recorded and reported. And he was just bringing out the
point that the Horizon had gone one year without having any
type of incident.
Q. And he writes and he says: "Please pass on my
congratulations and admiration to the entire Deepwater Horizon
team."
And that entire Deepwater Horizon team would have
included yourself; correct?
A. That's correct.
Q. Okay. And did you share Mr. Johnson's sentiment that the
entire team deserved congratulations and then admiration for
achieving this accomplishment of one year, recordable free
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ALEXANDER JOHN GUIDE - DIRECT
injuries?
A. Yes, I did.
Q. And he goes on to say that "reaching the milestone of
working one year recordable free is a great achievement and
something we should all feel proud of."
Were you proud of that accomplishment?
A. I was very proud.
Q. And it says: "It takes hard work and commitment from the
entire crew, and I would like to say thank you."Finally, it closes by saying: "Let's take one day at
a time, utilize with total commitment and passion all of our
safety tools and begin our quest of working two years
recordable injury free."
Did you agree with that statement?
A. Absolutely.
Q. Do you believe that you were managing the team that
reported to you in a way that was consistent with Mr. Johnson's
goal there, a request of working two years injury-free?
A. I did.
Q. At any time did anybody from Transocean, Halliburton, or
any of the other contractors that we saw listed earlier,
indicate to you that they did not believe that BP shared the
commitment and passion for safety?
A. No.
Q. Did anybody at any time, from any of the contractors that
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ALEXANDER JOHN GUIDE - DIRECT
you worked with as part of this team, ever indicate to you that
they believed BP was pushing them too hard or demanding too
much of them?
A. No.
Q. At any time did anybody from any other contractors
indicate to you they thought -- that they thought you, as the
well team leader, was not managing the team in a way that was
consistent with the goal of safety being the number-one
priority?A. No.
Q. Do you believe that you were managing your team consistent
with the goal of safety being the number-one priority?
A. Yes, I did.
Q. Now, in addition to this accomplishment that Mr. Johnson
notes, did you also have other safety performance milestones
that were achieved with the Deepwater Horizon under your
tenure?
A. Yes.
Q. Can you describe some of those for the Court.
A. Well, the biggest accomplishment by far was reaching seven
years without a day away from work case.
Q. And what does that mean, "seven years without a day away
from work case"?
A. A day away from work case would be where someone got
injured to the point where they actually would have to miss
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ALEXANDER JOHN GUIDE - DIRECT
work. And we had just got to the seven years in a row without
having such an incident.
Q. And was that quite an accomplishment, in your opinion,
having been in the industry for 30-plus years?
A. Yes, it was.
Q. Did you also receive any awards from the MMS for the
performance of the Deepwater Horizon's team?
A. Yes. The Horizon won an award when it was drilling
Atlantis, the Safe Rig of the Year award. And we were also upfor Safe Rig of the Year award in Lake Charles district for
2009.
Q. While you were the drilling superintendent or well team
leader, did any of the other rigs that you were in charge of
also get recognized for the accomplishments of those rigs under
your leadership?
A. When I was the Mad Dog drilling superintendent, the
Mad Dog rig won the Safe Rig of the Year award in the Houma
district one year and came in second the second year.
Q. And so all of those accomplishments were while you were
acting as the wells team leader for BP, managing the well site
leaders who were on those rigs; is that correct?
A. That's correct.
Q. All right. Let's change subjects.
There's been a lot of discussion in this case about
OMS and its application to the Deepwater Horizon, and I promise
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ALEXANDER JOHN GUIDE - DIRECT
you we're not going to go through all of that again. But I do
want to ask you just a few questions on this subject.
As the wells team leader for BP, what was your
understanding for how BP's safety management system applied to
the Deepwater Horizon?
A. We had a bridging document with Transocean's SMS, their
safety management system, and our OMS system. So there was a
bridging document between the two, and it was in the contract.
That was the main -- the main connection.Q. So through the bridging document, OMS supplied the
Transocean safety management system?
A. Yes.
Q. And that was for the operations on the rig offshore;
correct?
A. That's correct.
Q. There has been an assertion in this case and, in fact, a
question asked to Mr. Newman, whether there was any safety
management system, then, that applied to the folks that worked
onshore. You were one of the wells team members who worked
onshore in connection with these operations; correct?
A. That's correct.
Q. Was there a safety management system that applied to you
and the rest of the drilling team who worked onshore?
A. Yes.
Q. What safety management system is that?
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ALEXANDER JOHN GUIDE - DIRECT
A. Well, it all fell under the umbrella of OMS, but the
specific programs were the drilling engineering was -- it's
called "BTB common process," beyond the best common process.
That was their main management system.
And then on the operations side, and it all tied
together, was called "DWOP." It was the drilling wells
operating practices.
Q. And so between beyond the best, BTB, as you referenced it,
DWOP, drilling wells operations practices, was there somethingalso called ETPs, or engineering technical practices?
A. Yes. So then as part of the BTB process, then when you
get into the weeds, so to speak, you then have ETPs, which are
engineering technical practices. You have GPs, which are group
practices. You have site-specific practices. And we actually
had a -- it was called the "OMS library." And so you could
actually go onto this Web site and have access to all the
various processes and procedures and practices.
Q. Okay. It's been suggested that ETPs did not apply to
drilling. Is that accurate?
A. No.
Q. And likewise, is it accurate to say that there was no
safety management that applied to the work that you were doing
in connection with this well?
A. No. We had a very rigorous safety management system.
Q. That's all we're going to do on OMS. Let's talk about
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ALEXANDER JOHN GUIDE - DIRECT
something different now.
Under the Transocean safety management system that
applied to the operations on the rig and then the OMS safety
management system that applied to the engineering or onshore
operations, did you use those programs in order to improve the
safety performance of the team that worked with you as well as
those that you reported to?
A. Yes.
Q. Okay. Let's step back, and can you tell the Court, whenyou say that you believed that your team shared the importance
of safety, what did you do or what programs were you involved
in through BP that you felt improved the safety of the
operations for onshore as well as offshore operations?
A. I thought the most effective one that we used was called
SOC, which was safety observation conversation. Do you want me
to explain?
Q. Well, just list them first, and then we'll go through
them.
A. Okay. SOCs, safety observation conversations. We had
Stop the Job, was one. And so was Pulse Check surveys.
Q. Did you also have something called "safety standdowns"?
A. Yes. Yes, we did.
Q. We're going to talk briefly about each of those. The
first one that you listed was SOCs, safety observation
conversations?
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ALEXANDER JOHN GUIDE - DIRECT
A. Yes.
Q. Was this a program initiated by BP?
A. Yes.
Q. Okay. Tell us how safety observation conversations
worked.
A. So this could apply to anyone, but for myself, when I
would go to the rig, you would walk around and observe people
performing a task. And if you -- you know, once the task was
finished, you would have a conversation with them. And if theywere performing the task safely, then, you know, you would
discuss with them and say, you know, "Yes, I watched what you
were doing. You were doing it right, you know. Thank you."
But on the other hand, if you saw something that you
didn't think was safe, if you had to stop the job, you would.
But let's just say you didn't. Then you would discuss with
them after, okay, so, you know, "You really weren't doing this
right. Do you know why? Do you want me to explain?" And
stuff like that.
Q. Okay. So is it fair to say that it was basically an
observation where you would look at behavior and identify what
was being done right and then also identify areas for
improvement?
A. That's correct.
Q. Okay. Did you personally conduct some of these safety
observation conversations, SOCs, as you call them?
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ALEXANDER JOHN GUIDE - DIRECT
A. Yes, I did.
Q. All right. There's been suggestion that BP only cared
about personal safety and not process safety. Do you agree
with that observation?
A. No. It was -- safety was safety. It was all one piece.
Q. And so when you were doing safety observation
conversations, were you limiting them in any way to just
personal safety and ignoring process safety concerns?
A. No.Q. You also referenced Safety Pulse Checks. First, describe
what is a Safety Pulse Check survey?
A. We would -- there would be a list of questions we would
put together on a form, and we would pass out the form to all
the guys and girls that worked on the rig and ask them to fill
it out.
Q. So who participated in these? The folks that worked on
the rig?
A. Yes.
Q. How often are Safety Pulse Checks given?
A. They were about once a year.
Q. And were Safety Pulse Checks something that began when
Mr. Neil Shaw was the strategic performance unit leader in the
Gulf of Mexico?
A. Yes.
Q. Why were Safety Pulse Checks being conducted?
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ALEXANDER JOHN GUIDE - DIRECT
A. Well, we wanted to know what the people who were doing the
work, how they felt. Did they -- you know, did they -- and
also to get their feedback. You know, it was really about what
things are working good and what things aren't. Just trying to
get their input.
Q. And then did you, as the wells team leader, review the
results of those Safety Pulse Checks?
A. I did.
Q. And did you then pass those results on to your management?A. Yes.
MS. KARIS: If we could look at TREX-47570-N.1,
please.
BY MS. KARIS:
Q. This is the Safety Pulse Check - Report & Action Plan for
the Deepwater Horizon from 2008. Is this a Safety Pulse Check
that you're familiar with?
A. Yes.
Q. And was this administered while you were involved with the
Deepwater Horizon?
A. Yes, it was.
Q. All right.
MS. KARIS: If we could now look at 47570-N.3.1,
which is a page from this program.
BY MS. KARIS:
Q. This reports on the Safety Pulse Check positive feedback
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ALEXANDER JOHN GUIDE - DIRECT
from team. And it begins on the top there, which we haven't
called out by saying: "Summary of positive feedback received
from questionnaire and engagement sessions."
And without going through each of these, can you
describe for the Court what the positive results were from the
Safety Pulse Checks that were administered to the
Deepwater Horizon's crew?
A. Well, the first one, the strong performance and safety
culture is embedded, was obviously very, very good to seebecause it meant that all the folks working on the rig
understood how important it was and they applied it day-to-day.
Personally, what I thought was very, very good was
the Stop-the-Job culture.
Q. Okay. That says, "stop-the-job culture was noted as very
strong by all personnel interviewed"; correct?
A. That's correct.
Q. And why did you personally think that that was something
that was very, very good?
A. Because there's a lot of activity that goes on every day.
And we -- we really wanted to make sure that everyone knew if
they saw something, anything, and either they didn't understand
it or they didn't think it was going like they thought, that
they had the obligation to stop the job.
Q. There's a result here for excellent teamwork between
Transocean, third party, and BP personnel. Is that consistent
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ALEXANDER JOHN GUIDE - DIRECT
with your experience with the Deepwater Horizon and working
with Transocean, as well as other third-party contractors?
A. Yes, it was.
Q. And was that the feedback that the crew was giving to you,
BP, that they felt there was excellent teamwork being
conducted?
A. Oh, yes.
Q. All right. And then finally, it says, "All rig personnel
are very proud of safety and performance history"; correct?A. Yes.
Q. Did you ask only about personal safety?
A. No, no.
Q. Based on your experience and interaction with this crew,
are these results consistent with the feedback you were getting
from Transocean with respect to BP's performance on the
Deepwater Horizon and you and your team's performance onshore?
A. Yes. And the third-party folks.
MS. KARIS: And quickly and we'll move on to another
subject then, D-4350.
BY MS. KARIS:
Q. Does this reflect some of the Safety Pulse Check results
from that 2008 report?
A. Yes.
Q. Okay. And just to point out a couple here. "Do you feel
you are in control of your own" personal -- "of your own
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ALEXANDER JOHN GUIDE - DIRECT
safety," and there's 100 percent responsiveness; correct?
A. Yes.
Q. What does that indicate when you get 100 percent?
A. That everyone understands.
Q. And then there's another one that says: "Do you feel you
are given enough time to properly plan the job?"
What are the results of that?
A. 100 percent.
Q. Okay. Were the results that were seen in 2008 consistentwith the results that you saw then in 2009 and going forward?
A. Yes, it was.
Q. We talked about stop-the-job as another program, so we
won't talk about that one again. But you also mentioned safety
standdowns. Are you familiar with safety standdowns?
A. Yes.
Q. What is a safety standdown?
A. It's when we actually stop the operation on the rig, and
all that can attend would go into the theater room and we would
have a safety discussion.
Q. And so do they take place on the rig, they stop the
operations and those who can attend come to this meeting where
you discuss the issues?
A. Yes.
Q. How often, in your experience, did safety standdowns stay
place?
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ALEXANDER JOHN GUIDE - DIRECT
A. It was probably, average, once a month.
Q. So once a month you would stop the operations to discuss
something that was identified?
A. Yes.
Q. Does BP continue paying the rig rate, the daily rig rate
of almost $1 million, while the operations are stopped in order
to have a safety standdown?
A. Yes.
Q. Did you ever at any time raise any concerns withTransocean to not conduct a safety standdown because of rig
rates or time or time is money or anything like that?
A. No.
MS. KARIS: Let's look at TREX-47461, please. If we
can call out the bottom.
BY MS. KARIS:
Q. Talking about safety standdowns, was there a safety
standdown on the Deepwater Horizon on April 10th of 2010?
A. Yes, there was.
Q. So just ten days prior to this incident?
A. Yes.
Q. And this incident arises from crane block and dock
pictures, it says. It says: "While the block was lowered into
the stand, the stand shifted to the left, hitting the
roustabout in the left leg. The roustabout reported to the
medic. An ice pack was applied for a short period of time."
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ALEXANDER JOHN GUIDE - DIRECT
As a result of this incident, did you recommend in
the top e-mail there to your boss, Mr. Sims, that a safety
standdown should be taken?
A. Yes.
Q. And did Mr. Sims support your view to do a safety
standdown?
A. Yes, he did.
MS. KARIS: And if we can now look at TREX-47461 --
1.3, I'm sorry.BY MS. KARIS:
Q. And is this Mr. Sims' response back to you where you
propose a safety standdown, and he says, "John, agree with the
standdown. Happy to take as much time as you think. 2 first
aids and 2 drops in 2 weeks is worth a timeout"?
So for two first aids and two drops in two weeks,
operations were going to stop at BP's expense in order to take
a safety standdown; is that accurate?
A. Yes.
Q. And you respond back there and you say: "You would have
shot 64 at Augusta today."
A. Right.
Q. What's that about?
A. Well, Mr. Sims was a very good golfer and we golfed
together, and we were both watching the Masters at that time
and I was just kidding with him.
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