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K. Maintenance of the Deepwater Horizon BOP

The following sections provide details about Transocean’s maintenance of
the Deepwater Horizon BOP stack and the BOP stack’s condition at the time of the
blowout.

1. Transocean Maintenance Plans

Transocean began to use a maintenance tracking system called RMS II
shortly after its merger with Global Santa Fe in 2007. The RMS II system is
designed to automatically flag components in need of scheduled maintenance, to
order parts, and to create work orders.

Transocean senior subsea engineer Mark Hay described the RMS II system
as a “preventative maintenance system” used to tell the rig personnel which
pieces of equipment were due for maintenance. Transocean used this
maintenance tracking system to determine the different types of work that
needed to be done on the Deepwater Horizon BOP stack. Transocean had
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procedures to track maintenance on BOP components within their RMS II
system; however, the Company did not effectively track maintenance work on
each specific component.

The preventative maintenance orders generated from within the RMS II
system are developed using items such as original equipment manufacturer
(“OEM”) recommendations for replacing equipment based on lifetime service
hours, loads and pressures, routine rig move maintenance work‐lists, the
365/1095/1825‐day preventative maintenance work‐lists, as well as the subsea
maintenance philosophy.

2. Transocean Subsea Maintenance Philosophy

Transocean relied on a document entitled “Transocean Recommended
Practices, Subsea Maintenance Philosophy” that contained the company’s
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maintenance “philosophy” for subsea equipment. In the document,
Transocean provided guidance for subsea planned maintenance tasks and for
planning for maintenance to be completed while the BOP stack was being moved

361 Testimony of Mark Hay, Joint Investigation Hearing, August 25, 2010, at 237.
362 Transocean Recommended Practices, Subsea Maintenance Philosophy, May 2007, HQS‐OPS‐
RP‐400‐001.

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