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dependent on the findings of the major survey. During JIT hearings, Fry was
asked about the confusion surrounding the verification of the 1,825‐day major
overhaul start date and how the Panel could determine when the Deepwater
Horizon’s BOP stack components were installed. Fry responded:

Ram blocks, recertification of ram blocks ‐ I mean, a ram block that gets
inspected gets inspected for damage. It gets a hardness check. It gets a
non‐destructive testing inspection done on it. If thereʹs no damage to it,
again, thereʹs no requirement for a mandatory recertification of it.
Normally, to kind of expand on your question, the start date is from the
366
date of the COC.

A certificate of conformity or certificate of compliance (“COC”) was
issued by the OEM. The Panel could not locate any Cameron COC for the VBR
bonnets since the installation date in 2000. Transocean also submitted
documentation stating the VBR ram blocks had not been completely overhauled
since installation in 2000.
367

The Panel also never received documentation on the required 1,825‐day
inspection, which should have been done in 2005 for the VBR bonnets.
According to Transocean’s subsea items scheduled to be worked on during the
2011 shipyard visit, they were scheduled to “replace or rebuild all 6 bonnets on
pipe rams.”
368

3. “Condition Based” Monitoring and Maintenance

In testimony, Transocean personnel articulated an approach to BOP stack
maintenance that they referred to as “condition based monitoring” or “condition
based maintenance.” Transocean subsea superintendant, William Stringfellow,
described this approach as follows:

Again, we use condition‐based monitoring, and we look at [API] RP 53 as
a recommended practice. Using our condition‐based monitoring and
testing of our systems, we can determine what kind of condition those
BOPs are actually in. And we have history to back this up through –
we’ve actually pulled BOPs down within this time frame and there not be

366 Fry testimony at 46.
367 TRN‐USCG_MMS‐00097144.
368 TRN‐USCG_MMS‐00096390.

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