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So, I mean, you’re talking about pulling the rig out of service and – and,
there again, the practicality of doing this and what you gain by doing this
is weighed out.
373

Mark Hay, Transocean subsea superintendent, testified that it was well‐
known among the “top‐line supervisors” on the Deepwater Horizon that the BOP
stack was outside of its three to five year major inspection requirement, and
instead Transocean was relying upon its condition‐based maintenance.
374

4. Planned 2011 Shipyard Maintenance

Transocean planned to bring the Deepwater Horizon in for maintenance at a
shipyard in early 2011. The planned maintenance included: (1) replace or rebuild
all 6 bonnets on pipe rams; (2) replace both 28 inch super shear ram bonnets; (3)
replace Cameron high capacity riser connector; (4) completely replace lower
annular with rebuilt annular; (5) replace all control hoses on BOP; (6) replace
diverter; (7) replace diverter flex joint; (8) blast and paint both stack and LMRP
frames; (9) change out all anodes; (10) rebuild all shuttle valves; and (11) replace
375
or rebuild riser spider and gamble.

5. Deferring Maintenance on the BOP Stack

The Panel found that, less than a week before the blowout, BP informed
Transocean that it wanted to defer maintenance to the upper and lower annulars
(parts of the BOP stack) and agreed to accept liability if the lower annular failed
prior to the performance of maintenance work.

Brett Cocales emailed John Guide on April 15 to discuss “Stuff for Paul
[Johnson, rig manager].” Cocales informed Guide that “Paul [Johnson] needed a
couple of things from us for the upcoming end of well work list.” The first item

373 Stringfellow testimony at 379.
374 Hay testimony at 205‐06. Transocean was using conditioned based maintenance approach
notwithstanding the fact that, in 2006, MMS cited its “extended use of the BOP without
inspection/maintenance” as a contributing cause of a 2006 pollution event. MMS recommended
that “Annular BOP maintenance should be conducted per Transocean Schedule and criteria to
reduce wellbore seal, wear, and damage.” MMS found that Transocean had recommended a
maintenance schedule, but the crew had failed to follow it. See
http://www.goboemre.gov/homepg/offshore/safety/acc_repo/2006/060212.pdf.
375 TRN‐USCG_MMS‐00096390.

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