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stated, “He needs an email from you that states we don’t want to change the
annulars before the Nile and will accept that liability if both fail during Nile and
we have to pull the BOP. We all agree this is a low risk of having 2 failures. This
is coming from his upper management that they just wanted our confirmation
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with an email.”

On the same evening, just minutes after receiving the email from Cocales,
Guide sent Paul Johnson an email saying he concurred with not changing the
annular elements prior to starting the Nile well. The email stated, “B[P] accepts
responsibility if both annulars were to fail and the stack had to be pulled to
repair them.” While the Panel did not find that a failure of the annulars
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contributed to the failure of the BOP stack to seal the well, it did find that Guide
decided to accept liability on behalf of BP for any annular failures with
apparently little or no analysis of the conditions of the equipment.

6. Effects of the BOP Maintenance Record on Performance

The Panel found that the Transocean’s subsea maintenance plans were
generally in accordance with Cameron’s maintenance requirements. As noted
378
previously in this Report, the Panel found no evidence that Transocean had
submitted the variable bore rams to a major inspection (as defined in API RP 53)
any time since installation in 2000.

The Panel did not find any evidence of an actual deficiency in
Transocean’s maintenance of the BOP stack that played a role in the failure of the
BSR to shear the drill pipe and seal the well.

L. BOP System Leaks

BOP systems may develop hydraulic fluid leaks in their various
components. Part of regular BOP stack maintenance is to identify and assess the
seriousness of leaks to hoses and valves. While Transocean asserts that there
were no leaks on the Deepwater Horizon BOP stack when it was deployed at the

376 BP‐HZN‐MBI00254566.
377 BP‐HZN‐MBI00254591.
378 Cameron Special Procedures identified in EB 902 D, CAMCG 00003345.

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