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The Panel found no evidence that BP consulted with Cameron about
modifying the BOP stack with parts from a non‐original equipment
manufacturer.

c. API RP 53 Section 18.12

Section 18.12 of API RP 53 required a lessee to have on each rig a “planned
maintenance system, with equipment identified, tasks specified, and the time
intervals between tasks stated.” Maintenance and repair records were required
to be retained on file at the rig site or readily available.

4. BOP Pressure Tests

30 CFR § 250.447 required the operator to pressure test the BOP system
(choke manifold, valves, inside BOP, and drill‐string safety valve):

 When installed;
 Before 14 days elapsed since the last BOP pressure test; and
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 Before drilling out each string of casing or a liner.

While performing a 14‐day BOP pressure test, the operator was required
to comply with 30 CFR § 250.448. This regulation required the operator to
conduct both a low‐pressure and a high‐pressure test for each BOP component.
The low‐pressure test had to be conducted before the high‐pressure test. Each
individual test had to hold pressure for five minutes. Examples of approved
tests were:

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The MMS District Manager had the option to allow lessees to omit the last testing requirement
if they did not remove the BOP stack to run the casing string or liner and if the required BOP test
pressures for the next section of the hole were not greater than the test pressures for the previous
BOP pressure test.

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