Professional Documents
Culture Documents
IN
IN
RE
DEEPWATER
HORIZON
in
the
GULF OF MEXICO
on APRIL 20 2010
MDL No
Section
2179
Applies
to
The Honorable Judge
Barbier
CONFIDENTIAL
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
Summary
not Suitable for the
II
The
BOP was
Well
from
Hell
The Macondo
Safety Factor
BSR Lacked
Sufficiently
High
Wrong Type
of
at
Macondo
Used
at
10
BSRs
were
11
was Used
at
Macondo Used
at
12
Tandem
Macondo
Should have
been
13
at
Macondo
the
13
The
Drill
Pipe
Was
Off-Center
When
BSR
14
Closed
Forensic
Evidence
Shows
the
Drill
Pipe
Was
14
Off-Center
Sufficient
Force
for Buckling
15
Contrary
Expert
Opinions
are
Founded
Knights Theories
Criticisms of the
16 Off-Center
Drill
Pipe
Founded
to
23
the
IV
The
AMF/Deadman
of
Failed
Activate
BSR
24
Because
Transoceans
Improper
Maintenance
Battery
Transocean
Pod 27V
Run
24
Down
1cKoo1
40 193 7v2
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
Yellow
Pod
103Y
Solenoid
Failed
Because
it
was
Incorrectly
25
AMF
Failed
to Actuate
Two
27
Failures
Transoceans
the Evidence
Theories
are
Inconsistent
with
28
in
BP Was
and
did
Actively not
Involved
the Design
of the
BOP
and 28
Exclusively
Rely
on
Transocean
Cameron The
for the
BOP
is
Well
Operator
with
Responsible
for the
is
BOP
in
and Along
Best
the
to
Drilling
Contractor the
the
Position
Determine
Necessary 29
BOP
Capabilities
BP Was
Design and the
Actively Including
Involved
in
the the
DWH BOP
BOP
Stack
Specifying
Rams Used
or
29
BP Knew
was
Should
Blind
Drill
Have
Known
the
BSR
to
Shearing
Unable
Shear Off-Center
30
31
VI
Summary Of Key
Findings
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
INTRODUCTION
This
to report
is
offered
in
rebuttal
to reports
in
offered
detail
of other parties
this
litigation
as described
materials to
further
My
opinions
are
based
upon
the
and Phase
information
reviewed
forensic
including
materials
related of the
the
and
Phase
examination
and
testimony the
Horizon other
in
DWH
documents Appendix
testing
and
blowout
related
preventer
to
DWH
in
BOP
BOP
of that
including
materials
identified
my
analysis
information
of
my education
engineering
training
failure
experience analysis
oilfield
the areas
material
mechanical
and
and
my knowledge
of
and
drill
equipment
In
platforms
BOPs
been
have
not
and
e.g forming my
nor
relied
have upon
in
presumed
this
that
as
is
material
This
written
with
the
expectation
incident
that
have
some
familiarity
with
the
Macondo
and the
reports
addressed below
Executive have
found
Summary
to
the following
be true
was not suitable for the Macondo well for many because the wrong blind shear ram reasons including was used only one BSR instead of two was used the wrong control system was used tandem boosters were not used and the wrong operational sequence was used
The
DWH BOP
BSR
The Macondo
off-center
drill
drill
pipe
was
well
off-center
when
the
BSR
closed
and
pipe
was
known and
foreseeable
The
the
automatic
mode
function
AMF/Deadman
because program charge and
wired allowed the
did
failed
to
activate
BSR
at the
time of the
incident
Transoceans
the blue
flawed
control
condition-based
maintenance
to to lose their
pod
batteries
yellow not
control
pod
either
solenoid
103Y
be
incorrectly
but
identify
problem
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
British
Petroleum
DWH BOP
Deepwater
BP was
did not
rely
actively
involved
in
the design
of the
and
exclusively
Offshore
Drilling
Inc
for
Transocean
International
Corp
Since expert
drafting reports
Cameron
my Opening
in
the
BOP
have
to
Report
studied the
the
numerous
operation
reinforced
other
this
case BOP.1
of those
relating
design
experts
and
maintenance
of the
DWH
of those
my
find
original options
Several
however
described
have
reached
different
conclusions
than
mine
For
the
further
below
none
of those
II
Properly
Operated
BOP
using
BAST
could
have
Stopped
the
experts contend
that
the
DWH BOP
best
in
was
suitable
Macondo
and have
safer
disagree
because
the
available
and
technology
BAST
technology should operation
was was
not
implemented
to
in
the
DWH
BOP
which
proper
available
BP and Transocean
the
could
have
implemented on
DWH BOP
have
BOP
design
based
BAST
should
included
casing
shear
10Donnell
2011
D.L
Expert Report
submitted
by Cameron
International
Corp
October by
17
International
McGuire
17
of
2011
submitted
Cameron
E.G
Shanks
Expert Report
submitted Report
September 23
Childs
2011 on
the
Report
F.E
Davis
Expert
submitted
BP
October
17
Report
Shanks Report
of Justice the
R.R
Robinson
Preventer 2011
J.N
Novak
P.R
Merala
Deepwater Horizon
of
Plaintiffs
Blowout
Examination
and Testing on
Perkin 2011
of
behalf
of the
Department
behalf
August 31
Steering
Davis
Committee
submitted Engineering
Report August 26
behalf
G.S
Report
on
Perkin
on
BP
Report
on
BOP
Design
Report
on the
on behalf
Incident
17
2011
Report
2011
Macondo Dias
by submitted
Able Report
Expert Report
Methodology
BP
October
17
2011
Dias
Horizon 2011
Report
Blowout
and Zatarain Transocean Regarding Expert Report Preventer Subsea Control submitted System by BP
Deepwater
October
17
Zatarain Report
Childs
Report
25 Shanks
Report
50
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
CSR
should booster
and have
two
BSRs
been
one
above
and
with
one
below the
CSR
and
margin
The BSRs
higher
of
both
equipped
psi
to
tandem
an
boosters
pressure
5000
provide
acceptable
safety
The
proper
actuation
sequence
should
be as follows
CSR
and
lifting
of the tail or
drill
string
the the
Closing the
flow seal
will in
CSR
first
cut
and
centered the
and
reduces
will
blowout
situation
if
BSR below
CSR
likely
the well
However
reduced
be
further
is
any seals are damaged due to erosion the flow and the second BSR will easily seal the well
flow velocity
Erosion drop
in
proportional flow
will
to the
squared
thus
the progressive
to the
fluid
virtually
eliminate
any
damage
potential
second
BSR
closure
Further
riser
lower
annular
should
have
not
been
shut
first
to control
flow
up the
bore pipe
to
The upper
annular
should This
be closed
unless
in
the
variable
provides This
backup would
case
the
drill
erodes through at the lower annular hard sealed and the well contained
II
allow the
drill
pipe
be
The
BOP was
for the
Transocean
expert
that
Macondo3 Macondo
the
with
and
except
BP
for
that
for for
BSR.4
for
disagree
with
As
discussed
below
BSR was
the
unsuitable
that
Macondo and
it
other flaws
DWH BOP
well
ft
made
unsuitable
Macondo
of
The
are
Macondo
additional
was
that
drilled
to
depth
approximately
in
18360
well
ft
including
12360
for
When
drilling
deep
waters as
there as the
factors
difficulty
drill
of
drilling
requirements
BOP
The
pipe pressures
to
are higher
due
to the
greater depths
and the
pipe
needs
Childs
Report Report
25 50
Shanks
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
more
prone
to
off-center of
positioning
and
bowing
from
axial
in
loads
The
increased
difficulties
deepwater
drilling
are well
known
drill.6
the industry.5
The
to
Macondo
well
was
far
challenging
to call
well
to
One BP
wells
testified
technical
employee
terms of
went so
as
Macondo
That
ne
of those
problems during
technical
BP employee
would would look
like.8
further
fall
in
Ma condo
under
new
classification
of what
well
Despite
the
challenging
to that
nature
of the
Macondo
well
the
in
failure
of
BP and
relying
Transocean on BP9
well
implement
BOP
able
to
using
BAST
drill
resulted
the
DWH
well
BOP
and
was
not
shear
pipe
and
seal
the
under
foreseeable
Contrary to positions
offered
on behalf of
Transocean10
DWH BOP
was
not
suitable
for the
Macondo
The Macondo
safety factor or
BSR Lacked
margin
is
Factor
by the
level
design
the
load
divided
is
operating load
or
Actual
failure
load as the
is
name
indicates
to or
will
the load
fail
pressure
if
at
which
is
component
burst of
expected
should
actually
For
example
psi the correspond
one
designing
or
high
pressure
gas
at
1000
would
force
actual to
failure
be
4000
psi
This
safety
factor
Note
for shearing
Well
Completion
Design
Elsevier
G.E
Kazanis
E.G
Montgomery
TM
M.P
Deepwater
Gulf of Mexico
2006 Americas
Expanding
OCS
Report
MMS
2006-022
Deposition of
Billy
Ambrose
July
18-19 347-14 March 23-24 2011 2327-1 March 23-24 2011 19812-17
Exhibit
628
Shanks
10
Report Report
50
25
stating the
Childs
Deepwater Horizon
BOP
stack
was
suitable
for
use
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
capacity
of the
in
BSR
all
should
force
necessary
well
to
pipe
possible the
by
an
acceptable
safety
Fortunately thus
this
required
in
shear pipe
range
in
has
defined
limit
safety safety
should
be adequate
design
for
Unfortunately
was
present
the
BSR
the
DWH BOP
Transocean and shearing
capable
has pointed
calculations
to
pressure the
MASP
was
DWH BOP
of shearing
MacondoY
of shearing including
establish
drill drill
that the
BSR was
ideal
and and
6.25
pipe
under
circumstances
sharp
blades
that
centered
pipe
Engineering
shows
same size
more
for
the
DO
7Z
Iad
risl
500
13
3D0
200
__
F1
____
_______
\.rE
rii
1E
Study
for
Childs
12
Report
24-27
Services
West
Engineering Service
Shear
Ram
Capabilities
U.S
Minerals
for
Management
pipes
Requisition
No
3-4025-1001
September
2004 data
S135
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
Fig
pipe
shear force as
size
function
of
within each
vertical
single pipe
and weight The of equation from Appendix for safety factor of 1.0 and
1.3 respectively
This
variation
in
shown
in
the
West
Engineering
test
data would
fact
Camerons
chart
data and
Transoceans
using
in
data
In
the
Cameron
red to
can
be reconstructed
describing the
Fig
above.13
of the test
The
data
red but
line
Fig
good
fit
the
upper bound
provides
no
additional
margin
for
unexpected
the
conditions
In
my
Fig
opinion
factor
DWH BSR
safety safety
should
factor
have
of 1.3
been
is
designed
with
minimum
line
safety
in
of 1.3
represented design
Such blades
factor
provides
clear
account
high
for
dull
friction
higher than
expected
factor
well of
pressure
1.3 relative
in
and
end
material
properties
is
minimum
design
this
safety
to the
upper
of
bound
the
not
an excessive
time the
burden
could
As
described
Appendix
the
authors opening
at the
report
easily
be
met
with
technology
available
DWH
in
was
designed.14
we
sit
to the
pressure
vessels the
on the
DWH
in
have
state
safety called
in
factor
greater than
factor of 14.15
is
e.g
code
for escalators
one
its
for
safety
For piping
and pressure
vessels
actually
This
the safety
factor
13
Stevick
Report Report
14
Stevick
15
Norton
Boiler
R.L
Approach York
Prentice-Hall Material
to 9th
1998
ASME
J.E
and Pressure
Society
of
Vessel
Code
Section Engineers
Part
Ferrous 1992
Specifications Shigley
American
Mechanical
Mechanical
New
Hill
2010
Engineering
in
Design
McGraw
3rd
through
Editions
1977-2010
Authors experience
16
failure
analysis
and design
Pressure Vessel
Criteria
of
III
the
ASME
Section
Boiler VIII
and
Code
Society
for Design of
By Analysis
Engineers
in
Sections
and
Division
American
Mechanical
1969
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
of
near
1.0
for
the
DWH
oil
BOPs BSR
for
shearing
centered
pipe
and
preventing
massive
spill.17
In
the
absence
performed
to
of
higher safety
factor additional
its
shear
tests
could
have
the
been
on the
BSR
to determine to determine
capabilities
Cameron had
capability
do shear
tests
whether pipe
in
different
types
of
pipe these
i.e
tests
6-5/8 for
inch
27-pound upon
positions neither
and
nor
provides
customers such
request.18
But
BP
Transocean
ever requested
DWH.19
Wrong Type
The
of
at
Macondo
because
it
DWH BOP was also not wrong type of BSR The BSR
blind length
for
Macondo was
used the
shearing blade
the
DWH BOP
Cameron
blade.2 increase
ram
of
with
15-1/4
inch
single
Camerons DVS
and
for
rams
size of
The
the
shearing
capabilities21
the
Macondo
DVS
blades would
blind
be about
an
inch
wider
ram
used.22
The advantages
of
DVS rams
testified
blind
by
Camerons
Systems use
shearabillty at
Vice
President
of
and
the
Drilling
Division
who
were
DVS
least
gives
you
as
wider
range of
for
given
constant
pressure.23
at
Cameron DVS
as
early
rams
suitable
Macondo
available
2002.24
BP
or
17
It
should
be noted
that
causes
is
additional
significantly
friction
the
full
bore an
actual
off-center force
pipe
to
simply shear
the
required
not
increased
18
Erwin Erwin
13612-23
13624- 1372
20
Cameron Cameron
EB 852D EB 852D
7001 7001
18-19 2011 35213-19 7-8 2011 11817-20 108
21
Exhibit
22
Whitby McWhorter
July
23
July
24
Cameron
2002 Replacement
Parts
Catalog
BP-HZNBLYOO3664I4
10
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
Transocean
blades and
could
have
upgraded
the
BSR
rams
with
wider
so.25
more
efficient
shearing
design
chose
not to
do
Moreover
with
at
least
as
early that
as 200526
cover
Camerons
offered
its
CDVS
ram
rams
double
blades
the entire
to
wellbore.27
The
existing
DWH
with
April
replace
the shearing
blind
rams
constituted
the
and operated
Wrong Number
The
of
at
Macondo
because
the
was
Macondo
BOP
only
According
that that
Cameron
BOP
for
salesperson Camerons
customers
understood
BOP
stack
better.29
BOP
stacks
from
Cameron3 and
as
early
by 2009
2010
space most
two
BSRs were
available
of the rigs
At least
rigs
as
2000 BP
recognized
that
for
dynamically
positioned
such as the
DWH
operators
to
some
in
have
two sets of
seal
in
blind
shear rams
event of an
order
have
the
unplanned
set
to
disconnect
thought set
to
is to in
have
one
shear
and
seal
the event
25
Erwin
1342-7
26
McWhorter
27
July
18-19
2011
35410-17
deposition
of
David
Deposition of Melvyn Deposition of David Deposition of Jack Deposition of Jack Deposition of Jack
Whitby McWhorter
July
3533
14812
28
July
14718
29
Erwin Erwin
5211-16
13415-18
30
31
Erwin
11
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
that
the
ram
packer
of
the
shearing
ram
is
BSR
the
particularly
as
significantly seal
improved the
as
of the
is
DWH BOP
particularly
pipe
well
conditions
such
BSR
is
severe flow
of
it
significant
uncontrolled
precisely
where
In
that the
BOP
the
that
to
situation
the
first
BSR
erosion
will
and
greatly
unable
completely the
closing to
the the
well
first
be
reduced any
by
BSR
BSR
seal
virtually
eliminate
damage
allow the
potential
the
second
hydrocarbon
flow
and
will
second
BSR
to completely
the well
Wrong
The
Ill
Control
at
Macondo
Cameron Mark
the
failure
to
upgrade the
since
for
system
not
available
DWH BOP
Ill
was
suitable
Macondo
the
The Mark
II
control
DWH
BOP
lacked
II
the
coil
improved
solenoids
system
fail
that could
due
wiring
not
and be
were
not
which
could
monitored
coil
remotely.34
improved
control
pods have
from
single
solenoids with
subject to incorrect
wiring35
and rechargeable
be monitored
the
rig.37
32
Ex 2390
BP
2000 Well
Control
Manual
July
at
BP-HZN-2179MDL00336682
McWhorter McWhorter
Erwin Erwin
July
3716
McWhorter
12
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
been
Used
on
at
Macondo
also
is
implement
unsuitable
piston that the
Cameron tandem
for
boosters
the
DWH BOP
Booster
makes
Macondo
be
fitted
Cameron
to the that
Tandem
brought
to
an
to
can
back be
of
double
shear
force
can
that
ram
as
cavity.38
Cameron tandem
could
boosters
were
available
at least
as
early
1998
greatly
and
have
the
to
been shear
drill
added
force
to the available
would
have
increased
ability
This
and
well
accordingly
the
BSRs
shear
Macondo
and
BP was
certainly
aware
for
of
tandem
of
its
boosters other
as early as
equipped
the
BOP
one
rigs
with
tandem
at
Macondo
not suitable
for
example
the
of
how
that
the
Macondo
that the
EDS system
CSR
before
BSR
was implemented did not specify closure of the The DWH BOP implemented EDS-1 which was
programmed
Instead
to close the
BSR and
then disconnect
the LMRP.42
BP and BSR
Transocean
should
have
chosen
to to
have
fire first first
Cameron
and then
provides
flow of
program the
fire
available
EDS
that
would
cause the
Activating
CSR
the
the
CSR
the
advantages
centering
the
drill
pipe
and
reducing
the
38
Deposition of David
McWhorter
July
7-8 2011
1191-6
Cameron
40
EB 852D
10 Exhibit
7001
7-8 2011 the 11916-19
Deposition of David
McWhorter
July
41
Ex
4111
at
BP-HZN-2179MDL01490429
BOP
on
BPs
Thunderhorse
included
tandem
42
boosters
Erwin Erwin
David
McWhorter
July
7-8 2011
22513-24
13
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
EDS-2 is more hydrocarbons up the well Accordingly successfully shear the drill pipe and seal the well.44
likely
than
EDS-1
to
Ill
The
failure
Drill
Pipe
Was
Off-Center
When
the
BSR
Closed
drill
The
well
of the
BSR
to seal
the well
was due
to the
pipe within
the
being off-center
Forensic Evidence
Shows
the
Drill
Pipe
Was
from
It
Off-Center
The
drill
pipe
and
BOP
subjected
in
to detailed
the
well
and seen
can be
clearly
geometry images
that
of the
drill
BSR
the
shown
below
in
figures
and
the
drill
pipe
was
off-center
when
BSR was
activated45
McWhorter
Final
July
Norske
Veritas
Report
for United
Bureau
of
and Enforcement Energy Management Regulation Contract Award No Deepwater Horizon Blowout Preventer
Final
Ocean
Forensic Examination
M10PX00335
Report Vol Report
the
Volume
figures
Report
It
Report
No EP030842
that materials
61
should
be noted
DNV
to
41
the
DNV
to
and associated
source
DNV
documents and
the
and
as
reference
forensic
underlying of the
evidence
including
data
from
DNVs
incident
investigation
DWH
BOP
14
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
-_u
Fig
Pictures the of the
drill
--end
9-I-A
pipe
segment recovered
from the
from
DNV
Report.46
BOP
photographs of the drill pipe segment recovered from within the and the below laser scan images of drill pipe segments and the BSR
blocks
show
of the
that
the shapes
of the
severed ends
of the
drill
pipe and
closing
the
shapes
the
drill
deformed
BSR
the
BSR
on
drill
pipe
was
off-center
Sufficient
Force
for
Buckling Existed
that
KnightHawk
buckling
concludes
show
for
are flawed.47
disagree
at the
The
not
buckling This
of the
is
drill
began
prior
to
VBR
VBR
is
relevant for
at this
stage
buckled
As
VBR
time
string
drill
after the
annular
has been
closed
an extended
already
period
and
will
the
drill
on
new shape
the
VBR
is
begins the
to partially velocity
constrain
the
string
As
upper annular
closed
up
the
drill
string
DNV
Report Vol
Figure
41
KnightHawk Report
10
15
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
dramatically
increased
This
lbs
is
evidenced
corresponding
by
the
drop
in
in
hook
load force
joint
of
approximately the
drill
60000
and
loss
increase occur
upward
on
is
string
Additional
in
hook
load
cannot
as the
tool
and
probably
bouncing
of the
Note
still
VBR
VBR
as well as
some
translation
230000
lbf
suggested by
KnightHawk48
the the
or the
130000
lbf
suggested by
DNV
Prior to their to
if
VBR5 cannot
drill
close
instantly
in its
either
complete
position
string
kill
is
already
buckled At
this
state
forced
bore wall
between
drill
the
in
VBR
the
BSR
drill
time even
friction
friction
were
to
pipe
that
if
would
only act
the
pipe
state
even
the
axial
loads
to
were
to
change
significant
In
actuality
the
VBR5 would
due
to severe
unlikely
be
able the
provide close
any
the
axial constraint
erosion
As
VBR5
annular
material
flow
being forced
radially
inward
VBR
packing
at near
optimum
erosion angles
Founded
force resulting
was caused
following off-center
by the
downward
the traveling
rig.50
This
theory gives
another
it
why
not
pipe
must be considered
time of the
at
in
even
though
probably
at the force
BSR
time
closure
There
by the
was
almost
certainly
downward
some
the
of
caused
pictures
traveling
block
coming
down
As shown
below
drill
from
DNVs
3951
forensic
analysis
the curved
plastic deformation
pipe section
this
and
plastically
deformed lower
end
39E52
clearly indicate
section
experienced
high
axial
48
KnightHawk Report
Finnie
erosion
50
at
10
and
G.R
Stevick
J.R Ridgely
The
influence
of impingement
angle
on the
of ductile
Wear
152
1992
Shanks
Report
34
figures 51
51
DNV DNV
and 52
52
figures
51 52 and 65
16
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
11
gment 39
Fig
Pictures Report.53 of
drill
--__
Top Eud 39-E pipe
segment 39
DNV
DNV
Report Vol
figure
51
17
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
bBottom
cud
39-E
Fig
Laser scan
images
of
drill
pipe
segment 39 taken
from the
DNV
Report.54
DNV
Report Vol
figure
52
18
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
Fig
Pictures
of
drill
pipe
is
the
matching
end
to
DNV
Report.55
However
matched
the
in in its
plastically
lower
end 39E
is
not
reflected
in
or
mating
end 1-B-1-E
laser
just
above
the
tool
joint
As shown
the images of
DNVs
scan
modeling
1-B-1-E
shows no
such compressive
plastic deformation.56
DNV
56
figure
65 68
DNV
figure
19
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
Gnove
DriI
Frpe
End
39-E
Flats
DriLl
Pipe
Ertd
1-E
I-i
Fig
Laser scan
images
of
drill
pipe
segment
1-B-1-E
and
matching
the
DNV
Report.57
Thus
the high
1-B-I
on pipe
section
39 occurred no
pipe path
sections
separated
and
had
continued
downward
it
to the
BSR
of
location
into
The
bottom
of section
39 was deformed as
away
from
its
pipe
not uniform indicating the
riser
The
bending
noted
it
in
section
1-B-I
is in
particularly
riser
it
occurred
occurred.58
when
was
located
up
the
where
bend
DNV
58
figure
68 55
DNV
figure
20
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
flnfl--
41fl
ii
33
D2
II
ii
at
CSsg2aRais
-I
Upie
_lw nil
Vat
Is
-1
ft
TaWI
I-
341
iN
Cfl
.sttcabrttKs
Fig
Diagram
sinking
of
sequence
following
of
drill
pipe
break
at point
and
DNV
Report.59
DNV
Report Vol
figure
55
21
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
Section
83
just
above
the
BSR
also
shows no
curvature
indicative
of high
compressive
loading.60
ib lop
nd 83-C
of
drill
Bottom
end
S3-B the
Fig
Pictures
pipe
DNV
Report.61
aTop
Fig
end
83-C
of
drill
Bottom end
83-B
the
pipe
DNV
60
figures
43 and 44
61
figure
43 44
62
figure
22
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
In
loading not
due
to the traveling
block
in
failure
can
and
the
occur
However
drill
it
did
BSR
The
pipe above
was
bow
in
the pipe
the area of
Knights
Not Well KnightHawk
concludes
Criticisms
of the Off-Center
Drill
Founded
that
the
drill
string
analysis
with
done
the
by
DNV
was
inaccurate.63
KnightHawk
by
does
that
agree
boundary
only
conditions pinned
fixed
used
DNV
no
specifically
VBR
the
would
provide
connection
KnightHawk
believes that
VBR
would
provide
condition lead
where
translation
and
no
rotation
would
lbf.64
be allowable
This would
to buckling
230000
KnightHawk
also
has
its
constraint
directions
upside
down
joint
Due
in
to erosion
hangoff
at
VBR
did
would
be impossible without
not
tool
or just
above
VBR
joint
occur
clearly
in
occur
This
tool Hang-up at the upper annular by assured constraint only supports buckling or
bowing
theory
the
BOP
by an
upward
force
from
below
force
lacks
lower
drill
end
pipe
constraint
is
still
preventing
pipe
movement
while the
intact
KnightHawk
condition the
also
states
that
even
if
the
VBR
95550
would
provide
pinned
DNV
calculations
show
that
lbs of force
are available
and
for
buckling
fact that
thus
no
buckling
calculations
would
are
is
the
those
and the
fact
that
they
are of the
same
in
order of magnitude
his
DNV
could
research
engineer
testified
deposition
that that
analysis would
be required
at
to get
more
accurate
or
values
the
and
buckling
have
occurred
95000
120000
in
70000.66
drill
BEARs
pipe as
calculations
clearly support
these
lower values
modeling
63
p.10 p.10
64
65
10
July
66
Deposition of
Neil
Thompson
2011
19117-23
23
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
pinned-pinned
its
or
formula to account
for pre-buckling
and
resulting
off-center
IV
Failed to Activate
the
BSR Because
of
Improper Maintenance
Let the concludes
Transocean
Transocean
activate
Blue
Pod 27V
the
of
Battery
Run Down
did
in
expert
that
AMF/Deadman
depleted blue pod
fact
the
BSR
27V
battery
and
an
incorrectly
solenoid.68
disagree
failed
The
available
evidence
leads
me
of
to conclude
that the
AMF/Deadman
and
to actuate that
the
BSR
both
because
direct
these
two separate
independent maintenance
failures
were
result of
Transoceans
improper
The 27
control testing
volt
battery
pack
responsible
for 1.1
powering
volts
the two
1.0
SEMs
in
in
the blue
pod
with
registered
charges
This
of
and
volts
subsequent
the blue blue
no
load.69 did
evidence
strongly
suggests
to
that
pod pod
27
volt
battery
not
have
enough
charge
energize
the
As manufacturer
one
year
of
Cameron recommended
at
replacing
the pod
that
batteries
in
after
use
minimum.70 The
control to
pod
was
use as the
referred
as pod
No
had previously
installed
been
the spare
in
pod on deck
April
since
November 200771
batteries
in in
and was
as
2009.72
The
pod No
had
been
replaced
2007
67
Higdon
Childs
et
al
Mechanics
of Materials
John
Wiley
and Sons
3rd
Edition
1976
68
24 42
Table
69
DNV
70
Exhibit
3329
at
TRN-MDL-01075694
April
71
72
TRN-INV-01840853
Exhibit
3980
24
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
The
undercharged
flawed
27
volt
blue
pod
battery
is
unsurprising
in
light
of
Transoceans
battery
condition-based
maintenance
have
In
be measured problem
the
first
the
not
until
the device
that
during operation
batteries
fact
was
not
time
DWH
pod had
under
to
Transoceans have
condition-based
maintenance
program
been
found
low charge.73
Yellow
it
was
Yellow
pod
103Y was
coil
rebuilt
in
February 2010
by
by
Transocean
that
personnel solenoid
that
on
the
rig.74
Post-incident incorrectly
testing
DNV
determined
wired
at
positions
and
475 such
fields
the
the
solenoid would
create
electromagnetic
that
would counteract
each
other
Exhibit
1914
4305 19312
3602
at
p.54
Exhibit
3782
Deposition
of
Jim McWhorter
April
20-21
2011
Exhibit
CAM_CIV_0046705
DNV2011052708
DNV
IMG_0458
25
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
Figure
11
76
DNV
IMG_0458 showing
positions
the
solenoid
the wires
coil
and
where
were
Post incident
of
DNV
testing
of solenoid
other incorrectly
wired
is
solenoids
unlikely
additional that
Cameron
incorrectly
tests
an
wired
testing
as 103Y
failed
to activate either
DNV
24
bench
103Y
to
activate
coils
SEM
yellow control
volt
pod
when
both
solenoid
103Y
were
energized
via
DC power
source.77
DNV
was
performed
to
additional
testing
on solenoid 24
these
03Y where
tests
SEM
controller
was used
initially
power
103Y
volt
DC power source
because
Testing
There
did
understand worked.78
some how
confusion
different
DNV
Units
not
Electronic
PETU
one
DNV
later
discovered
use
of the
PETU
to activate
SEM
76
44
Exhibit
5172
78
DNV2011060743
26
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
would sometimes
both
activate
both
SEMs
The
is
and
to activate test
SEMs
in
only activated
of this activate
one.79
correct
of these
results
light
information dual-coil
that
when
that
both
SEM
and
not
SEM
function
simultaneously
properly
in
solenoid
solenoid did
out of
tests
September
coil
2010
Cameron showed
coil
test report
showed when
that
incorrectly
in
wired
dual-
solenoids This
would
not function
that
properly
used
wired
an
actual
control
pod.8
properly with that
testing
solenoids functioned
when one
was
activated
not function
result
when
not
both
coils
opposite opposite
polarities polarities
were activated
in
As
of
Cameron
will
determined allow
it
the
two
coils
solenoid
to
function
when
The
incorrectly
yellow
pod
solenoid
103Y
is
unsurprising
in
light
of
Transoceans
incorrect
condition-based
not
maintenance
wiring
be measured problem
until
the not
have
been
identified
as
the device
during operation
AMF
The
one
Because
of these
Two
but
Failures
BOP
blue control
pods
to
control
be operational
the blue
order to execute
the
AMF
As
and
described energize
above
control
pod
failed
properly
because
of the
greatly
depleted
charge
of the
27
the
of
volt coils
The
pod each
failed
to properly
actuate
because
fields
of incorrectly polarity
solenoid
103Y
created
electromagnetic
opposite
to
that
cancelled
of these
identified
other out
in
As
blue
result
the
AMF
failed
actuate
because
not
defects by
the
and
yellow control
pods
that
were
Transoceans
condition-based
maintenance
DNV2011060642
80
DNV2011060643
81
CAM_C
IV_0374341
27
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
Transoceans
Transocean
expert
with the
Evidence
valve
Mr
yellow
pod
solenoid
103Y
that
functioned solenoid
did not
properly
blowout.82
Mr
Childs acknowledges
that
103Y was
impact
wired
but
argues
at
the
incorrect of
wiring
solenoid
is
103Ys
founded
functionality
the
time
the
incident.83
This opinion
not well
and
disagree
the
Mr
Childs
II
based
his
conclusion by
on
the
argument
that
that
Phase
and
Phase
testing
performed
DNV shows
to
incorrectly
wired
solenoid
not
103Y worked
into
when connected
the
of
SEM
with
But
this
argument does
take
consideration
problems
they
of the
misunderstanding
how
worked
PETU
versa.84
to activate
one
SEM
not
would
and DNVs DNVs above initially and DNVs intended use of the PETU5 both SEMs and viceactually activate
the
Cameron
PETU5
As
described
Childs
does
address
this
issue
which
test
contradicts
in
his of this
argument
issue
is
The
an
proper
interpretation
of the
is in
DNV
data
light
that
incorrectly
wired
solenoid
unlikely
to function
properly
when
both
SEMs
as happens
in
practice
BP Was
Actively
Exclusively
Rely
Design of the
not
BP
only
of the
BOP
The
fell
on Transocean
and
the
Cameron85
well lead
in
and
that
BP
that
merely
relied
on the
Cameron
documents
involved
in
BSR
and
to
seal
an
to
emergency.86 conclude
of the
disagree
testimony
me
BP was
intimately
the design
build and
testing
DWH BOP
82
Childs
Report Report
33 33 DNV2011060643 10 11
83
Childs
84
DNV2011060642
Shanks Shanks
Report Report
85
86
28
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
is
Responsible
is in
for the
Contractor
the
Best Position
Determine
the
Necessary
with
BOP
Capabilities
talent
in
BP
is
sophisticated
information
Operator
substantial well
engineering the
and the
the
most
and
conditions
which
BOP
were and
must be able
in
BP and Transocean
what
as
Drilling
Contractor
the
best position
to determine
BOP
capabilities
were needed
Operator
at
BSR Macondo BP is
what
technology
was
required
Moreover
as
DWH
BOP.87
Transoceans
confirmed
better that
Manager
than the
of
Subsea
and
Engineering
Well
for
Control
Systems88
well
the Operator
Drilling
Contractor
to well
specific
are
suited
BOP
manufacturer
for
make
the
appropriate
Drilling
BOP
configuration
that
because
and
Contractor have
more
information
about
well.89
BP Was
Including According
Drilling
Actively
Involved
in
the
DWH BOP
and
the
Design
Specifying the
Vice
it
BOP
Stack
Rams Used
Quality for the
Drilling this
to
Camerons
President of Engineering
is
and
Systems case
common
configuring
for the
an
Operator
and
Contractor to take
in
BOP
and
stack.9
Indeed
in
was
role
the
with
DWH BOP
from
the
stack
where
BP
was
involved
the
configuration
in
of that
BOP
beginning91
BP
played an
its
active
specifying
specified
that
stack.92
BP
including
through
predecessor
of
Vastar
the configuration
of the
BOP
stack
rams
87
Code
Title
30 Part 250
Oil
Operations
et
in
the
Outer
Shelf
Institution
Subpart
30
CFR
250
53
Wells
Section
250.400
seq
American
for Blowout
88
Petroleum Prevention
Recommended
Practice
Recommended
Practices
Equipment Systems
for Drilling
API RP 275
53
Deposition of Robert Turlak Deposition of Robert Turlak Deposition of David Deposition of David Deposition of David
89
90
91
July
92
July
29
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
used.93
Moreover
the
Drilling
Contract
between
specified
BPs predecessor
the
Vastar rams.94
and
Transoceans
it
predecessor Falcon
that
model
for the
Ultimately
was BP
decided
what the
of
BOP
stack configuration
would
be and
specified
the location
and types
rams
used.95
BP Knew
Blind
or Should that
Ram
BSR was
Off-Center
Shearing
Drill
Pipe and
its
BP BSR
expert suggests
to seal
that
in
BP
an
on the Cameron
But the
BOP
seal
the
well
emergency.96
same
expert
also
recognizes
that the
drill
BSR was
was
have
drill
pipe and
the well
because
either not
the
pipe
off-center.97
BP
is
sophisticated
in
Operator
and
did not
knew
double
drill
or should that
known
BSR used
the
DWH BOP
did
have
blades
width
of the well
bore and
have
center
to
blades
in
that the
pipe even
drill
BSR may be unable to shear offwhere the BSR would otherwise be able
shear centered
The
with
1999 and
DWH
BOP
part
Transocean be
predecessor
blind of
Falcon
Cameron
which
the
BSR
it
will
shearing
ram
the
Cameron
paper
number
for
2163096.98
purchase order
position
establishes that
2000
outside
for
prepared the
BP
to
predecessor
design
of
by
an
consultant
addressed
Horizon99
BOP
rams
Stack
in
the
Deepwater
and
refers
the
Exhibit
4112
July
at
BP-HZN-MB100021537
BP-HZN-MB100021539
deposition
of
Michael
Exhibit
Byrd 4112
13-14 2011
48812-49418
deposition of Michael
at
BP-HZN-MB100021538
Byrd
July
13-14 2011
48818
4891
June and
2011 5371-13
Shanks Shanks
Report Report
11 29
at
98
BP-HZN-BLY00052579
BP-HZN-BLY00052636 TRN-HCEC-00026928
TRN-HCEC-00026736
at
30
REBUTTAL
EXPERT
REPORT
OF GLEN STEVICK
Ph.D P.E
BSR
rams
position.10 with
Thus BP knew
that did not cutting
or should
have
known
for the
shearing
did
blind
blades
cover
and
not
have
two
shaped
blades
were
used
BSR
VI The
subject to
number
the the
of
design
flaws
and
to
implement
made
DWH
BOP
to
inappropriate
the
Macondo
shear
time the
including
failure
drill drill
use
BSR
well
could
at the
off-center
The Macondo
and
off-center
pipe pipe
BSR was
The
activated
was was
to
off-center
known
and
foreseeable
AMF/Deadman
condition-based
battery to lose
function
failed
activate
because
the 27
Transoceans
volt
flawed
maintenance
its
program allowed
these
blue
control
solenoid
Finally solely
pod 103Y to be
charge and
without
pod
incorrectly
wired
in
identifying of the
problems
did
BP was who
the
actively
involved
the design
for
BOP
and
not
all
rely
on Transocean
conclude
and Cameron
otherwise
the
BSR
disagree
with
of the
experts
reserve
additional
right
to modify
this
report
and
in
to
supplement
to
my
opinions served
if
data
becomes
available
and
response
reports
by
other parties
Dated January
17 2012
Dr Glen
tevick
P.E
100
TRN-HCEC-00026736
at
TRN-HCEC-00026930
31