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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
IN RE: OIL SPILL BY THE OIL RIG * Docket 10-MD-2179DEEPWATER HORIZONIN THE *GULF OF MEXICO ON APRIL 20, 2010 * Section J
*Applies to: * New Orleans, Louisiana
*Docket 10-CV-02771, * March 5, 2013IN RE: THE COMPLAINT AND *PETITION OF TRITON ASSET *LEASING GmbH, et al *
*Docket 10-CV-4536, *UNITED STATES OF AMERICA v. *BP EXPLORATION & PRODUCTION, *INC., et al *
** * * * * * * * * * * * * * * * * *
DAY 6, AFTERNOON SESSIONTRANSCRIPT OF NONJURY TRIAL
BEFORE THE HONORABLE CARL J. BARBIER
UNITED STATES DISTRICT JUDGE
Appearances:
For the Plaintiffs: Domengeaux Wright Roy& Edwards, LLC
BY: JAMES P. ROY, ESQ.556 Jefferson Street, Suite 500Post Office Box 3668Lafayette, Louisiana 70502
For the Plaintiffs: Herman Herman & Katz, LLCBY: STEPHEN J. HERMAN, ESQ.820 O'Keefe AvenueNew Orleans, Louisiana 70113
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Appearances:
For the Plaintiffs: Cunningham Bounds, LLCBY: ROBERT T. CUNNINGHAM, ESQ.1601 Dauphin StreetMobile, Alabama 36604
For the Plaintiffs: Lewis Kullman Sterbcow & AbramsonBY: PAUL M. STERBCOW, ESQ.601 Poydras Street, Suite 2615New Orleans, Louisiana 70130
For the Plaintiffs: Breit Drescher Imprevento
& Walker, PCBY: JEFFREY A. BREIT, ESQ.600 22nd Street, Suite 402Virginia Beach, Virginia 23451
For the Plaintiffs: Leger & ShawBY: WALTER J. LEGER JR., ESQ.600 Carondelet Street, 9th FloorNew Orleans, Louisiana 70130
For the Plaintiffs: Watts Guerra Craft, LLP
BY: MIKAL C. WATTS, ESQ.4 Dominion DriveBuilding 3, Suite 100San Antonio, Texas 78257
For the Plaintiffs: Williams Law Group, LLCBY: CONRAD "DUKE" WILLIAMS, ESQ.435 Corporate Drive, Suite 101Houma, Louisiana 70360
For the Plaintiffs: Thornhill Law Firm
BY: TOM THORNHILL, ESQ.1308 Ninth StreetSlidell, Louisiana 70458
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Appearances:
For the Plaintiffs: deGravelles Palmintier Holthaus& Frug, LLP
BY: JOHN W. DEGRAVELLES, ESQ.618 Main StreetBaton Rouge, Louisiana 70801
For the Plaintiffs: Williamson & RusnakBY: JIMMY WILLIAMSON, ESQ.4310 Yoakum BoulevardHouston, Texas 77006
For the Plaintiffs: Irpino Law Firm
BY: ANTHONY IRPINO, ESQ.2216 Magazine StreetNew Orleans, Louisiana 70130
For the United States U.S. Department of Justiceof America: Torts Branch, Civil Division
BY: R. MICHAEL UNDERHILL, ESQ.450 Golden Gate Avenue7-5395 Federal Bldg., Box 36028San Francisco, California 94102
For the United States U.S. Department of Justiceof America: Environment & Natural ResourcesEnvironmental Enforcement SectionBY: STEVEN O'ROURKE, ESQ.
SCOTT CERNICH, ESQ.DEANNA CHANG, ESQ.RACHEL HANKEY, ESQ.A. NATHANIEL CHAKERES, ESQ.
Post Office Box 7611Washington, D.C. 20044
For the United States U.S. Department of Justice
of America: Torts Branch, Civil DivisionBY: JESSICA McCLELLAN, ESQ.
MICHELLE DELEMARRE, ESQ.JESSICA SULLIVAN, ESQ.SHARON SHUTLER, ESQ.MALINDA LAWRENCE, ESQ.
Post Office Box 14271Washington, D.C. 20004
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Appearances:
For the United States U.S. Department of Justiceof America: Fraud Section
Commercial Litigation BranchBY: DANIEL SPIRO, ESQ.
KELLEY HAUSER, ESQ.ELIZABETH YOUNG, ESQ.
Ben Franklin StationWashington, D.C. 20044
For the State of Attorney General of AlabamaAlabama: BY: LUTHER STRANGE, ESQ.
COREY L. MAZE, ESQ.
WINFIELD J. SINCLAIR, ESQ.500 Dexter AvenueMontgomery, Alabama 36130
For the State of Attorney General of LouisianaLouisiana: BY: JAMES D. CALDWELL, ESQ.
1885 North Third StreetPost Office Box 94005Baton Rouge, Louisiana 70804
For the State of Kanner & Whiteley, LLC
Louisiana: BY: ALLAN KANNER, ESQ.DOUGLAS R. KRAUS, ESQ.701 Camp StreetNew Orleans, Louisiana 70130
For BP Exploration & Liskow & Lewis, APLCProduction Inc., BY: DON K. HAYCRAFT, ESQ.BP America Production 701 Poydras Street, Suite 5000Company, BP PLC: New Orleans, Louisiana 70139
For BP Exploration & Kirkland & Ellis, LLP
Production Inc., BY: J. ANDREW LANGAN, ESQ.BP America Production HARIKLIA "CARRIE" KARIS, ESQ.Company, BP PLC: MATTHEW T. REGAN, ESQ.
300 N. LasalleChicago, Illinois 60654
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Appearances:
For BP Exploration & Covington & Burling, LLPProduction Inc., BY: ROBERT C. "MIKE" BROCK, ESQ.BP America Production 1201 Pennsylvania Avenue, NWCompany, BP PLC: Washington, D.C. 20004
For Transocean Holdings Frilot, LLCLLC, Transocean Offshore BY: KERRY J. MILLER, ESQ.Deepwater Drilling Inc., 1100 Poydras Street, Suite 3700Transocean Deepwater Inc.: New Orleans, Louisiana 70163
For Transocean Holdings Sutherland Asbill & Brennan, LLP
LLC, Transocean Offshore BY: STEVEN L. ROBERTS, ESQ.Deepwater Drilling Inc., RACHEL G. CLINGMAN, ESQ.Transocean Deepwater Inc.: 1001 Fannin Street, Suite 3700
Houston, Texas 77002
For Transocean Holdings Munger Tolles & Olson, LLPLLC, Transocean Offshore BY: MICHAEL R. DOYEN, ESQ.Deepwater Drilling Inc., BRAD D. BRIAN, ESQ.Transocean Deepwater Inc.: LUIS LI, ESQ.
335 S. Grand Avenue, 35th FloorLos Angeles, California 90071
For Transocean Holdings Mahtook & LafleurLLC, Transocean Offshore BY: RICHARD J. HYMEL, ESQ.Deepwater Drilling Inc., 600 Jefferson Street, Suite 1000Transocean Deepwater Inc.: Post Office Box 3089
Lafayette, Louisiana 70501
For Transocean Holdings Hughes Arrell Kinchen, LLPLLC, Transocean Offshore BY: JOHN KINCHEN, ESQ.Deepwater Drilling Inc., 2211 Norfolk, Suite 1110Transocean Deepwater Inc.: Houston, Texas 77098
For Cameron International Stone Pigman Walther Wittmann, LLCCorporation: BY: PHILLIP A. WITTMANN, ESQ.
546 Carondelet StreetNew Orleans, Louisiana 70130
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Appearances:
For Cameron International Beck Redden & Secrest, LLPCorporation: BY: DAVID J. BECK, ESQ.
DAVID W. JONES, ESQ.GEOFFREY GANNAWAY, ESQ.ALEX B. ROBERTS, ESQ.
1221 McKinney Street, Suite 4500Houston, Texas 77010
For Halliburton Energy Godwin Lewis, PCServices, Inc.: BY: DONALD E. GODWIN, ESQ.
BRUCE W. BOWMAN JR., ESQ.FLOYD R. HARTLEY JR., ESQ.
GAVIN HILL, ESQ.1201 Elm Street, Suite 1700Dallas, Texas 75270
For Halliburton Energy: Godwin Lewis, PCServices, Inc.: BY: JERRY C. VON STERNBERG, ESQ.
1331 Lamar, Suite 1665Houston, Texas 77010
For M-I, LLC: Morgan Lewis & BockiusBY: HUGH E. TANNER, ESQ.
DENISE SCOFIELD, ESQ.JOHN C. FUNDERBURK, ESQ.1000 Louisiana Street, Suite 4000Houston, Texas 77002
Official Court Reporter: Jodi Simcox, RMR, FCRR500 Poydras Street, Room HB-406New Orleans, Louisiana 70130(504) [email protected]
Proceedings recorded by mechanical stenography usingcomputer-aided transcription software.
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I N D E X
Page
Miles Randal EzellCross-Examination By Mr. Hartley: 1822Cross-Examination By Mr. Brock: 1847Cross-Examination By Mr. Beck: 1880Redirect Examination By Mr. Sterbcow: 1887Redirect Examination By Ms. Clingman: 1903
Ronnie W. Sepulvado
Direct Examination By Mr. Williams: 1918Cross-Examination By Mr. Underhill: 1947Cross-Examination By Mr. Kraus: 1954
Direct Examination By Ms. Karis: 1958
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MILES RANDAL EZELL - CROSS
AFTERNOON SESSION
(March 5, 2013)
* * * * *
THE DEPUTY CLERK: All rise.
THE COURT: All right. Good afternoon, everyone,
again. Please be seated.
Let's see. Who's up next? Halliburton?
MR. GODWIN: Yes, Your Honor.
THE COURT: Okay.MR. HARTLEY: Thank you, Your Honor. Floyd Hartley
for Halliburton, I'll be taking Mr. Ezell on cross.
(WHEREUPON, MILES RANDAL EZELL, having been
previously duly sworn, testified as follows.)
CROSS-EXAMINATION
BY MR. HARTLEY:
Q. Good afternoon, Mr. Ezell.
A. Good afternoon.
Q. I want to start with the morning meeting that you had on
the morning of April 20th, 2010. I think, in response to both
Mr. Sterbcow's question and Ms. Clingman's, you said that there
was at least some discussion about the cement job. Is that
right?
A. Yes.
Q. And if I heard correctly, you said that it was deemed to
be a successful cement job?
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A. To the best of my recollection, yes.
Q. This was a BP engineer on shore that's conveying that
information?
A. My memory's not clear exactly who it was that conveyed it,
but I heard it.
Q. And as a result, that they were not going to run a cement
bond log?
A. Yes.
Q. There were cement bond log tools on the rig that morning?A. To the best of my recollection, they were still there.
Q. And there was a Schlumberger crew on the rig that morning?
A. I believe so. I think they were supposed to depart that
day.
Q. Now, having been on the Deepwater Horizon for some nine
years or so, you have had experience with cement bond logs; is
that right?
A. I mean, yes, some.
Q. It's not uncommon to run a cement bond log?
A. That's correct, it's not uncommon.
Q. Now, had one been run and an issue with either top of
cement or channeling had been identified, that would give the
crew the opportunity to run some remediation of the cement job?
A. I suppose, if that was BP's election to do that.
Q. That's not a Transocean decision?
A. No, sir, that wouldn't be.
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Q. In your experience, is it uncommon to remediate cement
jobs?
A. Is it uncommon to do what?
Q. To remediate cement jobs, run a squeeze job?
A. No, I wouldn't say it was uncommon.
Q. It's something that happens on rigs?
A. Yes, it does happen from time to time.
Q. And had a cement bond log been run that morning and an
issue identified with the cement, an opportunity to remediatethe cement in the primary casing job could have been performed?
MR. BROCK: Your Honor, objection. He's calling
now -- asking now for opinion testimony from the witness. I
object to it on that basis.
THE COURT: Your question is: Had a cement bond log
been run, could it have been --
MR. BROCK: It sounds like --
MR. HARTLEY: Based on the witness's experience on
the rig and having run CBLs and having been there for the
performance of squeeze jobs.
THE COURT: That sounds like something you ought to
be talking to the cementing experts about, though. I'm going
to sustain the objection.
BY MR. HARTLEY:
Q. You were on the Deepwater Horizon for basically its entire
life in the Gulf of Mexico?
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A. That's correct.
Q. You worked as a driller, toolpusher, and senior toolpusher
on that rig?
A. That's also correct.
Q. Okay. Now, Ms. Clingman ran through some of your
education and training with Transocean. Do you recall that?
A. Some of my training?
Q. Some of your training. For example, you've taken well
control school?A. Yes.
Q. With Transocean?
A. Yes.
Q. You've been well-control certified?
A. I have.
Q. In fact, you've been recertified about every two years
since the late '80s?
A. It's been multiple times. I don't remember exactly how
many.
Q. It's fair to say you're generally familiar with the basic
principles and concepts of well control?
A. Fair.
Q. I think, in response to Mr. Sterbcow's question this
morning, you'd mentioned that mud is the first barrier in the
well. Is that fair?
A. Yes.
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Q. If we look at TREX-1454 at 286809.
Now, when you've taken these well control schools
with Transocean, I think you said you covered in fairly great
detail the Transocean Well Control Handbook?
A. Correct.
Q. You took tests on the various sections?
A. Correct.
Q. So you are familiar with the well control manual that was
actually on the rig?A. I'm sorry. Say that again.
Q. You were familiar with the Transocean Well Control
Handbookthat was on the Deepwater Horizon?
A. Yes.
MR. HARTLEY: If we go to page 6809. Blow up the
first paragraph.
BY MR. HARTLEY:
Q. Now, I think this is consistent with what you just said --
let me know if I'm wrong about that -- that "the primary well
control is the use of wellbore fluid density to provide
sufficient hydrostatic pressure to prevent the influx of
formation fluid into the wellbore. It is of the utmost
importance that primary control is maintained at all times."
Would you agree with that?
A. Yes, I would.
Q. Before you displace that heavy mud with seawater in the
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well, you want to make sure of the well integrity; is that
fair?
A. Yes.
Q. If there's any question about the integrity of that well
downhole, the job and make sure you get it right?
A. Yes.
Q. And that's why I think you told Mr. Sterbcow that
vigilance is absolutely necessary at that point and through the
displacement progression. Fair?A. It's necessary from a driller at all times.
Q. But even more so at this point where you're displacing and
removing the primary well control barrier?
A. It's very important.
Q. And whose decision is that to remove that primary barrier?
A. Whose decision, was your question?
Q. Yes, sir.
A. That would be something that -- that would be under BP's
decision-making process.
Q. Okay. Halliburton, for example, either the cementer or
the mud log company, they're not involved in the decision on
whether to remove the mud engaged in displacement?
MS. CLINGMAN: Your Honor, I'll object to lack of
foundation.
THE COURT: Sustained.
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BY MR. HARTLEY:
Q. In your nine years in the Gulf of Mexico on the Deepwater
Horizon, have you had an opportunity in these 50-some-odd wells
you've been on to be on tour during the displacement procedure?
A. Be on tour during displacement of?
Q. The displacement of heavy mud to seawater.
A. Yes.
Q. Have you had an opportunity to review displacement
procedures that have been provided to Transocean?A. Yes, I have reviewed displacement procedures in the past.
Q. Did you review the displacement procedure on the Deepwater
Horizon for the Macondo well?
A. On what day are you referring to?
Q. On the morning of April 20th, you attended a Transocean
meeting and then the morning meeting with BP. In either of
those meetings, was the displacement procedure discussed?
A. Not to my knowledge. It was held generally on the rig
floor.
Q. Do you recall ever having seen the displacement procedure?
A. I virtually had no input on the displacement procedure.
That was handled without me.
Q. In your experience from prior wells, these 50-odd wells
you drilled or helped drill in the Gulf of Mexico, did you have
an opportunity as a driller or a toolpusher to actually be
involved in the displacement of those wells?
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A. Yes, I have been involved.
Q. In any of those wells, did you ever see a displacement
procedure drafted by Halliburton?
A. The procedures were generally -- they generally came to us
from M-I.
Q. Not from Halliburton?
A. Not from Halliburton.
Q. And the decision to go forward with the displacement,
whether it's after a negative test or otherwise, is not onethat Halliburton, in your experience in the Gulf of Mexico, was
the one to make?
A. You're right.
Q. After the hydrostatic pressure buildup mud, I think you
told Mr. Sterbcow that the BOP is the second barrier. Is that
right?
A. Yes, in my opinion.
Q. Is that Transocean equipment?
A. It is Transocean equipment.
Q. Now, based on your experience in the Gulf of Mexico, is
Halliburton involved in either the maintenance or repair or
inspection of the BOPs?
A. No, sir, they aren't.
Q. Is Halliburton involved at all in the operation of the
BOP?
A. No, sir, they aren't.
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Q. Now, when you went through with Ms. Clingman the animation
of the drill shack, you were shown a portion of the BOP control
panel. Do you recall that?
A. I do recall seeing the BOP control panel.
Q. In what other places on the rig is there a BOP control
panel?
A. Primarily, the bridge would be the secondary.
Q. There's not one in the mud logger shack, is there?
A. No, sir.Q. The mud logger doesn't have any access to the BOP, can't
shut annulars, shut the DBRs, certainly can't shear the casing
or EDS; right?
A. Thank God, no.
Q. After the BOP -- when you were talking to Ms. Clingman,
you talked about the last line of defense once gas is in the
riser. And that's the emergency diverter system; right?
A. I'm not familiar with that term you just used there.
Q. The diverter system?
A. I thought you said emergency diverter system.
Q. Pardon me. The diverter system, you're familiar with
that?
A. Yes, I'm familiar with the diverter.
Q. And I think you characterized that as sort of the last
line of defense as you're trying to maintain control of the
well. Is that a fair characterization?
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A. Typically, yes.
Q. And again, the controls for the diverter are located in
the drill shack; right?
A. Yes.
Q. And on the bridge?
A. That's correct.
Q. The mud logger has no ability to activate the diverter?
A. No, he didn't.
Q. Nor does Halliburton's cement personnel?A. No.
Q. So in each case, the well control responsibility on the
well, as you understand it, based on your experience, lies with
Transocean to push the buttons, to pull the levers, to shut in
a well, and control it?
A. We would be the people that would shut the well down, yes.
Q. We talked to you very briefly about the negative test.
It's been covered at some length. I think you've talked about
Jimmy Harrell being adamant that one be run. Do you recall
that testimony?
A. I do.
Q. And I was curious as to why you characterized him as being
adamant. Was there some sort of dispute as to whether or not
to run a negative test?
MR. BROCK: Object to that, Your Honor. We've been
over this about three times now. Object as asked and answered.
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THE COURT: Sustained.
BY MR. HARTLEY:
Q. Do you think it was a good, sound policy to run a negative
test?
A. I do agree it was a good, sound policy.
Q. Do you have any reason to believe that the BP well site
leaders disagreed with the decision to run a negative test?
A. I don't think they disagreed, no.
Q. In the end, you understand now that there was a pressuredifferential between the reading on the drill pipe and the
reading on the kill line?
A. Yes.
Q. Now, you didn't know that when you talked to Jason
Anderson that night, did you?
A. I did not know that.
Q. Had you known that, would you have responded in a
different manner?
A. Had Jason told me he had a problem or something he
couldn't understand, I would have been right there with him.
Q. Prior to getting into a well control situation or a well
control event and addressing that, certain personnel on the rig
have a responsibility to monitor the well in an attempt to
detect the situation before it gets out of hand. Would you
agree with that?
A. Yes.
OFFICIAL TRANSCRIPT
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Q. And that well monitoring responsibility lies primarily
with the Transocean drill crew?
A. Primarily.
Q. Primarily.
If we look at TREX-1453 at 48232, we've talked about
the well control handbook, Mr. Ezell. Are you also familiar
with the Deepwater Horizon Emergency Response Manual?
A. Yes.
Q. That's something that was kept on the rig?A. Yes.
Q. And what is your understanding of the purpose of the
Deepwater Horizon Emergency Response Manual?
A. It was a guide to kind of assist you in any major
emergency.
Q. And if we look at paragraph 2 in TREX-1453 in the
emergency response manual, it talks about the detection of a
kick. Do you see that section, Mr. Ezell?
A. Yes, sir.
Q. It reads: "Detection of a kick (intrusion of liquid or
gas into the wellbore) is the responsibility of the driller."
That's a statement with which you agree; right?
A. It is a driller's responsibility for kick detection.
Q. "The driller and his crew will continuously monitor the
surface system indicators (flow rate, pit level, etc.) and
break downhole indications, such as mud pressure, for signs of
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a kick."
Do you agree with that?
A. Yes.
THE COURT: I think we've tread over this ground. I
don't remember if it was this exact document, but this
testimony is repetitive. This witness has already said the
exact same things. So we need to move this along. Okay?
MR. HARTLEY: Absolutely, Your Honor.
BY MR. HARTLEY:Q. At all times somebody is supposed to be in that Transocean
driller's chair; isn't that true, Mr. Ezell?
A. When we're connected to the wellbore, yes.
Q. And I think earlier this morning in your testimony you
said that Transocean requires at least two well control
personnel to be in that drill shack.
A. That was our procedure.
Q. Now, the mud logger is in a different sort of position in
terms of his well monitoring responsibilities and duties.
Would you agree with that?
A. I really don't know exactly what his responsibilities
would be.
Q. Do you know what information is available to the mud
logger or was available to the mud logger on the Deepwater
Horizon?
A. To the best of my knowledge, they had all the information
OFFICIAL TRANSCRIPT
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that was available to us on the HITEC; and, of course, they had
other data that they were looking at.
Q. You know Joe Keith, don't you?
A. Excuse me?
Q. You know Joe Keith?
A. I do.
Q. You worked with him for quite a long time; isn't that
right?
A. Yeah. I don't know the exact amount of time, but, yes,sir, a long time.
Q. He had been on the rig since '01, '02?
A. Possibly. I can't remember exactly when he came on, but I
will agree it was a pretty good length of time.
Q. And he did a good job. You thought he was a good man,
didn't you?
A. I had no problem with Joseph Keith.
Q. You never had a situation in which Joe Keith missed a
kick, did you?
A. No, sir, not any that I'm aware of.
MR. HARTLEY: Robin, let's pull up D-8179.
BY MR. HARTLEY:
Q. Very quickly, Mr. Ezell. Ms. Clingman showed you an
animated version of the drill shack. I don't have that one,
but I've got a static display. And what I want to ask you
about, there's a screen over here on the left-hand side that's
OFFICIAL TRANSCRIPT
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labeled "Drillers Sperry-Sun display."
Do you see that?
A. I do.
Q. You've talked briefly with Ms. Clingman this morning about
the information displayed on there. Can you give us some sort
of visual on what the driller would see in his A-chair looking
at that screen?
A. To be totally honest with you, we didn't use that screen a
lot. We relied heavily on the HITEC, which was in the directline of sight with the driller and the rotary table, because he
has to have the ability to monitor that information and plus
watch what's going on in front of him.
It was a peripheral-type monitor for us to kind of
support, if we needed to, what we saw.
Q. You viewed the mud logger simply as a backup to you?
A. A mud logger was a backup to me.
Q. To your knowledge, was all of the information the mud
logger had in his shack available to you on this screen in
D-8179?
A. Yes, sir, I believe he had all the information that we
had.
Q. And vice versa, you had all of the information he had?
A. No, sir, that's not the case.
Q. What information did the mud logger have that was not
available to the Transocean drill crew?
OFFICIAL TRANSCRIPT
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A. I don't know the full scope of it, but there were -- there
were other parameters that were specifically part of Sperry
data that was not part of ours.
Ours had a full array, plus it also had all the
control features for the equipment. So there were differences.
Q. Are you speaking about the MWD/LWD type data?
A. I am, yes.
Q. So let me make my question a little more precise. All of
the information that the mud logging unit, the mud logger waswatching, all of that data -- pit sensors, blowout, gas
traps -- all of that information was available to the
Transocean drill crew?
A. Yeah, we had that on HITEC or the mud logger did have it.
Q. Based on the position of the drill shack and the
responsibility of the driller, is it fair to say that there
aren't operations going on on that rig floor that the driller
is not aware of?
A. Any operations that would definitely be in the driller's
line of sight -- and you can see what that would be -- would
definitely be something he would be aware of.
Q. Would the driller be aware of movement of mud between
various pits on the rig?
A. Yes, he would.
Q. Would the driller be aware of when the sand trap's being
emptied?
OFFICIAL TRANSCRIPT
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A. Yes, he would. It would be a different way of discovering
that; but, yes, yes, he would be aware.
Q. Similarly, he would know if the trip tanks were being
dumped?
A. Yes, he would know that.
MR. HARTLEY: Robin, let's put up D-8180, please.
BY MR. HARTLEY:
Q. Have you been to the mud logging shack on the Deepwater
Horizon?A. In nine years, I've probably been in that shack maybe
twice. It was very rare.
Q. Do you remember the last time you were in that shack?
A. No. It could have been as much as a year prior to the
incident. But, you know, it had its own purge system with an
alarm, and you had to jump in and jump out, you know, or you
would set that off. I really had no need to go in.
Q. In D-8180, it shows, in the upper left-hand corner, an
exterior view. Does that look like the mud logging shack that
was on the Deepwater Horizon?
A. I guess. I have very little information on that, but it's
similar.
Q. In the lower right, we've pulled out a circa 2003 picture
of the Deepwater Horizon mud logging shack. Does that fairly
and accurately represent, as best you recall, what the shack
would look like from the inside?
OFFICIAL TRANSCRIPT
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MS. CLINGMAN: Your Honor, I'm going to object, lack
of foundation. The witness has said he doesn't know anything
about this area in --
THE COURT: Well, I don't know if he does or he
doesn't. Have you been inside of there?
THE WITNESS: Yes, sir, I have; but it's only been a
couple of times and I don't have a real good memory of it.
THE COURT: All right.
BY MR. HARTLEY:Q. Do you have an understanding or a sense of what data is
available to the mud logger while he's on tour in terms of rig
operations?
A. I'm sure that just like we've been discussing, he was
connected with HITEC. So he had the ability to see what we
were seeing on the HITEC monitor.
Q. Was he in a position where you could see the rotary table?
A. No. He was behind the drawworks.
Q. Was he in a position to, with the exception of following
data on his screen, understand what rig operations were
underway?
MS. CLINGMAN: Objection, Your Honor, lack of
foundation as to what he would understand from the mud logger's
shack.
THE COURT: Overruled.
Can you answer that, sir?
OFFICIAL TRANSCRIPT
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THE WITNESS: I'm thinking. Would you please
restate?
THE COURT: Was he in a physical position? Is that
what you mean?
MR. HARTLEY: Yes, sir.
THE COURT: Physical location?
MR. HARTLEY: Yes.
MS. CLINGMAN: He answered that question. Then he
said would he be able to understand what operations were goingon. That was the question to which I lodged an objection to.
MR. HARTLEY: Let me go at it a different way.
THE COURT: Why don't you do that. I understood the
question somewhat differently, but go ahead and ask the
question again.
BY MR. HARTLEY:
Q. In your experience as a driller toolpusher, senior
toolpusher on the Deepwater Horizon, when you're on tour in the
drill shack, do you call the mud logger and advise him of what
operations are going on on the rig?
A. The mud logger is generally always in the loop. He should
come to the pre-tower meeting to know what's going to happen
during the day.
Q. When you say he's generally always in the loop, how does
he get into the loop, with the exception of attending the
pre-tower meeting?
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A. Communication. Yeah, the driller would talk to the mud
logger.
Q. And that's the requirement of a driller's job, to
communicate effectively with the mud logger, to advise him of
what's going on on the rig?
A. I don't know if it's a requirement for his job, but it's
something that we did do. We did communicate.
Q. It would be a good, safe practice to tell the mud
logger -- for example, if you're moving mud between pits, ifyou're dumping a trip tank, those sorts of operations, to tell
him would be a good, safe practice, in your experience?
A. Yes, it would be a safe practice, for sure.
Q. I want to turn briefly to this prior control event that
you talked about earlier.
Do you recall testifying that you had been briefed on
the Sedco711 event in the North Sea?
A. Yes.
Q. That's a well control event that happened on, what,
December 23 of 2009?
A. Can you show me the document to refresh my memory? I
don't remember the date exactly.
MR. HARTLEY: Absolutely. Let's show Exhibit 1523.
BY MR. HARTLEY:
Q. If we look at the upper right-hand corner, this is the
well operations group advisory issued on April 5th of 2010. Do
OFFICIAL TRANSCRIPT
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you recall ever seeing this prior to April 20th of 2010?
A. No, sir, not -- not prior to.
Q. Okay. Let's look at Exhibit 926. This is -- in the upper
right-hand corner, an April 14th, 2010 advisory just issued in
the North Sea. Do you recall ever seeing this advisory prior
to April 20th, 2010?
A. No, sir. But those are so current that I don't know that
they even had a chance to go through the management process to
where they're distributed in the right places. They're verycurrent.
Q. Do you know who Bill Sannan is?
A. Yes, I do.
Q. General manager for North America Transocean at the time?
A. Yes.
Q. Do you know if he would have been the individual
responsible for circulating the April 5th global advisory?
A. I'm sorry, I don't know.
Q. Fair enough.
This morning, in testifying in response to
Mr. Sterbcow's questions, you said something to the effect,
lessons learned would not add value because the crew was
already aware of basic concepts. Do you recall that?
A. I do.
Q. Do you think it would be helpful to be reminded to
exercise additional vigilance, for example, after a negative
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test or displacing seawater?
A. I really don't think these would have been of great value
to the crew because they were a competent crew. They were well
trained, and I don't think it would have been a large value to
them.
Q. You certainly would want them to continue going through
training and progressing in their skills?
A. Right, but this is basic well control examples here.
Q. And they should have an understanding of basic wellcontrol?
A. I'm sorry, I didn't hear you.
Q. And they should have that understanding of basic well
control?
A. Yes, yes.
Q. Things like paying extra vigilance when you remove the
primary barrier in the well?
A. Yes. They were aware that barriers would fail or could
fail.
Q. Things like shutting in immediately upon detection or
suspicion of a kick?
A. They were also well aware of that.
Q. Things like at the first indication of a potential kick,
you shut the pump's flow check and then shut in, as you
discussed with Ms. Clingman?
A. They were highly aware of that as well.
OFFICIAL TRANSCRIPT
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Q. In response to Mr. Sterbcow's questions, you said
something about the drill crew, that they were doing everything
within their training to keep the well under control. Do you
recall that?
A. Yeah, I believe I do.
Q. And that would be the sort of things we just discussed
about how you would appropriately respond to a well control
event. Is that what you meant?
A. I meant they exercised all the training that they had beentaught to try to get the well under control in those last few
minutes.
Q. Do you know when the drill crew first had any indication
that there may be a problem downhole?
MR. BROCK: I'm going to object on foundation.
THE COURT: Sustained.
BY MR. HARTLEY:
Q. In your discussions with Mr. Anderson or Mr. Curtis, did
they convey to you any information that would suggest when they
suspected a problem?
A. They didn't relay any of that to me, no, until the very
end.
Q. And that would be the call from Mr. Curtis?
A. It would be.
Q. That's when he told you, "Randy, we have a problem. We
have mud shooting to the crown"?
OFFICIAL TRANSCRIPT
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A. Correct.
Q. You responded, "Is the well shut in?"
A. Right.
Q. He said, "Jason's shutting it in now"?
A. Yes.
Q. That would suggest at least that mud was shooting up to
the crown prior to an effort to shut in the well; right?
MS. CLINGMAN: Your Honor, I would object not only to
foundation, but this is repetitive. This is what Mr. Ezelltestified to earlier.
THE COURT: It is. I sustain the objection.
BY MR. HARTLEY:
Q. Based on your understanding of your conversation with
Mr. Curtis, when did they first attempt to shut in the well?
A. I have no idea.
Q. That shut-in process would be the two-button sequence you
discussed. It would take about 50 seconds?
A. I don't know exactly what they shut in first, to tell you
the truth.
Q. Based on your experience and your well control training
over 20-some odd years, what is the Transocean policy for the
first element to shut in -- to shut in the well?
A. They would typically close an annular, but I don't know
which one they selected.
Q. Were you familiar with the status of the BOP on the
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Deepwater Horizon as of April 20th, 2010?
A. Explain what you mean by "status."
Q. Did you know what were -- what was in each of the ram
cavities?
A. Yes, I did at that time.
Q. And you knew the lower annular had been converted to a
stripping packer in, what, 2006?
A. I'm not sure of the right date, but, yes.
Q. It had been converted to a stripping packer prior toApril 20th, 2010?
A. Yes, it had been converted prior to 2010.
Q. So you wouldn't expect the drill crew to shut that annular
in a well control event to try to contain the flood?
A. I can't answer for what the guys thought or what they
did --
Q. That's fair.
A. -- at that moment.
Q. That's fair.
Based on your experience and your training, what
would you do first in attempting to shut the well in on the
Deepwater Horizon?
A. I think that would have been a call that I would have had
made when I was on the floor that night. I mean, I don't know
that I can sit here in the courtroom and make that call here.
Q. It's tough to put yourself in their shoes.
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A. You don't know how tough it is.
MR. HARTLEY: Thank you, Mr. Ezell. I don't have any
more questions for you.
THE WITNESS: Thank you.
THE COURT: All right. BP?
MR. BROCK: Yes, sir.
Your Honor, are we good to proceed?
THE COURT: Yes.
CROSS-EXAMINATIONBY MR. BROCK:
Q. Mr. Ezell, I'm Mike Brock; and I have some questions for
you, I'm supposed to say, on cross-examination. So just
putting that in for the record.
You might see me flipping through my notes here a
bit. I had a bigger outline. Many of the questions that I had
for you have been asked, and I'm going to do my best not to go
back over material that's already been covered. So if you
would just be patient with me a little bit, I would appreciate
that.
A. Yes, sir.
Q. I understood from your testimony yesterday and today that
your recollection is that the Deepwater Horizon had drilled
about 50 wells in the Gulf of Mexico. Correct?
A. Yes, sir, 50-plus, I think.
Q. You drilled the deepest in history at the time it was
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drilled, and that was the Tiber; correct?
A. That is correct.
Q. And the deepest water depth well, which was the Walker
Ridge well?
A. Correct.
Q. And going into April of 2010, you-all had a history --
safety history that was very impressive in terms of not having
a lost time incident for about seven years?
A. That's also correct.Q. And the men and women of the Deepwater Horizon were very
proud of their record both in terms of performance -- that is,
drilling wells -- as well as in the area of safety?
A. Yes, sir, we were.
Q. And as you've expressed here today, the folks at BP were
also proud of the record that Transocean had developed on the
Deepwater Horizon during that period of time?
A. They were exceptionally proud of Deepwater Horizon.
Q. And on most of these wells that were drilled in the Gulf
of Mexico, Halliburton was also a partner in those endeavors
providing advice about cement?
A. That's correct.
Q. On each of these wells -- I think you said maybe one was
done for a different company; but on each of these wells, you
would be executing a BP drilling plan?
A. Correct.
OFFICIAL TRANSCRIPT
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Q. And you would be working with BP well site leaders who
would be there on the Deepwater Horizon during the operations?
A. That's correct.
Q. And then you would also be interacting with different
contractors that might be there, like the mud contractor, the
cement contractor. You might have other people there to do
special tools or special tasks. But you would have a good
number of contractors that would be on the rig also?
A. That's correct, too.Q. And it was your view that the Deepwater Horizon, working
with BP and these other contractors over a long period of time,
had established a very good track record?
A. You're right.
Q. It was a good team?
A. It was a very good team.
Q. And it's important in this business, the specialty
business of deepwater drilling, that you have good cooperation
and good communication between the parties as the drilling
process is ongoing?
A. Yes.
Q. Now, you mentioned earlier today -- I believe they showed
you a document where it showed that you came on board on April
the 13th -- do you remember that -- and then would have been
there up until the 20th?
A. Yes, sir, I believe I do.
OFFICIAL TRANSCRIPT
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Q. Okay. So that would have been about seven days before the
event that you had been on board?
A. Yes, sir, about that.
Q. Okay. And the records that I've looked at show that you
also were there for hitches for 1/19 -- that is, January 19th
of 2010 -- to February 8th, 2010. And then you would have also
had a hitch from March the 4th, 2010, to March the 25th, 2010.
Does that sound right?
A. Yes, sir. It's been a long time, but that sounds like itcould be possibly, yes.
Q. Your schedule would be 21 days -- well, you were on
14 days on and 14 days off? Or 21?
A. No, it would have been 21.
Q. 21, I'm sorry. Yeah, 3/4/2010 to 3/25, you would have
been on the 21-day schedule?
A. Yes, sir.
Q. Now, on those three hitches -- that is, from the time you
went to the Macondo well site up through the explosion that
took place on April the 20th -- you never felt pressure to rush
through the operations; is that correct?
A. Not at all.
Q. And at all times when you were on the Deepwater Horizon at
Macondo, you felt that Transocean and BP personnel on board the
rig were acting in a careful, safe, and prudent manner?
A. Yes, sir.
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Q. You believed that the operations on board the rig were
safe?
A. I did.
Q. I want to ask you just a couple questions about the well
control manual that we haven't covered. I'm not going to pull
it up and ask you in detail.
Is it correct that copies of the Transocean well
control manual were available on the rig floor in the
toolpusher's office, in the OIM's office, and that the drillershad individual copies of that well control manual?
A. The well control manuals were at those locations.
MR. BROCK: Now, if I could go back and just ask that
we pull up Exhibit D-365, please.
BY MR. BROCK:
Q. You were -- can you see this okay?
A. Yes, sir.
Q. Okay. You were shown a little earlier the organization
chart that covers the drilling operations. Do you remember
that? It had the OIM to the senior toolpusher, and then right
on down, toolpusher to deckpusher and driller. Do you remember
those conversations?
A. Yes, I do, sir.
Q. Now, this, in fact, is the Transocean Deepwater Horizon
organizational chart for the entire rig, isn't it?
A. I'm not sure it's for the entire rig.
OFFICIAL TRANSCRIPT
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Q. Okay. Well, it takes into account, at least on the
left-hand side over there, the marine operations, it has the
drilling operations, and then it has "Maintenance" and
"Materials" over on the right-hand side, if you look at the
lines reporting directly to the OIM. Do you see that?
A. Yes, it does have quite a few more positions on this one.
Q. Right. Than the one that you looked at earlier?
A. Yes.
Q. And you would agree that the OIM was the person who was incharge of the Deepwater Horizon rig?
A. The OIM was the PIC when we were drilling.
Q. He was in charge of the rig, wasn't he?
A. Yes, he was the PIC.
Q. The good news is that every one of these pages I'm turning
is one where I'm not asking questions, so just hang with me
here.
A. That is good news.
Q. All right. Just a couple more details on the driller's
obligations in terms of shutting in the well.
You would agree that the driller, the moment he or
she sees a hydrocarbon influx, would want to start controlling
the well?
A. Yes.
Q. And that you do not wait to see how the situation develops
before you exercise well control?
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A. Well control should be -- the first thing on a driller's
mind would be minimize the influx, shut it in as soon as
possible.
Q. Do you agree with my statement that you shouldn't wait to
see how the situation develops before you implement your well
control measures?
A. No, you shouldn't wait to see how it develops.
Q. Right. Thank you.
And the reason for that is that if you shut in thewell quickly, it will minimize the influx of formation fluids?
A. Correct.
Q. And the purpose of shutting in the well immediately is to
keep hydrocarbons below the BOP?
A. To minimize the influx.
Q. I think you've said this, and I apologize for asking it
again, but just in case.
Do you agree that nothing is more important than well
control, that that is the primary goal of the Transocean crew?
MS. CLINGMAN: I'm going to object that it's been
asked and answered, but maybe not --
THE COURT: All right. I'll let him answer. That's
fine.
THE WITNESS: Can I answer it?
THE COURT: Yes.
THE WITNESS: Would you state it again?
OFFICIAL TRANSCRIPT
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BY MR. BROCK:
Q. Yes. I'll be happy to.
You would agree that nothing is more important than
well control? That's your primary goal?
A. Well control is a primary goal.
Q. Now, you've talked a little bit about certification for
well control in the period of 2001 to 2010. I wanted just to
ask you a few follow-up questions about that, sir.
If we could turn to TREX-52652, please.Do you see this is "Fundamental Well Control
Course-Content and Objectives"? Do you see that?
A. Yes, sir.
Q. Then if we look at 526521.2, if you could pull that out,
please.
Do you see this is going over the areas of
instruction, evaluation, and testing?
A. Yes. Give me just a moment to fully read it here.
Q. Sure.
A. (Witness reviews document.)
Okay.
Q. Okay. Actually, I have one here that's not highlighted.
Do you see the section "Formation Fracture Pressures"? Do you
see that? Fourth bullet --
A. Yes, I do. I do.
Q. -- fourth bullet down?
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And is there a section there, "Why's and When's of
FIT and LOT Procedure"?
A. Yes.
Q. What is the FIT procedure?
A. That's formation and integrity.
Q. Test?
A. And leak-off test procedure.
Q. And was this part of the course material that would be
included in your well control training?A. If we look back, I believe this was entitled "Fundamental
Well Control Training." It was not the supervisory training.
Q. In supervisory training, would you receive training in FIT
and LOT procedures?
A. To some degree, but it's not outlined as we're looking at
here.
Q. It would be at a different format and at a higher level?
A. It would be at some format, yes. I can't remember exactly
what.
Q. Did you receive training on the why's and when's of the
FIT and LOT procedures?
A. Yes, to some degree. Of course, that's our client or the
oil company that actually, you know, handles that particular
procedure there, both -- what we get is kind of an overview,
just kind of a global view of why this is happening.
Q. Okay. Thank you.
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Let me ask you to turn -- or let's -- or I'm going to
turn now to one section from the well control handbook,
TREX-1454. And if we can go to call-out 14.2.
And I'm not going to cover this in detail, but I just
need to show you this for the next one.
Do you see here, on the first one, it says, "It is
the responsibility of the driller to shut in the well as
quickly as possible if a kick is indicated or suspected"?
Do you see that?A. Yes, sir, I do see that.
Q. All right. Now, if we go down to 1454215.1, I want to ask
you a couple of questions about this section.
It says: "The driller has full authority to flow
check or shut in the well, as he sees fit, and is expected to
fully investigate any occurrence which deviates from a stable
trend."
Do you see that?
A. I do.
Q. Now, you've talked about a little bit about flow check
today. You've described that. I'm not going to ask you to go
back into that. But if the driller sees an occurrence which
deviates from the stable trend, how does he reach out to others
on the rig to conduct the flow check?
A. I'm not really with your question there when you say
"reach out to others."
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Q. Yes. So let's go back to this.
You've described what a flow check is. How does the
driller check flow if there has been an occurrence which
deviates from a stable trend?
A. Well, he would typically shut his pumps down, pick up to
where the tool joints are not located in an annular or ram, and
he would check at that point to see if the well was flowing.
Q. And would he do that himself? Would he make a personal
observation to see if the well was flowing, or would he asksomeone to do it, typically?
A. It depends. There is a CCTV that could show the flow
line, which he could actually see that. Or he had the ability
to ask a checker hand to do a flow check for him.
Q. Okay. Could you do a flow check by walking out to the
rotary table and looking down the hole?
A. You could, but that would be something a driller wouldn't
do.
Q. Could he ask someone to go out there, shine a flashlight
down and see if a well is flowing?
A. We used to do it in the old days like that.
Q. Sure.
The driller does not need permission from BP to
conduct a flow check; is that right?
A. That's right, he doesn't need permission.
Q. Just so that we're all clear on this, the first thing that
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you do to conduct a flow check is to shut down the pumps;
right?
A. That would be your first step.
Q. Right. And if the pumps are shut down, the well should be
static?
A. Correct.
Q. If it's flowing, if you're -- if the flow is coming back,
then you have a situation that you have to deal with?
A. You do have a situation you have to deal with andunderstand, for sure.
Q. If you'll just be patient with me, we're saving time here.
So sorry about that.
A. Okay. Good. No problem.
Q. You've mentioned this. Let me just go back over it a
little more.
The Sperry-Sun mud loggers monitored information on a
continuous basis throughout the well; correct?
A. Yes.
Q. And part of their roles and responsibilities were to
record pit volume totals for the purpose of monitoring the
well?
A. That's my understanding.
Q. Did you understand that the Sperry-Sun mud logger's sole
obligation on the Deepwater Horizon was to monitor the pit
volumes and other information and data that the driller was
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looking at?
A. I'm not so sure it was their sole obligation, but I do
know they had a large part to play in that.
Q. As the senior toolpusher on board the Deepwater Horizon,
you expected someone from Sperry-Sun in the mud logger's unit
to be monitoring the data at all times?
A. Yes.
Q. And the mud logger is supposed to call the rig floor to
notify someone if he takes a break or leaves the mud loggershack?
A. That is correct.
Q. All right. Let's look at Exhibit 1454.215.3, please.
This is a document we haven't looked at today.
You see there at the top where it says: "Recognizing
the signs of an influx and acting with the necessary speed to
minimize it requires constant, accurate observation and
recording of the mud volume, weight, and relevant parameters."
Do you see that?
A. I do.
Q. And then it comes down and talks about "the crucial
feature being the communication triangle between the driller,
the mud loggers, and the derrickman/mud engineer in the mud
pits."
Do you see that?
A. Yes, sir, I do.
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Q. And then it goes on to talk about how important it is to
maintain communication between those three points of contact.
Do you see that?
A. I do.
Q. The driller would be the Transocean driller; correct?
A. Correct.
Q. Mud loggers in this particular case would be the
Sperry-Sun mud loggers?
A. Correct.Q. And the derrickman would be the Transocean derrickman?
A. Correct.
Q. BP is not in this particular communication triangle, are
they?
A. Not in what I'm looking at, no, sir.
Q. Now, on the Deepwater Horizon on the 18th, 19th, and
20th -- let me just take a step back.
You know who Ms. Kathleen Willis was, don't you -- or
is?
A. Yes, sir. I believe she worked for Sperry-Sun for a
length of time on the rig.
Q. Okay. And to the best of your recollection, did
Ms. Willis ever express to you any concerns about her ability
to monitor the pits or the mud?
A. No, sir, not to me.
Q. She never came to you on the 18th, 19th, or 20th to
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express any concerns regarding her ability to do her job?
A. No, sir.
Q. She never came to you and expressed any concerns about the
safety of the operations on board the rig?
A. Not at all.
Q. You also know Mr. Joseph Keith, as you referenced here
today?
A. I do.
Q. He was a mud logger on the Deepwater Horizon, been there agood while?
A. That's correct.
Q. On the evening of April the 20th, did he ever express any
concerns to you about the safety of the operations on board the
rig?
A. No, he did not.
Q. Or did he ever say to you, as the senior toolpusher, that
he had any concerns regarding the ability to do his job?
A. No, sir, he didn't.
Q. Switching now to a few questions about the negative test.
Just telling you what I'm going to.
It would be typical, in your experience, for
Transocean personnel to express their views on whether or not a
negative test was successful?
A. They would express their view to the well site leader, of
course.
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Q. And if they saw something wrong or anything that was out
of the ordinary with a negative test, you would expect them to
stop and determine what was wrong before proceeding to the next
step?
A. If they recognized that there was a problem, yes, I would
expect them to stop.
Q. As the senior toolpusher on board the Deepwater Horizon,
you would expect any of your drillers, assistant drillers, or
toolpushers to halt the procedure if they saw anything thatconcerned them at all with respect to the negative pressure
test?
A. That's correct, they would have.
Q. You were asked some questions earlier today about whether
or not you had heard of the terms "bladder effect" or "annular
compression." Do you recall that being asked of you?
A. Yes, sir, I do.
Q. And you said that you had not heard of the term bladder
effect; correct?
A. That's correct.
Q. You had heard of the term annular compression?
A. I think I have, but, I mean, it's not a common
terminology. It would usually come from, possibly, a BP
engineer or something like that.
Q. Let me just -- let me just ask a couple questions here.
You don't recall specifically who has used the term
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annular compression in your presence, as you sit here today, do
you?
A. No, sir, I don't remember who's ever even used that term.
Q. I just want to confirm with you, though, that prior to
April 20th, 2010, you had heard the term annular compression in
connection with the work that you did on the Deepwater Horizon?
A. It seemed like annular compression has come about at some
point. I don't know how or where it was associated -- but not
bladder effect.Q. I understood you to say that you had not heard of bladder
effect. I just want to confirm that you had heard the term
annular compression. True?
A. I think I have.
Q. Now, you talked a little bit about the test -- the
negative pressure test that was conducted at the Kodiak well
just prior to the Deepwater Horizon coming to --
THE COURT: We lost something here.
THE DEPUTY CLERK: I'm sorry, Judge.
THE COURT: We'll take about a 10-minute recess.
(WHEREUPON, the Court took a recess.)
THE DEPUTY CLERK: All rise.
THE COURT: All right. Please be seated. I had a
technical problem where my computer got turned off,
disconnected or something, but we're back in business now.
All right, Mr. Brock.
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MR. BROCK: May we proceed, Your Honor?
THE COURT: Yes.
BY MR. BROCK:
Q. Mr. Ezell, just before the break we had introduced the
Kodiak well as the next topic. Do you remember that?
A. Yes.
Q. So let me get you to turn -- let us pull up right here
Exhibit 34651.1. Can you see that this is a Daily Drilling
Report for Macondo 727 No. 2?A. Yes, sir, I can.
Q. Okay. And the Daily Drilling Report is signed here by Don
Vidrine, and by, it says, Miles Ezell. But you go by Randy;
correct?
A. That's correct.
Q. And that would be normal protocol for you and the well
site leader, to sign off on the daily drilling report?
A. Correct.
MR. BROCK: And if we come down a little bit to
33261.1 -- I'm sorry. This is the next exhibit. Go back to
the one before, please. 34652.1, which is a pull-out of the
daily drilling report. Okay.
BY MR. BROCK:
Q. And do you see here that the notes record that a pre-job
safety meeting was conducted with regard to the negative
pressure test and displacing the riser? Do you see that?
OFFICIAL TRANSCRIPT
14 9 P M
24 9 P M
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A. Yes, sir, I do.
Q. And that's similar to the process that you've described
for the court today in terms of what happened at Macondo, that
when you start an important task like this, you'll stop and
have a safety meeting and talk about what you're about to do?
A. Yes, sir, that's correct.
Q. Now, if you look at the next exhibit, which is
Exhibit 3326 -- can you read that okay? Probably better now.
A. Yeah, it's better now, for sure.Q. All right. You see that this is from the Deepwater
Horizon assistant driller to the Deepwater Horizon toolpusher,
and it's dated January 28th, 2010. Do you see that?
A. Yes, sir, I do.
Q. Okay. And it says: "The message is ready to be sent with
the following file or link attachments"; and then it says
"negative test while displacing." Do you see that?
A. Yes, sir.
Q. And you would have been a toolpusher on the Deepwater
Horizon during this period of time?
A. Yes, sir, the senior toolpusher.
Q. The senior toolpusher. Yes, sir.
Then if we go to the next exhibit, which is 3326.2.1,
do you see that that is the negative test while displacing?
A. Yes, sir. I see it.
Q. And that sets out ten steps there coming down the page.
OFFICIAL TRANSCRIPT
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Do you see that?
A. Yes, sir.
Q. And Step No. 8, if you look at Step No. 8, it says:
"Monitor for pressure buildup, 15 minutes." Do you see that?
A. I do.
Q. Is this a test of pressure for pressure on the drill pipe?
A. I'm not sure.
Q. Do you see where it says "displace down drill pipe with
seawater to the top of stack"?A. Yes, I do.
Q. And then it calls for monitoring pressure buildup for
15 minutes; correct?
A. That's what it says.
Q. Now, if we go now to 76521.2, do you see that this is the
Daily Drilling Report for January 29th, 2010?
A. Yes.
Q. And if we go now to 76522.1, do you see that it describes
the conduct of the negative test from 1200 hours to 12:30 there
on the left-hand side?
A. I do.
Q. And it describes "performing the negative test, closed the
upper annular, differential pressure, Halliburton bled off the
pressure, monitored for 15 minutes, good test"; correct?
A. I see that, yes.
Q. You're also familiar with a written negative pressure test
OFFICIAL TRANSCRIPT
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135 3 P M
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that was aboard the Deepwater Horizon; correct?
A. It's according to which one you're talking about.
Q. There was a written negative pressure test that was
developed by Jason Anderson and Murry Sepulvado?
A. I know the one you're referring to.
Q. And you would describe that as a one-page type document?
A. Yes, that's correct.
Q. And to your recollection, it was one form of a negative
test?A. Yes, that's a good statement, I believe.
Q. And it was formulated or prepared jointly by Jason
Anderson and Murry Sepulvado?
A. Yeah. I don't know exactly what role Jason played in
that, but he definitely was involved.
Q. Okay. Do you recall having told us that the only one you
could talk about was one that Murry and Jason had designed out?
A. I believe I did say that.
Q. Now, I want to show you an e-mail from toolpusher,
Deepwater Horizon rig, to George Coltrin, dated October 19th,
2005, please. Do you see this is a note from toolpusher,
Deepwater Horizon rig, to George Coltrin, dated October 15th,
2005?
A. Yes.
Q. This would be a note from the toolpusher on the rig to
George; correct?
OFFICIAL TRANSCRIPT
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A. I mean, it appears that way.
Q. And does it say, "Here is the procedure for performing the
negative. We would like to incorporate the negative test into
the displacement. From an operational standpoint, this
procedure makes the test much faster and easier to perform
versus performing it with base oil, where the base oil has to
be reversed out and then handled on the surface"? Do you see
that?
A. I do.Q. This is a suggestion from Transocean to BP about the
conduct of the negative test?
A. I'm not really sure exactly who with Transocean suggested
this, if any.
Q. Have you seen this before?
A. No, sir, I haven't. I don't recall it.
Q. That's fine, sir. Thank you.
On the evening of the 20th -- taking you to a
different topic, now. I apologize -- you were aware that
fluids had leaked past the annular in the BOP stack during the
first negative test; right?
A. The one that was aborted?
Q. I'm talking about the first negative test that was being
conducted at about the time you came into the room and there
was some discussion going on.
A. Yes. That was the one that was aborted.
OFFICIAL TRANSCRIPT
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