I I Case Document 19 Filed 02/11/15 Page10f5 . COURT mr?r?a? Sistine-r at mursm law FEB 112015 WILLIAM W. BLEVINS CLERK UNITED STATES DISTRICT COURT. EASTERN DISTRICT OF LOUISIANA UNITED STATES OF AMERICA CRIMINAL NO: 15-13 v. SECTION: RACE ADDINGTON FACTUAL BASIS The United States, represented by the United States Attomey?s Of?ce for the Eastern District of Louisiana, and the defendant, RACE ADDINGTON, hereby agree that this Factual Basis is a true and accurate statement of the Defendant?s criminal conduct, that it provides a suf?cient basis for the Defendant?s plea of guilty to the charge contained in the Bill of Information in the above-captioned matter, and had this matter proceeded to trial, the following facts would be established beyond a reasonable doubt through competent evidence and testimony: On or about November 27, 2012, the defendant, RACE ADDINGTON, was serving as a well Site supervisor for Energy Resources Technology (ERT) on an offshore oil and gas production facility located at Ship Shoal 225 which is erected on a federal mineral lease at 28 degrees north latitude and 91 degrees west longitude in the Gulf of Mexico, 74 miles from Port Fourchon in the territorial jurisdiction of the Eastern District of Louisiana. This federal mineral lease and all production activities conducted within it are administered by the Bureau of Safety and Environmental Case Document 19 Filed 02/11/15 Page 2 of 5 Enforcement of?ce located in New Orleans, Louisiana, within the jurisdiction of the Eastern District of Louisiana. On this date, production and well workover operations were being conducted on the facility and the blowout preventer system had to be tested. A blowout preventer system is designed to ensure well control and prevent potential release of oil and gas and possible loss of well control. According to the Code of Federal Regulations, the blowout preventer system must be pressure tested at regular intervals, and the entire system must pass the pressure tests prior to re?commencing with operations. According to the Code of Federal Regulations, the results of the pressure testing, including any problems or irregularities observed during the testing and the actions taken to remedy the problems, must be recorded. According to the Code of Federal Regulations, the blowout preventer pressure chart must be signed and dated by the onsite representative as correct. The blowout preventer pressure chart that recorded the November 27, 2012, testing of the blowout preventer system on the facility at Ship Shoal 225 only recorded 6 of the 7 required components as being tested and was not signed nor dated by any representative on the platform. At trial, testimony would be presented to show that on November 28, 2012, when he came on his shift, ADDINGTON saw the blowout preventer pressure chart from November 27, 2012, and believed it looked bad. ADDINGTON admits that he asked two contract workers to make a replica blowout preventer pressure chart that would look better and show that the 7 blowout preventer system components passed the pressure tests. The two contract workers sat at a chart recorder and working a small mobile pump manipulated the pressure and the chart in the recorder to create 7 ?tests? that showed smooth pressure lines that appeared to hold pressure for ?ve minutes as required by regulations governing blowout preventer testing. At trial, a video of the individuals performing this process would be offered into evidence. Photographs of the true ezc Case Document 19 Filed 02/11/15 Page 3 of 5 blowout preventer pressure chart actually produced from the testing done on November 27, 2012, and the replica blowout preventer pressure chart created on November 28, 2012, both unsigned and undated would be also be offered into evidence. On November 29, 2012, inspectors with BSEE made a routine inspection of the facility at Ship Shoal 225. As per routine inspection guidelines, the blowout preventer test records were requested. ADDINGTON presented the replica blowout preventer pressure chart made on November 28, 2012, to the inspectors as if it was the true blowout preventer pressure chart created by the testing done on November 27. ADDINGTON had labeled the replica blowout preventer pressure chart that he presented to the inspectors as ?Ship Shoals 225 BOP Test? BOP is the industry acronym for ?blowout preventer.? The replica blowout preventer pressure chart contained the signature of one of the contract workers who created it, the date of November 27, 2012, and it was labeled with the seven components of the blowout preventer that were required to be tested. Unbeknownst to ADDINGTON, the replica blowout preventer pressure chart that he presented to the inspectors did not show passing pressure tests. Following the inspection, ADDINGTON additionally emailed one of the inspectors the replica blowout preventer pressure chart. BSEE later received information that the blowout preventer testing may have been manipulated. Another team of inspectors was sent to gather the original records and ADDINGTON again gave the inspectors the replica blowout preventer pressure chart. Ultimately, ADDINGTON gave the inspectors the true blowout preventer pressure chart which had been dated incorrectly, and signed by the worker responsible for the actual testing that had been conducted on the blowout preventer on November 27. The true blowout preventer pressure chart showed that the blowout preventer had not passed the pressure testing. As a result of V3V Case Document 19 Filed 02/11/15 Page 4 of 5 concerns that the blowout preventer pressure test was intentionally fabricated, the United States Department of the Interior?s Investigations and Review Unit initiated an investigation. On December 6, 2012, ADDINGTON was interviewed by the IRU investigators and claimed that the replica blowout preventer pressure chart dated November 27, 2012 that was originally presented to BSEE inspectors was a ?function test? of the chart recorder. ADDINGTON claimed he believed that the true blowout preventer pressure chart produced from blowout preventer testing done on November 27, 2012, showed a passing blowout preventer pressure test, but just looked bad because of the wavy lines. ADDINGTON told IRU he wanted to see if the chart recorder was working properly so he had two individuals test it with a small pump. ADDINGTON further claimed that BSEE inspectors were responsible for getting the wrong chart as both the ?function test? chart and true blowout preventer pressure chart were in the same ?le given to BSEE inSpectors. ADDINGTON told IRU that BSEE inspectors should have known which test was the real test. At trial, BSEE inspectors would testify that the original test was a failing test and that ADDINGTON had presented them only with the fabricated or replica blowout preventer pressure chart during their November 29, 2012 inspection. I ADDINGTON admits that he ordered that a replica blowout preventer pressure chart be created so that it would appear that the blowout preventer components held the required pressures and was a passing test. ADDINGTON admits that he speci?cally told the individuals who created the replica blowout preventer pressure chart that he wanted the chart to be a replica of the true blowout preventer pressure chart and that he secured signatures and labeling in support of the Case Document 19 Filed 02/11/15 Page 5 of 5 of the replica blowout preventer pressure chart after it was created. READ AND AP ROVED: . Race Addington Defen Bea? Attorney for Defendant Emil .Greenf Id La. Bar. 28587 Assi tant Unite tates Attorney Mal/5 Date Date HIT Date I