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 During April 14‐19, 2010, BP made a number of casing design changes, but
corresponding MOC documents were never formally completed. Gregg
438
Walz agreed in his testimony that this was a “clerical error.”

 The casing design changes for the Macondo well were submitted to MMS
for approval prior to completion of the MOC process.
439

 The following operational changes were not subjected to the type of risk
analyses required by BP’s MOC policy:

(1) Rig procedure changes such as replacing the viscous spacer with
a lost circulation material. The 450 barrel lost circulation material
(M‐I SWACO Form‐A‐Set and Form‐A‐Squeeze) with polymer
viscosifier and weighting material added was highly thixotropic
(resistant to initiate flow) and viscous. This would lead to a
resistance to flow‐in in the colder kill line (located outside the
riser), which in turn would result in the suppression of pressure
readings using the kill line for the negative test.

(2) The decision not to run the cement bond log lacked a proper risk
evaluation because several factors were not considered such as
the relatively small volume of foam cement pumped, insufficient
centralization of the casing, and questionable conversion of the
440
float collar.

David Sims testified that, during 2010, BP was in the process of converting
from a paper MOC process to an electronic process. He called the process a
“gradual, painful process.” Whether the members of the Macondo team were
441
using the paper or electronic process, there is evidence that they were not
following BP’s carefully crafted policies on operational changes. The team’s
decision‐making proceeded with few or no checks and balances. On April 17,
just three days before the blowout, Guide stated in an email to Sims:

David, over the past four days there has [sic] been so many last minute
changes to the operation that the WSL’s [Well Site Leaders] have finally

438 Testimony of Gregg Walz, Joint Investigation Hearing, October 7, 2010, at 128.
439 Sims testimony, August 26, 2010 at 147.
440 BP did not appear to ignore the MOC process in all of its decisions. The panel found evidence
that the casing design changes for the Macondo well were subject to an MOC analysis.
441 Sims testimony at 165.

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