Page 197 - test2

BP’s failure to have full supervision and accountability over the activities
associated with the Deepwater Horizon was a contributing cause of the
Macondo blowout.

As part of BP’s operations integrity and risk management programs, BP
developed a systematic, risk‐based MOC to document, evaluate, approve and
communicate changes to facilities, systems, process, procedures, organization,
and personnel. The BP MOC process did not document certain critical changes,
including:

 During April 14‐19, 2010, several BP casing design changes occurred, yet
multiple MOC documents were never officially completed due to a
“clerical error.”
 These casing design changes for the Macondo well were submitted to
MMS for approval prior to the MOC being approved, according to
testimony by Sims on August 26, 2010.
 During a reorganization in 2010, the responsibility shift from the drilling
team leader (David Sims) to the drilling engineering team leader (Gregg
Walz) was not properly completed.
 A MOC was not completed for the operations drilling engineer (Bret
Cocales) in regard to his transfer to the BP drilling engineer team.
 Examples of BP’s failure to conduct a proper risk analysis include:
(1) No formal MOC risk analysis document was completed for the
well site leader transition from Sepulvado to Kaluza.
(2) Rig procedure changes, such as replacing the viscous spacer
with lost circulation material, were not subjected to a formal
risk analysis. 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
thyrotrophic (resistant to initiate flow) and viscous. This would
lead to a resistance to flow in the colder kill line (located outside
the riser), resulting in the suppression of pressure readings
using the kill line for the negative test.
(3) 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 float collar.

192