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Halliburton pumped a total of 51 bbls of cement for the production casing
                   cement job, consisting of 5.26 bbls of lead cement, 38.9 bbls (47.74 bbls when
                                                                              92
                   foamed) of foamed cement, and 6.93 bbls of tail cement.   BP did not plan to
                   pump cement above the top wiper plug in order to preserve the ability to run a
                   cement evaluation log (discussed below), if necessary.  Cement above the wiper
                   plug would have provided an additional barrier to hydrocarbon flow.

                                   2.    Pump Time and Rate


                          BP planned to pump the cement into the well at a relatively low rate of
                   four barrels a minute in order to reduce pressure on the formation that could
                   result in lost returns.  This strategy carried risks since a higher pumping rate
                   generally would have increased the likelihood that cement would displace mud
                   from the annulus and thereby would have increased the likelihood of a
                   successful cement job.

                          BP was aware that it was using a low pump rate, so it wanted to be able to
                   maximize the amount of time it could run the pump without the cement setting
                   up or fracturing the formation.  Brian Morel, BP Drilling Engineer, expressed this
                   in an email to John Guide, BP wells team leader, on April 17, which stated: “I
                   would prefer the extra pump time with the added risk of having issues with the
                   nitrogen.  What are your thoughts?  There isn‘t a compressive strength
                   development yet, so it’s hard to ensure we will get what we need until its [sic]
                   done.”
                          93

                                   3.    Nitrified Cement

                          Another way in which BP sought to reduce additional lost returns during
                   the cement job was by using a nitrified or “foamed” cement slurry in the annular
                   space (the “tail cement” for the shoe track was unfoamed cement).  Cement
                   specialists make nitrified or foamed cement by injecting cement with nitrogen
                   bubbles while the cement is being prepared on the rig.  Nitrified cement is less
                   dense than unfoamed cement and therefore exerts less pressure on the formation.
                   However, the use of foamed cement creates the risk of nitrogen breakout – if the
                   nitrogen bubbles in the cement “break out” of suspension – which can result in
                   inconsistent cement placement and densities.  The use of nitrified cement in




                   92  BP‐HZN‐CEC011406.
                   93  BP‐HZN‐MBI00255923.


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