THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF LOUISIANA

IN

RE OIL SPILL by the OIL DEEPWATER HORIZON in

IN

RIG
the

GULF OF MEXICO
on APRIL

MDL No
Section

2179

20

2010

Applies to

The Honorable

Judge

Barbier

ALL CASES and

210-cv-02771
_____________________________________________________________________________________

Mag Judge Shushan

REBUTTAL EXPERT REPORT OF DR FREDERICK GENE BECK ON WELL DESIGN CONTROL DRILLING AND MONITORING

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

TABLE OF CONTENTS
Executive

Summary
For

II

ResDonsibilitv

The

Well

As The
Held

Majority

Of

The

Parties Experts

Ultimate Contrary

And Exercised Responsibility For The Macondo Well Any BP Is Unsupported Suggestion By By The

Agree BP

Evidence

BP
well
all

held

and

preserved

ultimate

responsibility

for the

design

and

operation

of the

Macondo
to

BPs

ultimate

responsibility

extended

operations

conducted

by

Halliburton

and

Sperry
control

In

exercising

over

the

design

and

operation

of the

Macondo

well

BP

repeatedly 13

prioritized cost

and time over safety

Ill

Practice

Failures

BPs

Expert

Is

Wrong
In

To So
16

Suggest

That

BP Complied With
Regulations Written
Its

MMS
And

Regulations Doing

BP

Violated

Federal

Failed

to Follow

Own
30
the

Practices

BP
zone

violated

C.F.R

250.421 hydrocarbon
of

when

it

disregarded
with

M57B
to top

bearing 16

respect

cement

BP

violated

30 C.F.R
safe

250.427 margin

when

it

failed

to maintain

drilling

17

MMS
test

regulations

specifically

250.401
pressure the 19

required

BP
well

to

conduct

negative

as

it

prepared

to temporarily

abandon

Macondo
IV

The

Negative

Pressure Test

As Other
Results

Parties

Experts

Agree BP And Transocean

By
Disregarding Test

Caused
Of

The The To

Blowout
Negative

The

Pressure

And

Proceeding

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

Significantly

Underbalance
Integrity

The

Well

Without

First

Ensuring

Well

20 By Experts Of
For

The

Float

Collar With

As

Explained Sole

The

Other

Parties

The To The

Exception

BP And
Collar

Weatherford

BP

Failed

To Convert The The Shoe To

Blowout By

Float

To

Shut

Its

Valves

Track

Without

Damage
Contrary

Allowing

Occur
For

Any

Suggestion
Is

Experts

BP

And
23

Weatherford

Unsupported

By The Evidence

VI

Unnecessary Heightened

Risks
Alert
In

BP Should
Conducting
Prior

Have The

Been

On
Test

Negative

Pressure Test

Because

To That

Critical

BP Knowingly Designed Drilled And Operated The Macondo Well In An Unnecessarily Risky Manner
For Financial

Reasons
to

27
safe

BP

failed

provide

drilling

margin
that

instead

drilling

an

unstable

well

unnecessarily

necessitated

lower

density

cement such as foamed cement

27

BP
zone

incorrectly

suggests

that

it

was
have

free

to

ignore

the

uppermost
it

hydrocarbon-bearing not

because
from

may
royalty

been
This

producible
suggestion

standpoint

shows

disregard for safety Halliburtons

29

BP

unreasonably

disregarded
of at least
likely

recommendation
centralizers channeling

twenty-one
causing

thereby

30 chose
risk

BP

imprudently the

long

string

design 34

increasing

of

cement
flow

contamination

fracturing and

annular

BP

unreasonably up
or
to

chose

not

to

circulate

bottoms

adequately

condition increasing

the the

wellbore for
risk

cement placement

of channeling

and contamination

35

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

BP unreasonably
log

canceled

the

cement bond
37

previously scheduled

with Schlumberger

BP chose
plan VII

risky

temporary

abandonment
38

The Cement Job

As Other
Is

Parties

Experts

BP
Failure

Not

Halliburton

Responsible

For

Agree Any
42

Of The
Isolation

Primary

Cement Job

To Achieve

Zonal
VIII

Cement
Is

Remediation

The
Of

Only
Failed

Reasonably

Foreseeable Consequence

Cement Job
Did

Cement
Because

Repair
It

Job Which

BP

Not Allow Of
Its

For

Disregarded

The

Results

Negative

Pressure Test
Sperry
final

44
acted reasonably while

IX

Mudloaaina
monitoring the

displacement mudlogger

45
not the

The
crew

Sperry

was

in

same
drilling

position

as

BP and

the

Transocean

46
standpipe
test
is

The

pressure
at best

increase subtle

during

the

sheen

indicator

of well

flow notable Joe

to Keith

only

in

hindsight data available

50

properly

monitored not

all

him and

would

have

been

expected

to

stop the displacement

52
reasonably
that set

Joe
pit

Keith or

could pressure
kick

not have

flow have 54

alarms

would

indicated

Sperry
or

had no say

in

how

the

rig

was plumbed
be run supported
by

how

the displacement

was

to

55

BPs

expert

makes

claims

not

the surviving

mudlogging

data

56 58

Summary

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

LIST

OF FIGURES
shows
that

Figure

BPs OLGAs
was

simulation by the

most

of the

kick

volume

not detectible

mudlogger
interpreted incorrectly

Figure

Sperry

mudlogging data

by

BPs expert

Mr Grace

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

Executive

Summary
and
conclusions
in in

My

opinions

regard

to the

Macondo
parties

well

blowout have
in

are thoroughly

discussed

my October 17 2011
by the opinions support

Opening

Report
involved other

reviewed the expert reports submitted

matter experts

the other

this

and

ascertained
often

that

expressed

by

the

parties

my own opinions which have not changed disagree with certain experts who present opinions that run contrary to my own group comprised mostly of experts retained by BP
most agree
with

and

and

Weatherford addresses

and

find

their suggestions

unsubstantiated

This

rebuttal

report

the other parties expert reports and

summarizes

my key

findings With involved

ultimate
in

the
this

exception matter

of

certain
in

experts

retained
that

by held
In

BP
and

the

experts

are
for

agreement

BP
and and

exercised
that
in

responsibility

the

Macondo
first

well

exercising over

responsibility

BP

repeatedly

prioritized

cost policy

time

safety

disregard

of

BPs
dollar

express safety counts

more

consistent

with

BPs every
to

mantra
include

Risk-increasing
for

decisions decision

made
to

by

BP
final

save

time and

money
to

example
of

BPs

disregard

Halliburtons production
centralizers

recommendation
casing avoid
In

of placing at least

21 centralizers

on the use
to

the another
of

risk

channeling

and decided one

to

only

instead

example
at

BP
that

disregard

Halliburtons
circulation

recommendation
prior to

conducting

least

full

bottoms
gelling of

up

pumping
from the

the

cement
so as

so
to

debris the

and
risk

mud
were and

would

be

removed
and

well

reduce

cement

contamination

channeling proceeded
that

And
with

as

operations

on

the

well

concluding

BP

displacement
the
rig

procedure

simultaneous operations
ability

undermined

crews and
kick

mudloggers

to accurately
In prioritizing

monitor the well cost

for signs of

and

time

ahead

of

safety

as other experts

have

recognized
retained by

BP BP

violated

several
to

MMS

regulations
different

One

of

the

experts

attempts the

suggesting

that

cement

requirements
that

by for example MMS regulations did not require BP to meet top of for the uppermost hydrocarbon zone the M57B
paint picture

zone because
standpoint

zone

may
the

not

have

been

producible
significant

from safety

royalty risk

even

though
the
test

zone

presented
did

and

suggesting negative

that

MMS
do

regulations
its

not

require

BP

to

conduct procedure
test

pressure the

during not

temporary
the

abandonment

because

regulations

use

term negative

pressure

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

expressly even
tested to ensure
further

though
that
it

the
is

regulations
control

clearly at
all

require

that

the

well

be

under

times

The same BP
otherwise
the the

expert

suggests INC

that

despite
drilling

evidence margin

establishing simply
to

BP must
did

have
issue

maintained

safe incident

because

MMS

not
of

an

of

non-compliance
by

BP

during

course

drilling

These

suggestions parties

BPs

expert disregard safety concerns

The
conclusion
of

other
that

experts

appear caused
failed

to

uniformly explained

agree

with

my

BP and Transocean
pressure the
well test

recklessly

away
by

the

results

the

negative

and
the

the

blowout

significantly

underbalancing time
it

despite

negative

pressure

test
that

At the
it

conducted and
in

the

negative

pressure well

test

BP was
its

well-aware

had

designed
decisions
high-alert

drilled

high-risk

Given

multiple

risk-increasing

regard

to well

design

and operations
caution

BP

should

have
the

been

on

and
test

exercising Instead

extreme

when
at the

conducting other

negative

pressure
part

BPs

conduct

was

extreme
it

when

in

based

upon

explanations
that test

provided the
well

by

Transocean
In

recklessly

explained reckless forward

additional

away
with
its

indications of the

disregard

results

was leaking was motivated

of

my

opinion

BPs
move
and

by

its

desire to

temporary abandonment
additional

the
to

well

without
well

incurring

cost

or expending

time

ensure

integrity

control

BPs
negative

failure to correctly test led

acknowledge blowout

the

results

of the

safety

critical

pressure experts

to the that

Nevertheless
in

even

though
results

BP
of

and
the

its

acknowledge blowout

BP

did

fact

misinterpret

the

negative

pressure
for the

test certain
to

experts

retained

by

BP

attempt

to shift

some blame

Halliburtons
with to

cement

work

and

Sperrys

mudlogging operations

disagree attempt
different

BPs

experts on both fronts Halliburtons primary

The
work
offer

experts

who

criticize

cement
that

drastically
likely

opinions

none

of

which
In
in

establish

Halliburton

caused caused
the

the

primary

cement

job to

fail

my opinion BP
regard
to

not

Halliburton
of

any

problems

that

existed

the
for
light

performance

cement

downhole
centralize

BP and
the well

BP

alone

decided
relatively

example
weight forego
at least

to

inadequately

leave

drilling

mud

in

the rathole
circulation

adopt

long string production

casing
not wait

full

bottoms up
the

prior to of these

cementing
decisions
fail

and

24 hours on the
increased the
float likely

cement Each
risk

individually

and

together convert

that

the

cement
it

job would

BPs
risk

failure to

collar

without

damaging

added
with

to

that

making process

it

even

more

that there

would

be problems

the cementing

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

Furthermore as appear
to

number
the

of experts

including

one
of

of

BPs
failed

experts
primary
to the of

recognize
is

reasonably
repair

foreseeable

result

cement
extent
failed

jobnot Here however cement remediation such was needed BPs disregard any
job pressure
test

cement

blowout

the

negative

precluded
with
its

BP
riser

instead

moved
it

forward

any opportunity for cement repair unsafe temporary abandonment and have

procedure whereby
to

underbalanced

the well

opened up
designed
in

the

well

and

dangerous
plan

hydrocarbons
that

BP

could
left

temporary
state

abandonment
at
all in

would

have
in

instead

the well

balanced

times so as not to allow

its

dangerous
next well
to criticize with kick

hydrocarbonsbut

BP

failed to

so

haste to

move on who
for

to the

The
the Sperry

experts

attempt together

Sperrys work Transocean

led
in

improperly

group

mudlogger blame Transocean

with

the
that

drilling

crew

when
they
kick

assigning Sperry

missing

the

to

the

blowout
the

Although
well
for

and

each

played

role situations
final

monitoring

were

presented

vastly

different

and

opportunities

detection

and

response

during the

the

displacement

Whereas
of

the

Transocean
drilling

drilling

crew and
the Sperry

operations

BP company man were aware mudlogger was only aware of the

to

ongoing

information
limited

that

BP and Transocean
night of the

conveyed

him which

was

exceedingly

on the

Incident displacement

During

the

final

BP and Transocean
to

were

complacent

and
M-l

failed to

communicate key
decisions
pit

information
that

Sperry
to

BP

Transocean and
primary
kick

SWACO made
including

blinded

Sperry

several

indicators

volume

increase

gas

concentration

and

flow-out
flow-

data
out

Additionally data from

to

BP and Transocean
separate
If

had constant sensor

access
they

to critical did

Transocean

that

not

make
most
test

available assuredly signaled

Sperry

BP and
in

Transocean
in

had

recognized
after

what sheen

was

substantial

increase

flow-out flow-out

the the

by an increase

the Transocean contrast

unlike
final

data

blowout could
Sperry not

have no

been

prevented
opportunity the ensuing experts

In

BP and Transocean
kick

had have

clear

to

detect

the

and

thus

could

prevented

disaster also attempt

in

Several

to criticize

Sperry

for allegedly failing

to

execute

the

displacement as
Sperry

straightforward

misplaced conducted
final

had

no no

control role
in

over

manner This criticism is how the displacement was amending or approving the BP and Transocean were
M-l

Sperry

played

drafting both by

displacement
the

procedures

whereas
plan

familiar with

displacement

drafted

SWACO

and

approved

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

by

BP
in

BP and Transocean
complicate the
well

knew
at

the

approved

displacement
Sperry
well

procedure sensor
to

would
late

monitoring

by bypassing time

the the

flow-out
likely

displacement
available

when
in

was

be

underbalanced
the
well

Nevertheless
to

the

Sperry

mudlogger accurately
real

monitored

data

him which
well forth control
in

time

contained

no

clear

indications
In

of the

impending

situation

conclusion as set
that

my Opening

Report and
are

herein

it

is

my

opinion

BP and

to

lesser extent Transocean the

responsible

for the to shift

Macondo
blame support
II

well

blowout and and

consequences
is

thereof

Any

attempt

to

Halliburton

Sperry

improper

and

without

evidentiary

Well As The Majority Of The Parties Experts Agree BP Held And Exercised Ultimate Responsibility For The Macondo Well Any Contrary Suggestion By BP Is Unsupported By The Evidence
Responsibility

For The

BP

held

design

and preserved ultimate responsibility for the and operation of the Macondo well BPs ultimate extended
to
all

responsibility Halliburton Certain responsible experts

all

operations

conducted by

and Sperry
retained by

BP suggest
disagree
that

that

BP was

not
in

ultimately

for

well

operations
dictates

As

explained

Report

industry of
all

custom

the

well

operator

my Opening here BP takes

in

ownership course
well

procedures
drilling

devices

processes
It

and decisions used

the

of conducting

operations.1
all

is

the sole responsibility

of the

operator to ensure that

drilling

operations procedures

and

materials used regulations

litigation
it

during the course of

well

meet

or exceed
of parties

all

applicable
in

and

safety

standards
fact2

The

majority

involved

this

recognize

this

including

BP

itself

BPs written

practices

make

clear

Expert

Report

of

Dr

Frederick

Gene
at

Beck

on

Well

Design

Control

Drilling

and

Monitoring

hereinafter Rule

Beck Report

11 20-22

See e.g

20

2010

by the Basis

Opinion
Plaintiffs
M-I

26 Report on BPs Macondo Blowout Re Oil Spill Commencing April Transocean Horizon in the Gulf of Mexico Rig Deepwater Expert of Opinion and Discussion Pritchard Analysis prepared by David
Oil

8/26/2011

hereinafter

Pritchard

Report

at

27

Expert Report

Prepared
at

for 1of

LLC

by George
of

Expert Report

Medley Jr Gordon Cain

P.E

10/25/2011 10/17/2011

hereinafter
at

Medley Report
Drilling

MOEX

7-8 Expert

Report

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

that at
is all

BP

intends to control

all

aspects

of well

design
in

and

drilling

operations
that

times3 and

BP witnesses have

confirmed
all

their depositions

BP

responsible for directing

and conducting
is

well

operations.4
in

BPs
performed
Halliburton

ultimate

authority

particularly Halliburton

clear

regard

to

work
of

by

BPs
The
Unit

contractors

and
for

Sperry
of

division

April

16 2009
Well

Contract Services

Gulf

Mexico

Strategic

Performance Production

Offshore

Between Services
Halliburton

BP
Inc

Exploration hereinafter

and
the

Inc

and

Halliburton

Energy
that

HAL/BP
related

Agreement CONTRACTOR may

to

provides provide

and

Sperry and

as

BP
been
all

with

recommendations
to

opinions

the

work

they states

have
that

hired

perform

The

HAL/BP

Agreement
provided by

clearly

recommendations
shall

and/or by
inferred

predictions

Halliburton

and

Sperry

be received

as opinions
by from

only and

no warranty

expressed

or implied shall be

Roger Vernon

Anadarko

10/17/2011

at

see also The

Bureau

of

Ocean
at
Oil

Energy
Chief

and EnforcementReport Regarding the Causes Management Regulation JIT 20 2010 Macondo Well Blowout 9/14/2011 hereinafter Report Counsels
Offshore

of the April

Report
Drilling

National

Commission

on the BP
at

Deepwater

Horizon

Spill

and

2011

hereinafter

CCR

30 Transocean
hereinafter

Macondo

Well

Incident

Transocean
at

Investigation

Report June 2011

Transocean

Report

Vol

16-17 Beck Report

at

20

4See
Wellsite

e.g

Sepulvado

Depo
has the

5/11/2011
final

at

20713-17

testimony by
6/2/2011
at

BP

Senior

Leader

BP
is

testimony by former BP Vice

it

President
that

my

perspective

Lacy Depo and Completions Gulf of Mexico that the operator has the ultimate to responsibility

say

5197-52011

of Drilling

make
or

the

final

decision

and

it

is

not

uncommon
Guide

to

make
5/9/2011
is

decision counter
at

to

an advice testimony

disagreement

on the

day
that

Depo

15722-1 5916
for the well

by

BP

Wells

Team

Leader

MMS Depo
and

regulations

Waltz
that

BP as operator Depo 4/22/2011

ultimately

responsible

pursuant

to

at

7132-19

testimony by
for well

BP

Drilling

Engineer

Team

Leader
at

BP was
by

responsible

4/22/2011

57118-5727
testimony

same
BP
Vice
for

OBryan

Depo
of

7/15/2011
Drilling

Walz design at 4949-49921 and

Completions

60424-60515

President operations

regarding Breazeale
well
site

BPs

various 5/16/2011

responsibilities at

on

the

Macondo
Leader
is

well
the

Depo
leader
is

3746-9
all

testimony by
operations

BP

Wellsite

that

BP

responsible

for at

rig

insofar

as the by

well

concerned

Corser

Depo
that

2/10/2011

15120-1523

testimony

BP

Drilling-Engineering

Manager

BPs

John Guide was responsible

for operations

on the rig

10

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

such

recommendations..

The

contractual

provision

in

question

reads

as

follows
2.3 COIJTRACTOR may give COMPANY
the benelit of
its

pidgment
either

iasd
written

irpr1nQ
or

mforrnaton
niitenal

an
or

fliakin
of

jO4flifldtiQflS

amount

of

or type

oilfield

wvice
01 shall

to

be

provided

by

opcrnce to DATA or th CONTRACTOR

on
its

or

oral

manner of performance such recommendabons

only1

prediction predictions

ruults

riarwithstancling

the foregoing

II

andlor

received be

and

no

warratdy

expressed or
in

or impEed of the

shaD

COMPANY infwed by COMPANY

by of obtainoig
Iirst-hand

as opinions
front

such

icammnctioi
of

and

view

rripracticability reliance

knowledge

th

many

variable

con1itIQns are not

infaIIble

the

on

assumptions supporting

which
oiftield

ano
by others

inJreAc.s
of

the

necessity

reIyin

m.asurernent on facts

and and

service3 provided

Depo
industry

Ex 6320
custom

at

BP-HZN-MBI-00022200
of the

HAL/BP

Agreement
provides
of
all

29.3
what
drilling

The express language

operations

already

HAL/BP Agreement therefore dictates BP alone is in charge

Likewise the Minerals

into

Management
of

Service

MMS now
Energy
looks

reorganized

two agencies known Bureau

of

as the Bureau

Ocean The

Management and
to

the

Safety

and

Environmental
party for the
in is

Enforcement

the

well

operator as the responsible

to

well

MMS

regulations

relating clearly

the

drilling

of

wells

that

were and
it

place the well

to

on

directed at the well operator define the well Despite plan and
industry

20 operator who was

April

2010

are

required to
plan.6

seek permission

drill

as

specified

in

that

custom

BPs
for

written

practices

testimony

by

BPs
that

witnesses the

HAL/BP Agreement and

responsible
of
all

MMS

regulations

establishing

BP was Macondo
exercised

ultimately

procedures
that

undertaken
Halliburton

on
held

the

well

some
for

BPs
over

experts
certain

suggest
well

and
Fred

ultimate

control

operations

BPs
stable

expert

Sabins states
design

example
of

that

Halliburton
to

had

sole responsibility

for the

and

testing

the

foam cement

ensure

foam cement

Depo Ex 6320

at

BP-HZN-MBI-000222000

HAL/BP

Agreement

29.3

emphasis

added
See e.g 30 C.F.R
as having
control or

250.105

Operator means
of operations

the

person

the

lessees
or of the

designates thereof
or

management
lessee
the

on the leased
designated

area agent

portion

An
the

operator holder

may be
of

MMS-approved
rights et

lessees
oil

the

operating

under

an

MMS-approved
forth

operating
for

rights

assignment
drilling

30 C.F.R
in

250.400
Outer

seq

setting

requirements

and

gas

operations

the

Continental

Shelf

11

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

composition.7 responsible
failure of the for

Mr
cement

Sabins

further

suggests and

that

Halliburton

was

solely

execution
job.8

monitoring

reporting

on

the

success

or

disagree
direction including of

Halliburton

as
the

BPs
in

contractor regard
to

acted
all

solely

at

the

BP.9

BP

called

shots

drilling

operations any
than
of

cementing

operations

and
did

was
in

free

to

disregard

Halliburtons

recommendations
This conclusion
is

and
by
in

fact

do so on

more

one

occasion.1
States
of

consistent the

with

the conclusion expert

of the

United

America team

As

explained

USAs

Glen

Benge

BP
of the

wells

decision both

the final cementing They makers and were empowered to accept or reject the advice

was well-versed

were

BPs
of

internal the

cementing
well
to

expert
the

and

Halliburton
wells

Throughout demonstrated

drilling

Macondo
with lack

BP

team
and

considerable

control

respect
of

cementing
control

design

operations.11
of the
drilling

Halliburtons operations
is

ultimate

over

any

portion

consistent are not

with

industry to

custom
reservoir

dictating
liability

that

as
well

general operator
is in

rule contractors

exposed

The

here
best
in

BP

controls to to

the ownership

and development

of the well
its

and

the not

position position

mitigate

or eliminate risks

whereas

contractors risks

are

be

aware

ofmuch

less

evaluatethose

Thus

Evaluation

of

the

Cementing

on

the

7/8

Production 10/17/2011
at

Casing

String

on the

Macondo Well
at 10

Expert Report

by Fred

Sabins
Report

hereinafter

Sabins

Report

emphasis added see

Report
at

also

Sabins

30 47

Sabins

12 33 36 81

See
Leader

e.g

Sepulvado

Depo
sir

3/10/2011

at

2875-14
to

okay from
involved

And to flip Houston Im

talking
in

it

around

you dont proceed

testimony by BP Well Site pump cement until you do get the

that

Yes
about

And
well
site

understand leader

there

may

be

other parties
its

but

BP

needs approval
with

from

people

in

Houston
10

his people

Houston before he can proceed

several
of

cement

Yes

sir.

BP

did

in

fact

disregard

Halliburtons

recommendations
that at least

for the

Macondo
were

well

BP
to

ignored achieve

Halliburtons zonal
its

recommendation and
avoid

21
well

centralizers

needed warning
presented Expert

isolation

channeling

as

as

Halliburtons
well

based on

industry-recognized

SEVERE
Report

gas

flow

potential

that OptiCemTM software See Beck Report at 20-22

BPs

design

of Glen

Benge
in

on Behalf

of

the United

States

8/26/2011

hereinafter

Benge

Report emphasis

original

12

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

contractors stands
well
if

are

not

expected

to

assume

operator

risk
its

The

well

operator
in

to

make

millions

or
to

billions

above and beyond

contracts
to with

investment
in

the are

the

drilling

operation

proves successful
their written well

Contractors
the

contrast

compensated
regardless equation
is

pursuant

well

operator

of

whether

the

proves

be
the

profitable
right

The

risk/reward upside
for the

simple

the well

operator
it

holds

to the

potential

the

biggest

operator to contractors
financial

reward making assume liability for

do not share
for
in

possible

from

financial

standpoint

the

reservoir

the
in

biggest risk
it

Because

the

the

biggest
to

reward

makes

no sense

from
result

standpoint

contractor

share

the biggest risk

As
as

contractor perform

such as work

Halliburton

or Sperry customarily
of well

would such

not agree to

any
that

for or

on
the

behalf

operator

BP

if

by

making

agreement
indemnity
this

contractor
of the

reservoir consistent
In

The
with

clause

for the was assuming liability HAL/BP Agreement reflects and is

industry

custom.12
that Halliburton with ultimately controlled

sum
job

any

suggestion

the

cement
practices

cannot

be
by

reconciled

industry

custom

BPs

written

testimony
or the

BPs
BP

witnesses
freely

the

HAL/BP Agreement
Halliburtons held advice
or exercised

MMS

regulations than

fact

that

ignored
that

on more
ultimate

one

occasion any

Any
aspect

suggestion
of
drilling

Sperry

control

over
for the

and
well

completion

operations
controlled

would

be

flawed
all

operations

same reasons BP as the Macondo well on

exercising control

operator

and

directed

In

Macondo
safety

and operation of the well BP repeatedly prioritized cost and time over
over the design

My
Practice

Opening

Report and

discussed

BPs

Drilling

and

Well

Operations

DWOP

associated
written

Engineering

Technical
for designing

Practices

ETP5
standard

which
drilling

together

provide

framework
recognizes
that

and

conducting

operations.13
Drilling

BPs DWOP
and
to high

Good
drilled

Practices

dictates

many BP wells As

of the

industry

should

be
in

designed
compliance
expert

and completed
relevant laws

and consistent

standards

and

with
12

all

and

regulations.14

explained

by

BPs 19

Depo Ex 6320 Depo Ex Depo Ex

6121 6121

at

BP-HZN-MBI-00022184-88

HAL/BP

Agreement

13

at at

BP-HZN-BLY00034512 BP-HZN-BLY00034512

14

DWOP DWOP

1.2 1.2

13

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

Morris safety

Burch

BP

considers

the

DWOP

to

be

critical

to

conforming
of

to

management system and achieving BPs goals harm to people and no damage to the environment.15
Significantly

no accidents no

BP

states
well

in

DWOP
operations as

2.3

that

when

planning should

and be

undertaking
prioritized Installation

drilling

and
of

safety

concerns

in

order

importance and

Personnel

Environment

The

Reservoir
that

Integrity

Well

Delivery.16

BPs

written

practices
first

thus

state

safety

personnel

environment
should the

should

be

prioritized

and time

to production written

well delivery
including

be

prioritized last
first

BPs
well

practices
if

safety

directive

of

DWOP
and
for

2.3 are only

effective

followed
failed

This
to

was

not the case

with
its

on the

Macondo
Take

where

BP

repeatedly

comply

own

standards

repeatedly

prioritized time

and

money above
the confirmed

safety

concerns.17
log.18

example

BPs

decision
log

to cancel

planned cement bond

that

Although met

cement
planned
issues

bond

would

have

the

top
or

of

cement

targets

and

determined
requiring

whether

channeling

other

placement planned because

log.19

produced
log

result prior to
in

remediation

BP canceled
of the

the

cement bond
that
it

temporary abandonment
its

well

BP suggests
test

was

justified

decision

to to

cancel

the

planned

Halliburton

did

not not

indicate

need

conduct

cement
of

bond

disagree
for testing

BP
the

Halliburton
of the

integrity

was ultimately in control cement BP alone made

log
its in

and

responsible

the

risk-increasing

decision

not to conduct
in

cement bond
failed to follow

the interest of saving

first

time and

money and

doing

so

safety

policy deciding incident

in

BPs
conduct discussed conduct
time

failure to

make
in

safety

its

first

priority

in

whether Rather
pattern

to

cement
at length

bond

log

was

not

an

isolated

as
of

on

the

my Opening Report Macondo well whereby repeatedly

it

BP engaged
conduct

prioritized cost

and

ahead

of safety dollar

concerns

This

pattern

BPs every
15

counts

philosophy

and

was consistent with rendered the Macondo well

of Burch

Report
16

of Morris

Burch

BP

10/17/2011

hereinafter

Report

at

22

Depo Ex

6121
at

at

BP-HZN-BLY00034516

DWOP

2.3

17

Beck Report Beck Report

Sabins

23-31 87-88

18

at

19

Report

BP

at

78-80

14

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

high-risk

and

dangerous

well

that

was

described

by

BPs own

engineers

as

nightmare.2

BPs
cost
attributes

expert
at

Dr
the

Kathleen

Sutcliffe of

claims

that that

savings
of

expense
safety

safety

and

BP did not incentivize BP demonstrated the

strong

culture.21

Similarly

BPs
and

expert

Mr

Burch

opines

that

BPs
the

risk-management
during the

processes and and

herein

procedures
of

were

appropriately well.22 For

applied

planning

design

the

Macondo
pattern of

reasons There
risk

discussed
is in

throughout
in

my Opening money

Report conduct

disagree
that

no question

that

BP engaged
time and the

increased
parties

the interest of saving For

is

Other

share on

my opinion
drilling
rig

example

Chief
points

Counsels
to multiple well

Report observes
specific

that

time

money
at

and

decisions saving

by

BP that

increased

risk

the

Macondo
behavior

while

potentially

time.23

Dr Robert Bea and

similarly to the

Dr

William

Gale

experts
in

retained increased
cite

by the
risk

Plaintiffs
in

conclude

that

BPs
and

resulted

proportion

amount

of time

money saved and

Macondo well decisions that increased risk but saved time and money.24 And David Pritchard another expert retained by the Plaintiffs found that the final week of the well BP made ten 10
to

exemplary

key

choices and
to

which save
the

were

designed
in

to

save

rig

time costing

it

$1000000
taken
in

day

money
risk

additional

increased
that

of

blowout.25
risk

ways Thus
by

These

decisions

together concluding
of

am

far from

alone

BP

repeatedly

increased

prioritizing

time and

money ahead

safety concerns

20

See generally Beck Report

Expert Report
of Kathleen

at

31-101
Sutcliffe

Depo
Ph.D

Ex 126

at

C0N67
82

21

BP

at

22

Burch

Report
at

BP

at vi

see also Burch Report

41 to

BP

at

36-44

23

CCR

245-46

citing

Amendment 126763

Drilling

Contract

No 980249

BP-HZN-BLY 269181
and Guide

125444
Interview
24

BP-HZN-MBI Sims 19
on January

BP-HZN-MBI 2011

225981

BP-HZN-MBI

HAL_10648

interview

February

BP-HZN-CEC22433

2011
BPs
Deepwater Gale
Horizon

Rule

26

Report

Macondo

Blowout

Prepared

by

Dr

Robert

Bea and

Dr

William

Jr

8/26/2011

hereinafter

Bea-Gale Report

BP
25

at xx-xxi

Pritchard

Report

Plaintiffs

at

17-18

15

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

Ill

Practice

Failures

Complied With
Regulations Practices

BPs Expert Is Wrong To Suggest That BP MMS Regulations BP Violated Federal

In

And

Doing So

Failed

to Follow

Its

Own

Written

BPs
the

expert

Chuck Schoennagel
at least

maintains

MMS

regulatory

regime while operating the 30 C.F.R

BP Macondo
that

fully

complied

with

well.26

disagree

BPs
and

conduct

violated

250.421 30 C.F.R

250.427

30 C.F.R

250.401
violated

BP

30 C.F.R

250.421

when

it

disregarded

the

M57B hydrocarbon cement

Pursuant
operator
at least
is

bearing zone with respect to top of

to

the

MMS
the

regulation

at

30 so

C.F.R
that the

required to set production

feet

casing

250.421 the well casing is cemented

500

above

uppermost
that

hydrocarbon-bearing
misidentified well

zone
the

My

Opening

Report

explained

BP

the

uppermost
highest

hydrocarbon-bearing hydrocarbon-bearing

zone zone

in

the

Macondo

by

claiming

17803 feet even zone was actually much higher though the uppermost hydrocarbon-bearing at 17467 feet the M57B Because BP failed to account for the sand M57B zone BPs designed the top of cement to be at only 17300 feet well plan consequently was designed to place only 167 feet of cement over
located
at approximately
it

was

the

uppermost
27

hydrocarbon-bearing

zone

in

violation

of

30

C.F.R

250.421

BPs

expert

Chuck Schoennagel
because
the the

suggests zone

that

BP

did

not violate count

this

MMS
at this

regulation

M57B
notes

does

not

as
arrive

hydrocarbon-bearing zone under conclusion

define

MMS

regulatory

regime.28

To

Mr

Schoennagel

that the

MMS
and meets
forth

regulations

do not
that

expressly

hydrocarbon-bearing

zone
that set

reasons
the
in

hydrocarbon-bearing
for

zone must be
royalty

zone

requirements

producibility

from then

standpoint
that

30

C.F.R
not

250.115-116

He
of

concludes

because

the

M57B zone may

Regime

26

Expert

Report

Chuck

Schoennagel

hereinafter
27

Schoennagel
at

Report

BP

L.L.C at 19-28

MMS

Regulatory

10/17/2011

Beck Report Schoennagel

47-50

28

Report

BP

at

27

16

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

have zone

been
that

producible

in

the
in

royalty

context
with

it

must therefore 250.421

29

not

be

requires cementing expert

is

compliance Although

BPs
expressly the
well industry

wrong

the
it

MMS
is

regulations

do

not
in

define hydrocarbon-bearing
that

zone
seen
at

uniformly understood
feet of
is in

the gas-bearing

zone

17467
volume

the

Macondo
to
In

would

be capable

of delivering

significant

hydrocarbons
fact

the wellbore

i.e hydrocarbon-bearing
of to

No
has

definition

needed

am

not

aware

any

operator

that

or

would
that

define

hydrocarbonfrom

bearing
royalty
testified

zone
that

be

limited to only those

zones

are producible the

standpoint
if

Indeed
by

asked

BPs regulatory advisor on BPs drilling team in regard to

of

Macondo well sand level thats

they

gas

bearing

and
feet

capable above

flow

and

asking

you

whether

need

to

cement 500
satisfy

the

MMS
based

that she would have advised them that they had to More important BPs suggestion that an regulation.3
avoid

operator formation

can

selectively

cementing under
safety not

of

hydrocarbon 30

bearing

on

its

producibility
for well

C.F.R

250.115-116
regulation
in

shows
question

complete

disregard
is

The
royalty reflection

MMS
of

250.421
honor

directed suggestion
first

at safety
is

considerations

Mr

Schonnagels
failure to

contrary
its

another

BPs

continuing

safety

policy casing
at least

BP was
that

required

to set the

and 500

design
feet
in

the

top

of

cement so
uppermost
well

the

casing

was cemented
zone

above
the

the

hydrocarbon-bearing
violated

i.e

the

M57B
do

layer

Macondo

BP

250.421

when

it

failed to

so when
it

BP

violated
drilling

30 C.F.R

250.427

failed

to maintain

safe
Section
related drilling to

margin
of

250.427
drilling

the

MMS

regulations

sets

forth

requirements
that
in

safe

margins
the

Section safest

250.427b
drilling

requires

you

must

maintain

margin

identified

the

approved
this

APD
margin you
the

for Permit

to Drill
drilling

When you cannot

operations

maintain the

safe

must suspend
in

and

remedy

situation
drilling

As

explained
in

margin

safe my Opening Report BP failed to provide Macondo well BPs well design and drilling resulted

29

Schoennagel Douglas

Report

BP

at

27
at

30

Depo

10/11/2011

2672-15

17

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

in

little

or no
to

drilling

margin
its

in

the wellbore
drilling

and

measures
30 C.F.R

remedy

unsafe

margin.31

BP did As

not take
result

available
violated

BP

250.427b.32
United expert
to

The
issue
Its

States

Department Huffman safe

drilling

of

Justice
that

agrees

with

me
the

on

this

Dr Alan

opines

multiple
drilling

occasions

BP

failed

maintain

margin under
safe

while

Macondo

well.33

Dr Huffman

concludes

that

his

interpretation

of the

MMS
have

regulations

BPs

failure to maintain

drilling

margin

violated

not only

250.427b but also reviewed Dr Huffmans

His conclusions
little

250.401
opinions
with

250.427a
drilling

and

250.428a.34 agree
with

on the and

margin and

are

consistent

support

my

conclusions

him that BP
as

had

or no

remaining

drilling

margin

and

that

the

Macondo

well

drilled

by

BP was

dangerously
that
it

unstable
with the

BP suggests
safe
drilling

complied

MMS
of

regulations

relating

to

margins because
relating to safe

no
to

INCs

non-compliance

were

issued well.35

to

BP

drilling

margins during the course

maintain safe
drilling

of drilling the for the

disagree discussed
forth
in

BP
above

failed

margin as
well

reasons

and

in

my Opening
expert
well

Report and
the

as

the
of

reasons set

Dr Huffmans
the

report
is

non-issuance

an INC during the course

of drilling the

not proof to the contrary

BP
its

was

required

to

maintain
to
if

safest 0.5

drilling

margin
safe

identified

in

Application

for Permit
drilling

Drill

i.e

ppg absent
maintain
that

waiver36 during the margin suspend

course

of

and

it

could

not

operations

and

remedy

the situation

BP

repeatedly

violated

250.427b

31

Beck Report Beck Report

Expert

at

31-36 31-36
of

32

at

Report

Dr

Alan

Huffman

Submitted

on

Behalf

of
at

the

United

States

Department

of Justice

8/26/2011

hereinafter

Huffman Report

Huffman Report Schoennagel

36

USA at

Report
filed

BP
it

at

23-24

BPs APD was

absent gradient

that

on May 13 2009 would maintain waiver

while
drill

Depo Ex 4021
0.5

BP

represented
its

to the

MMS
and

ppg margin

between

mud

weight

fracture

drilling

the

Macondo
0.5

well

BP

sought
but
at
in

and received
no case did

three waivers

from the waiver

MMS

to

with

less

than

ppg margin

BP

request

to less

than

0.3

ppg

See Huffman Report

USA

16-21

18

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

when

it

failed to

do

so
250.401 required BP
to to

MMS

regulations specifically

conduct

negative pressure test as it prepared temporarily abandon the Macondo well

BPs
at

expert

Mr
1721

Schoennagel
through not

suggests

that

because

the

regulations Temporarily
test

30

C.F.R

30

C.F.R
that

1723 well
of
its
it

covering

Abandoned
conducted conduct procedure
expressly

Wells

do

require

negative

pressure

be
to

when
on

temporarily abandoning pressure

test

was

not

required

negative
April

as

part

temporary abandonment 1721-23

regulatory

20

2010
in

disagree
pressure test

Although
the

do

not

require

negative

MMS
wells the

regime
well at
all

does contain
operator
to

such

requirement

250.401
to

That section requires under

control well

take necessary precautions times and as discussed below in the necessary precautions
included

keep
of

case

Macondo
test successful

such

negative

pressure

As discussed
pressure
test

in

my Opening
the
it

Report
of the

because
well

negative
that

establishes

ability
is

to withstand test that

is

conditions
run
in

would

normally induce
prior to

flow

the

most

critical

by the well opinion

operator negative

removal
test

of the

blowout

preventer.38

Thus
this
in

my

pressure

was

necessary precaution
itself

for
its

keeping

Macondo well under control BP standards which demand that two

be
in

recognizes

own
fact
test

written barriers

independently
to the

pressure
seafloor.39

tested
In

place

along

any

potential

flow path
of
its

had

BP
all

properly

interpreted

the

results of the

negative well
it

pressure

during
that

temporary abandonment
of
its

Macondo
of the

would

have

known
test

expected

barriers
if

for

one

potential

flow paths negative claims

it

had

failed.4

On
to

the
its

other

hand

BP had
had

not conducted

the

pressure

during

temporary abandonment
it

procedure

as

it

was

not

required

do

would

have

no chance
by

of discovering

that failure

Accordingly
pressure
test

believe that

any suggestion

BPs

expert

that

negative

Schoennagel
38

Report
at

BP

at

25

Beck Report Beck

Report

92
91-92
citing

at

Depo

Ex 6121

at

BP-HZN-BLY00034588

Depo

Ex

184
40

at

2-3
at

Beck Report

93

19

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

during temporary
control
In
is

abandonment

was

not

necessary precaution

for well

disingenuous
in

sum
while
in

my

opinion the

regime above

operating

BP did not comply with Macondo well For the

the

MMS

regulatory

reasons
at least

discussed 30 C.F.R
in

and

my Opening
foregoing

Report

BPs

conduct

violated

250.421 30 C.F.R
violating
its

250.427 and 30 C.F.R

federal

250.401

Additionally
2.2 shall

the

regulations

BP

also failed to follow

well

of

DWOP

which

provides
in

that

drilling

and
all

operations

be and

planned

and

performed

compliance

with

applicable

legislation

regulations.41

IV

The Negative Pressure Test As Other Parties Experts Agree BP And Transocean Caused The Blowout By Disregarding The
Results Of The Negative
Significantly Integrity
All

Pressure Test

And Proceeding
First

To

Underbalance The Well Without

Ensuring Well

experts

addressing

the

results

of

the

negative
to

pressure the

test

appear
pressure

to

agree
test

that

BP and Transocean
success42 and
in

were wrong

deem

negative

BP

and

Transocean
expert

previously
that

acknowledged

this

their public

reports.43

No

suggests

BP

41

Depo Ex

6121

at

BP-HZN-BLY00034516
of

DWOP
Grace
should
not

2.2
10/17/2011 hereinafter

42

Expert Report

on Behalf
believe

BP

Robert Test

P.E

Grace

Report
Expert

at

17
of

the Negative
Barnhill

have

been declared 32

success
Control negative Expert
at

Report

Calvin

Macondo
Well

Engineering
Barnhill
integrity

Operations

and Well

Response
testing

9/23/2011
that

revealed
of

the

Transocean Macondo
test

hereinafter lacked

and

Report was

at

The

not

secure

Report 12 Report
test

David negative

Calvert

10/14/2011

pressure

Weatherford hereinafter should have been considered Azar Report

Expert Report
at at

Calvert

Report

of J.J

Azar

Ph.D

BP
by

hereinafter

failure Expert 46 the negative pressure

was

misinterpreted

everyone
Bourgoyne
hard to

of

Adam
Report
of

Bourgoyne
of

10/17/2011 negative

BP
pressure
barrier

hereinafter
test
is

Report

62 the

misinterpretation

the

extremely

McCormack
bottomhole should
not

10/14/2011

Weatherford
never

hereinafter

understand Expert McCormack

Gregory
at 21

Report

The
test

was

verified Medley Report successful

Investigation

M-I

at

23

negative

have been considered

Horizon Report

BPs
April

Deepwater

Accident
at

Report

hereinafter
Interview

Bly of

10 31 Transocean

30

citing

BP

Investigation

Team

Report at Don Vidrine

and
Stress
of Incident

27 2010

BP-HZN-MB100021406-19
Inc
Hydraulic

Data
of

Engineering

Services

Analysis

Logs April 1520 Macondo 252 Well

2010
Prior to

20

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

and

Transocean
the
test to

were
and

correct
that

in

concluding

that

the

Macondo
thus

well

had
in

passed

BP

and

Transocean

were

justified

proceeding

underbalance
offer

the well explanations

with largely

The
pressure negative the

experts
did

different

as
pipe

to

why
critical

the

kill

line

not

increase
test.44

along
is

the

drill

pressure

during
point well
is

the
that

pressure

This

irrelevant

The

pressure not been

significantly

increased

during the

test and test

thus
it

integrity

had

established
to

Given

the
to

results of the

was

reckless for
in

BP and Transocean my Opening

This the With
kill

proceed

underbalance

the

well

as explained

Report
is

conclusion pressure
to the

not affected not

by the varying explanations along the the

with lack
kill

as

to

why
to
this

line

did

increase
attribute
in

the

drill in

pipe the
kill

pressure
line

regard valve

experts

who

of flow
if

closed

or hydrostatic

pressure

line

they

are correct

just further

reflects that

the test failed and

should

not have

been

deemed
kill

success
test
line

because this would reflect further errors in the negative pressure test the by BP and Transocean as during the negative pressure valve was supposed to be open and was hydrostatic pressure
to

supposed
Similarly
kill

have

been
is

removed so

that

the well

could

be tested
that

for

leaks
the

irrelevant

BPs
being

expert William monitored

did

Graces
rise.45

suggestion

when

line
is

pressure

was
kill

the well

was

not underbalanced disagree

and
with

that

why

the

line

pressure

not

Not only do
that

April

20 2010
the

April with

27 2011

Post-incident

analysis shows prepared

the well
federal

was

likely

in

communication
reach

the formation.

The
at

reports

by

the

same

conclusion

JIT Report Report

the Future of Offshore Drilling

to the

93 Deep Water The President at 109

10/17/2011
material

Gulf

Oil

Disaster

government and

See

e.g

Expert Report
that

of

William
lost

Abel

Cameron
restricted
kill

hereinafter
line

Abel
Expert

Report
Report

at 13 opining of

heavy
at

circulation

flow

Donald
Weintritt

Weintritt

P.E
21

LA and

TX Retired

10/17/2011

Halliburton
to
site line

hereinafter

Report
the
kill

useincluding
costslikely valve
is

the Form-A-Set AK

the spacer that BP and MI-SWACO decided and Form-A-Squeeze to avoid hazardous waste

likely

plugged line Azar Report at 63 opining Bourgoyne Report

BP
that

at

47 opining
the reason
hydrostatic or

that
kill

closed

kill

BP

that that

line

failed to flow

unknown
line

Medley Report
Barnhill

M-I

at 20-21
at

opining

pressure
hydrostatic

prevented pressure

kill

flow
kill

Report

TO
17

28 opining

plugging

blocked

line

flow

See Grace Report

the time the
Kill

BP

at

In my

opinion

the well

was

not

underbalanced

during

Line

was monitored

21

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

Mr Grace
reflect that

but the

more
test

importantly

if

he were and

correct not

this

would been
well

also further

was
as

failure

should the

have
the

deemed was
for to

success
46

because

BP

designed

test could

be

underbalanced

during the test so that the well

be checked

leaks

Again the
did

critical

point

is

that the

results of the

negative

pressure

test

not

establish

well

integrity

and
to

thus

BP and
had

Transocean
well

absolutely
resulting

should

not
is

have

proceeded
proof test

underbalance
well
integrity

the not

The

blowout

conclusive pressure

that

been

established

by

the negative
46

Given

the

way BP
the with

designed

the
if

negative the well

pressure

test

BP

sought

to underbalance

the well

during

test

Thus

was

not

underbalanced
failed not to

during

the test the

test

suggestion
correctly to

which
test

and
extent

the

disagree should have been deemed

is

BP

and

Transocean
failure the well

perform

success
not state of

Furthermore
during the

the

Mr

Grace
test

trying

to

suggest

that

was

flowing

negative
flow
into

pressure the well

strongly

disagree
is

The

underbalanced pieces

of the well

and the
the high

during the test

reflected

by several

evidence
significant to

pressure
of

readings
that
drill

shown

on the

drill

pipe pressure
off

gauge
is

the

quantities

seawater
that

were repeatedly
pipe pressure
of

bled

to bring

the

pressure back equivalent

fact

the as

approximately from the expert on

psi

1400 psi

the zero and to what one would

the

expect noted

result

pressure
of

formation

when

underbalancing Report
at

well

as

by

another
drill

one

BPs

reports

Bourgoyne
pore increase

63

calculating
with effect

expected

pipe

pressure
that

based 1400

measured
pressure

pressure seen was

This
the
is

disagree U-tube

Mr
of

Graces
spacer
psi

suggestion
with
lost

the

circulation

material

LCM

below the 3600

BOP
of the
fill

improbable
spacer annulus
with

1400
lost

pressure

differential

would
height

require that

over

feet

16 ppg
feet

circulation

material

would more than

3300
of

between

the

drill

pipe and
that
if

the

casing

below the
of

BOP

am

unaware
in

concluded

this

amount

spacer

remained

the

any expert annulus below the

during the

who

has

BOP
it

Moreover
pressure

the

well

was
not

merely

hydrostatically

out of
drill

balance

negative as
did

test

would

expect

pressure

on

the

pipe to build

up gradually

between stopped
pressure reservoir

800 PM
response
If

and 832

PM

after the leak past the of

drill

BOP
was

annular

The gradual

build-up

pipe pressure
if

between

800
in

preventer had been PM and 832 PM is

with the

that

would

be expected
in

the well

communication
condition

the

well

was

merely

hydrostatically
if

imbalanced

the pressure

not instantaneous Regardless Mr Graces response would be much more sudden do not in BP and Transoceans the attempted explanations declaring any way justify to underbalance the well The success and proceeding negative pressure test pressure the well
justify

increases seen undeniably

After-the-fact

required that

they not
relied

proceed

with

underbalancing

hypotheses that were BP and Transoceans declaring the test

fact that

not

upon during the test do not success and thus underbalancing the
establishes
this

well

The

the blowout

occurred

indisputably

22

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

Lastly negative

while

BPs
test47

experts

acknowledge

that

BP

misinterpreted

the

some of BPs experts appear to suggest that the test was not the direct cause of the catastrophe negative pressure blowout was known or reasonably foreseeable risk strongly disagree of reckless disregard of the negative pressure test On the other hand that there would be reckless disregard of the negative test was not pressure
pressure reasonably foreseeable
direct to contractors of the loss
like

Halliburton control

and Sperry subsequent blowout

test

The which
test

cause

of well

and

was BP and Transoceans

is

reckless disregard
fully
in

of the

negative

pressure

discussed

more
to
is

Section

VI

below and
well

despite

the failed

their

proceeding

underbalance
important
to

the note

per

BPs
that
in

temporary

abandonment
have
well
in

plan

It

also safer

again

here plan

BP
be
well
of

could the
shut-

designed would
not be
to

much
left in

temporary abandonment
state

which

an underbalanced
risk

but instead would

balanced
in

avoid

the

of

hydrocarbons

coming

up

the

As
well
well

explained
including

the

my Opening Macondo

Report
well

temporary abandonment
not
require

does

leaving

the

underbalanced.48

As Explained By Experts For The Other Of BP And Weatherford BP Parties With The Sole Exception Failed To Convert The Float Collar To Shut Its Valves To The Shoe Track Without Damage Allowing The Blowout To Occur Any Contrary Suggestion By Experts For BP And Weatherford Unsupported By The Evidence
The
Float

Collar

Is

All

the

parties
float

whose
collar

experts

have

considered

BPs

attempted
the by the fact

conversion
float

of the

share
it.49

my
This

opinion that conclusion

BP
is

failed to convert

collar without

damaging

supported

Grace Report
48

BP
at

at

17 Azar

Report

BP

at

47

Bourgoyne Report

BP

at

62

Beck Report
Barnhill

90-91

Report

Transocean
Cementation

at at

13 18-19
19-20
Operation by

Macondo
of Ian

Engineering the

Operations 9-7/8

and

Well

Control

Response
Frigaard

09/23/11

Review

Macondo
10/17/11 Kevin

Production hereinafter

Casing

Frigaard
of

Cameron
10/17/2011

Report

at

16 29
at

Expert

Report

Trahan
at

Cameron
Report
at of

hereinafter

Trahan Report

17-19

Benge

Report Hughett

USA

26-28

Expert

John

Hughett

P.E

10/17/2011

hereinafter

Report

Halliburton

34

23

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

that

BPs
track

failed negative

pressure
that

test

showed
path This

the well
of the

was
is

leaking and

by the

the

prevailing

view

to

date
float

the

flow

blowout

was up

shoe

through

the

collar.5

conclusion

further
its

supported
conversion

by evidence showing
attempts.51

that

BP knew something blew

manufacturer

during

Only
the
float

BP and

the

float

collar

Weatherford

suggest

that

collar of

converted

or

may have
after

converted.52 the

disagree.53

The
of

absence
that

observed backflow
valves experts experts

pumping
without

cement does
as
not

not establish

the

float

converted

damage
path

even one shoe

of

some

Weatherfords Weatherfords
through the

acknowledge.54 can
reconcile

Moreover
flow

BPs

or

up the

track
float

and

float

collar with
in

non-damaged
Report served as and

properly converted the

float

collar
in

As Macondo
fluid

explained
well
if

my Opening
have

collar barrier

installed

the

would

temporary

and
the

held
float

back
collar

flow not

properly converted
to act

undamaged.55
barrier

Although
the

was
that

intended by

as

permanent
for both

post-blowout

testing

performed
if

Stress

Engineering

BP and Transocean
it

confirmed acted

properly

converted

and

undamaged

would

have

as

50

While

the prevailing by

view
kill

to

date

is

that
is

the

flow

path

recorded

BP

during

operations

inconclusive
flow
at

was up the shoe track data Depo Ex 3005 at BP-HZN

the

2179MDL01591521
through
flow

BP modeled
the casing

three different crossover

yet flow

paths two up
feet

casing

and one

breach
fit

in

near

12487

None

of these to

assumed
been
that

paths

the

observed

data

no

additional

modeling

appears
it

have

conducted

to

determine possible

an exact

path
long

Id
string

Nevertheless
in

thus appears through

BP
in

acknowledged
the casing
51

damage

to the

modeling

flow

breach

Depo Ex 2584
Expert Report

at of

BP-HZN-MBIOO1
Brent
Lirette

29068

Transocean
of

Report

at

52
10/17/2011
at

52

on Behalf

Weatherford Report Report

U.S L.P
of

hereinafter

Lirette

Report

at
at

48
3-4

57
13-17

Calvert Expert
at

Weatherford
Marion Report

McCormack
10/14/2011 worth

Report

Weatherford

Woolie

Weatherford
noting that not

hereinafter

Woolie Report
retained

12

Sabins

BP
merely

at

84
that

It

is

all

of the experts

by

BP and

Weatherford
Calvert at

insist

the
that

float

collar

must have

converted

Weatherfords expert
Calvert Report

David

says

conversion

may

have occurred
at

Weatherford
Report

10
at

Calvert

Report
at

Weatherford

10 see

also

McCormack

Weatherford

18

Beck Report

79

24

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

temporary
the

barrier

by

preventing

flow at the
in

differential

pressures the

seen

in

Macondo
test

well.56 for

Additionally

the

way BP
float

configured
collar

negative

pressure

the
in

Macondo
combination

well
with

the the

was

tested

as
in

temporary Opening

barrier

cement as

explained

my

Report.57

Also

as

discussed
published ignored

in

my Opening
and

Report

instead

of

following

Weatherfords
float

instructions

real time

guidance used
high

regarding brute

the

collar

BP

Weatherfords
the
float

advice

and

nine

force

attempts
likely

to try to convert

collar.58

These
have

pressure from the

attempts
auto-fill

damaged
The
with

the

float

collar parties

possibly

ejecting

the

ball

tube.59

majority

of

whose
point.60

experts

considered

this

issue

agree

my

conclusion

on

this

Certain the
ball

experts ejected

retained

by

Weatherford
fail

discount

the

possibility that possibility of

was
tube

But their opinions

to

account which

for the

obstructions
auto-fill

such
in

as

barite

or

other

debris

could

have
by

held

the

place

acknowledge
valves
to to help

the

As all of the auto-fill was used in

float collar.61

experts the

retained
collar

Weatherford
hold

float

to

open

its

reduce surge pressures but providing an opening jam

the

for debris to

enter

and

BPs
collar

high

pressure prevented

attempts
it

clear

such debris as
it

likely

damaged
if
it

the

float

and

from performing

would
float

have

had

been

properly

converted

and

undamaged
to

The
failure

auto-fill

collar

is

mechanical

device

and

thus

susceptible

and

damage On
the other

hand
in

the following

photograph

of

an
the

auto-fill float

float

collar

like

the

one

used

the

Macondo
at

well

shows
at

that

collars

two

56

Lirette

Report

Weatherford
at

42-44

Beck Report

79

Beck Report
58

93
67-72
the crew that psi
the
ball

Beck Report
Weatherford

at

advised

could

be ejected without conversion

with

at

pressure

of

around 1300

This advice
for

was

confirmed

the mechanical
at

testing

conducted
60

by Stress Engineering

Transocean

Beck Report

70 73-74 18 see
also Barnhill

Frigaard Report
61

Report

Cameron
at

at

29 Trahan

Report

Cameron

at

Transocean
Report

19
at

Lirette

Weatherford
at 9-11

19

Calvert

Report

Weatherford
at

at

McCormack

Report

Weatherford

Woolie

Report

Weatherford

12

25

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

check

valves

are

stout

piece

of

equipment
in

for holding

back

fluid

flow

if

they are properly closed

and

not

damaged

the conversion

process

Lirette

Report Weatherford
test

at

Fig

5B

It

is

not

surprising
float

that

the

backpressure
withstand
In

conducted

by

BP

established

that

the

collar

could

very

high pressures

5000 psi as my Opening

collar at the
it

designed.62

sum

as discussed
convert the

in

Report
safest

BP
time

first

failed to safely

and

properly the

float

and
to

next

failed

to

repair

damaged
pressure

float

collar

when

had the opportunity

by
its

do

so These
of

unreasonable
negative

actions

by

BP

followed

reckless

disregard

the

test led to the blowout.63

62 Lirette

Report

Weatherford
at

at

43

Beck Report

at

79

63

Beck Report

79

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

VI

BP Should Have Been On Heightened Alert In Conducting The Negative Pressure Test Because Prior To That Critical Test BP Knowingly Designed Drilled And Operated The Macondo Well In An Unnecessarily Risky Manner For Financial Reasons BP
failed

Unnecessary Risks

to provide

safe

drilling

margin instead
necessitated

drilling

an unstable well that unnecessarily density

lower

cement such as foamed cement

in

As discussed
were
well while
its

my Opening
are
attributable

Report and performance

problems
those

with

the downhole

below to the extent there of cement on the Macondo

problems
not

to decisions
it

made
if

by

BP.64

Further

am

cementing

expert
it

is

my

opinion that

BP had managed
for

drilling

margin more

effectively

could

have

avoided altogether the need

the need lower

to lower

the

cement
it

density

and

if

BP had

not created

cement

density
well

would design

not necessarily

have
for well

used foamed unreasonably below

the the

cement
narrow
drilling

BPs
margins
in

which

called

the open

hole section of the lowering the

bottom-most casing can be

shoe
design

necessitated

density

of

cement which
margins
in

accomplished caused

by nitrogen

foaming

The narrow

drilling

the well

densities created

BP to be concerned about the equivalent circulating when heavy mud was pumped out of the reamer shoe
Specifically

and

up the annulus
the

high the

pump
would

pressures

would

be required and

to place

cement and

mud
at the

into

annulus between
in

the formation high

the

long string production

casing

which

turn

apply

pressures

to the fragile formations

In

bottom

of the

hole

view

of the

narrow margins
the

in

the

Macondo

well

it

was BPs

risky

well

design

that

created density

need

for lower

equivalent

circulating

densities

and thus
to

lower the

cement

e.g

foamed cement
of the

The

nitrogen used lowering

foam

cement reduced
circulating
in

the

density

cement

thereby

the equivalent

density

As discussed BP would have been

drilling

my Opening
to repair level steel

Report

the

prudent

course

of action

by

the bottom of the well thereby before casing attempting

to

increasing the the

final

margin
Extra

to

safe

cement

pay

zones

cement and

would

have

isolated

and

reinforced

64

Beck Report

at

79-85

see also

VII

below

27

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

certain

zones and
of
liner

then

lighter

mud weights
been
to

that to

produced
to the

lower

equivalent

circulating

densities could

have

used

drill

The use
the allowed cement.65

as opposed
the

long

string

would

bottom pay zone have further reduced would have

equivalent the

circulating of

densities
well to

These

safer

alternatives with

bottom

be cemented

standard

unfoamed

The
alternative

Plaintiffs

expert

Mr

Pritchard

agrees
that

with

my

opinion
of

that

that

designs

were

available the

and

BPs

use

improperly

balanced

mud
When

weights
set
its

placed

cement

job at risk
1000
ft

BP

g-7/s

inch casing of

approximately
loss circulation

above

the

reservoir

BP then

pumped

copiou
its

amounts cement

material losses the

LCM

and

purposefully

compromised cement would

This

job to avoid
casing

additional

BP should
of the

have

chosen to
plug1

set

plug and have

allowed

run another
for

liner

above

top

new cement
balanced

which

BP to re-enter
days of
rig

the

reservoir with

proper

mud weight
another liner

would

have

required hole

timer cost

more money1
provided

and

required

further condition

reduced
to

size

but

also

would

have

safe

at-balance

welibore

conduct
Instead

logging

casing save

running the

and

non-compromised

cementing
risk

operations

BP chose to

time and

money and

took the

to

its

cement

job

Pritchard

Report

at 12

highlighting
alternatives
in

added
available well

Although
the

safer

were

BP chose
This
led circulating

not to
to
its

remedy
use
of

narrow

drilling

margins

the

Macondo

light

foamed cement

slurry to

reduce equivalent

densities and
at

potential

damage
of the well BP chose
the long

to

the

sensitive

hydrocarbon-bearing

formations

the

bottom

Again

the Plaintiffs expert agrees with

liner as
In

me
determined
that using BP $7liner

to use
string

long tring rather than Production create

loss

it

MOC
to

BP

9-5/8

casing

opposed

would save

$10 million yet could

nitrified
risk

of circulation

problem during
the

cementing1

requiring accept the

cement cement

to

reduce

density and

ECD

It

chose to save

morey and

to

its

job

65

Beck

Report

at

36-38

see also Design

at
still

e.g
and
16-17

Expert

Report

of

Sam

Lewis

Ph.D on Cement
Halliburton the
risk

Chemistry
hereinafter
fracturing

Formulation Lewis

Laboratory

Testing

10/17/2011

Report
while

BPs

use

of

foam cement
of long

reduce

of

the

formation

allowing

the use

string

production

casing

string

28

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

Pritchard

Report

at iv

highlighting here
is

added
not to

The obvious
drilling

question the

why BP chose
answer
in is

remedy the narrow

so would
liners

margins

in

well

The

that

doing

have would

required that multiple

liners

be set

the well This

and would

each
cost

of the

have

required

separate

cement job

BP

both

time and

well that moneyresources that BP was likely unwilling to part with for was already millions of dollars over-budget and behind significantly schedule.66 BP chose the riskiest path in the interest of Consequently

saving

time and

money
incorrectly

BP

suggests

that

it

was

free to ignore the

it

uppermost hydrocarbon-bearing zone because may not have been producible from This royalty standpoint
suggestion

shows

disregard for safety Report

is

As discussed
achieve proper zonal must ensure the because zone
in

in

my Opening

BPs

well

design proper

failed

to

isolationwhich

critical

because

well

design

isolation

and containment and

ignored the

of hydrocarbon-bearing

zones
Section
III

BP
the

misidentified well

uppermost zone
in

hydrocarbon-bearing
in

the M57B
that
royalty

zone.67
the

Now
M57B

as discussed

above BP
is

BP suggests
in

because
context
in is

may
the

not

have
the

been
zone.68
in

producible

the

BP was
Section directed

justified
III

ignoring

wrong As

also discussed

above

MMS

regulation

question

30 C.F.R

250.42

at safety

not producibility

from

royalty standpoint

Furthermore there are

reservoir

many

factors

that

control

the producibility

of

one
in

of

them

being

thickness
yet

producible
other

the royalty context properties

Some zones may not be deemed may be virtually identical in regard to

and hydrocarbon capable
over
of

significant

such

as

porosity

saturation
delivering

Thinner zones
significant

such
of

as

the

M57B

zone
to

can

be

volumes
for safety

hydrocarbon
to

well

bore

short

period of

time and

need

be cemented

and

isolated

just the

same as
BP-HZN

66

BP-HZN-MBI-OO1

25958
to

BP-HZN-MBIOO1

MB100192559 247
67

According

CCR

92549 BP-HZN-MBIOO1 BP was $58 million over budget at

92552
that

time

CCR

at

See Beck Report Schoennagel

at

47-51
at

68

Report

27

29

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

producible
of the

welibore from

the royalty standpoint again

of

By
in

ignoring

the existence
of saving
in

M57B zone BP once money

the
of the well
is

increased

risk

the

interest

time and hole

Identification

hydrocarbon
important option
of

bearing
for

formations safety

open

sections
with

critically

managing
the

but
of

BP
the

went

riskier

less

costly

ignoring

existence

M57B zone BP unreasonably

recommendation
thereby
After likely

disregarded

Halliburtons
centralizers

of at least twenty-one

causing
other

channeling
opinions
points

reviewing

the

expert

regarding
in

centralization
Vll.B of

have

determined

that

the
in

following

discussed

my

Opening

Report are not

dispute69
in

Inadequate

centralization
70

the

Macondo

well

increased

the

risk

of

Halliburton

recommended
Halliburtons flown

at least

twenty-one

centralizers
fifteen

to

BP
additional

Based on
centralizers

recommendation
to the
rig

overnight

BP had so that BP had

total

of twenty-

one

centralizers

available for

use
in

BP

placed

only six centralizers

the

well

69

See Beck Report

Barnhill

at 53-60

VII.B 23-25
against

70

Report

also

Depo

Transocean at 19-20 Frigaard Report Cameron at Beirute Ex 4842 at cementing expert Dr Robert cautioning
run just

see
not

running
Pritchard
71

centralizers

few

otherwise Report
at

it

would

result at

in

poor cement

job

Report

Plaintiffs

at

19 Trahan
71-72

Cameron

25
61327 HAL_10604
Plaintiffs

Sabins

Report

BP BP

at

CCR
Report

83

BP-HZN-BLY
at

HAL_10608

HAL_10713

Frigaard
at

Cameron

Pritchard

Report

19 Trahan Report
72

Cameron
at

25

Sabins

Report
of

71-72

CCR
at

at

83-84
Bly

BP-HZN-BLY
Report
at

61327
64

Tr

of

Telephone
as

Interview

Gagliano 6/11/2010
that

50-52

BP

The

investigation

team determined
result of the

the decision to ship 15 additional

centralizers

was made

OptiCemTM

modeling

on

April

15 2010.

30

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

BP
in

did

not consult
to
its

Halliburton

or Weatherford

its

centralizer
in

supplier

regard
did

decision to place

only six centralizers

to

the

well
model
in

BP

not

ask

Halliburton

generate

an

OptiCemTM

predicting

the risks associated

with

placing only six centralizers

the

well
Halliburton channeling placed only using
its

OptiCemTM
gas
in

software
potential

predicted
in

risk

of

and

SEVERE
centralizers

flow the

the

event

that of

BP
this

well

and

informed

BP

prediction

and
its its

BP
in

did

not follow
with

internal

management
regarding

of

change

MOC process
of the well.77 to

connection

decisions

centralization

Two

of

BPs

experts

nonetheless
attempt
to

seek

to justify

BPs

decision

use only and

six centralizers.78 incorrect

They

do so based

on three unsupported

claims

CCR
Coast
Marine

at

86

Bly

Report

at

63 BP-HZN-BLY
Service

61225
Marine Sinking

Tr

of

the of

Joint

United

States
into

Guard

Minerals

Management
Loss
of Life

Board

Investigation

the Unit

Casualty

Explosion

Fire Pollution
in

and

of Mobile

Offshore
April

Drilling

Deepwater Horizon With

the Gulf of Mexico 21-22

2010

hereinafter Report

USCG/MMS Cameron at
Beck
Report by

Investigation
Pritchard

7/22/10
at

Guide

Testimony
at

at

374

Frigaard

Report

19 Trahan
Fred Sabins

Report

25
to justify

at

56 BPs
to

expert

attempts

BPs

use

of

only

six

centralizers

citing

various

testimonies Report

by
at

BPs
72

contractors But

including
is

Halliburton
irrelevant

Dril-Quip

and

Weatherford
to

Sabins
six

such testimony
without

BPs

decision

use

only

centralizers of the

was
fifteen

unilateral additional

involving also

contractors

BPs

overnight

delivery

centralizers

any of its shows that

BP deemed

additional

centralizers

necessary

for the operation

Beck Report
76

at

56
Report
of
at

CCR

at

86

Bly

64 BP-HZN-MBI

128708-756
at

at

BP-HZN-MBI
Trahan
of the

128739
Report
at

Tr

of

Telephone

Interview

My
flow

Opening Report

Jesse Gagliano 06/11/10 explained that had BP disclosed

41 44-45
existence

25
to

the

M57B
note

zone

Halliburton
potential

Halliburtons OptiCemTM
for the
effort

simulation would
to
its

have

predicted potential
pertinent

CRITICAL
that

gas

well

as

opposed
or justify at

SEVERE
withholding

gas

flow

BP

has made no

to explain

of such

well

information

from Halliburton

Beck Report

57

Bly

Report

at

64 Depo Ex 6291

31

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

First of

BPs
fifteen

experts

Fred

Sabins and

J.J

Azar suggest decision

that

BPs
that
in

use
the the

six centralizers

was an

acceptable

engineering
by

and

additional well

centralizers

recommended
only

Halliburton

for

use

were

not necessary

or suitable.79

disagree

To

start
in

BPs
BP

so-called

engineering procurement
timely

decision
decision

to

use

six centralizers
in

was

reality

poor
failed to

As discussed
quantity

my Opening
Regarding

Report
well

procure
of

sufficient centralizers

of centralizers
rig.80

for the

leading to the
fifteen

shortage
additional

on

the

whether
fail

centralizers

were
if

necessary
that

BPs
the

experts

to

provide

any

explanation procured

as

to at

why
the the
is

was

not

case

BP went
at the

ahead and

them

last

minute

based

on

Halliburtons procured
that
in

advice
last

BPs
minute Report
in

experts were

claim that

fifteen

centralizers

BP

not suitable
that

similarly inexplicable
fifteen

given

BPs own
question

Bly

concludes

the

additional
well.81

centralizers

were

fact

the correct centralizers

for the

Second recommended
centralizers.82

BPs
that

expert

Mr

Sabins
with

suggests

that

Halliburton

BP

proceed

the
to

cement
place

job

using

only
in

six

disagree

The
before

decision

six centralizers

the

Macondo
this

well

was BPs and BPs alone

testified

BP engineer Gregg Walz made

Board
of Investigation

clear

when he

the

USCG/BOEM

78

BPs
not

expert Sabins

Mr

Sabins

references
at

Displace

3D
it

modeling

conducted
after the
is

after

the
it

blowout
could
to

Report

BP
BPs
was
this

73-74

Because

was conducted
centralizers

blowout
relevant

have informed
that

decision to use only reasonable

and thus

not to

whether
not

decision

when made
modeling

Mr

Sabins

appears

agree

as

he does

assert that

post-blowout
that

influenced

BP

pre-blowout consistent
with

Azar Report

BP
at

at

38 opining

BPs

use

of six centralizers

is

sound engineering
80

principles

see also Sabins

Report

BP

at

72

Beck Report
Bly

54-55

81

Report

at

64

82

Sabins

Report

BP

at

34 omitting OptiCemTM
flown

events

on

April

Gagliano

conducted
additional

multiple

simulations with
to

15 2010 where Halliburtons BP engineers which led BP to

have

fifteen

centralizers

the rig

32

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE
our
we
dx-

BECK

Sir
The You
we

we

had that

plans had

in

place

centralizers

available oftentimes

know
have
to

the

role of

hung
between ccmpany weiqh
riot

make

judgments from
one to

recommendations other
10 11 12 13 14 15

versus because for

risks
good
set

We
for of

have one

out

whats
another

may

be

better

criteria
that were
so

We judgment by usIng that

rrtade

assessment
incurring we

that risks the

we

other

those
to

when to

realigned Because

centralizers

get

Ti

of

USCG/MMS
Halliburton

Investigation

10/7/2010
in

AM

WaIz

Testimony
in

at

18720-18815
informed

Additionally
of
its

as discussed
to

my Opening

Report

BP never
the well
subject.83

decision

use only Jesse

six centralizers

and

ignored

an email from
learned
of

Halliburtons

Gagliano on the would

When Gagliano
frustrated

BPs
that

decision to use

just six centralizers

he

was
Walz
the

and he

concerned

the cement
that

job

require

remedial

work84
confirmed
risk

but
this

knew

that

was
job

decision.85

BPs
and due

Gregg accepted

when he
and
that

testified

BP was
be

fully

aware

that

remedial

cement

would

required
in

to

inadequate

centralization

BP had contingency
Dr Azar
asserts

plans

place.86 did

Third

BPs

expert

that

Jesse Gagliano

not warn
in

BP

of

inadequate Report

centralization.87

Again

disagree
Brett

As discussed
Cocales and

my

Opening
83

BP

Operations

Engineer

Drilling

Beck

Report
at

Testimony MBI 128489

84

56 2596-9
at

Tr

of

Walz

USCG/MMS Depo 4/21/11

Investigation
at

8/24/2010

Gagliano
at

18116-1827

CCR

106 BP-HZN

Telephone Telephone Tr
of

interview

of

Jesse Gagliano Jesse Gagliano

6/11/2010 6/11/2010

at

85

interview

of

at

41 95
at

86

USCG/MMS

Investigation

10/7/2010
to

AM
realign

Walz Testimony
to the six

18321-1847
had

18710-19

When

we went
in

to the direction
in

the contingency
87

plans

place

the

event

something went

wrong.

Azar Report

BP

at

37-38

33

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

Engineering 18 email

Team Leader Gregg Walz

Halliburtons

reviewed

and

considered

an

April report

from
of the

Gagliano
with

that

included

the

OptiCemTM
Halliburton

warning
ignored

risks associated

using

just six centralizers.88 their belief that

But both

the warnings
to

Rather
perform

based

on

would

have

an opportunity
they

remedial

cementing

if

the

primary

cement

job channeled

decided

that

BPs

poor

centralization

would

probably

be

fine.89 with

similarly disagree centralization isolation

risk

Dr Azars
to

suggestion

that of

the

inadequate
zonal creates

was
up and

irrelevant

the

blowout.90 causing

Lack

annular

through

inadequate

centralization

channeling
prevailing

of flow

that

the flow

down the annulus and under the was down the annulus and up the shoe
not conduct
sufficient

view
did

to date

track

likely

enable

the blowout

BP
timely

did

itself

as

prudent
to of

well

operator

when

it

failed to

procure

centralizers

properly
at least

centralize

the

casing

ignored

Halliburtons

recommendation

twenty-one

centralizers

and

installed

only six centralizers

BP imprudently chose long string design increasing the risk of cement contamination fracturing and annular flow Some
production casing might
of

BPs

experts

suggest

that

BPs

use
long

of string

long

string

casing

was appropriate.91 make sense for certain

in

disagree
wells
in

production
for the for the

the Gulf of
that

Mexico but
the

reasons discussed
88

my Opening

Report

was

not

case

Beck Report

at

56-57 were aware

of the potential

89

BP

engineers
of

channeling as
April

and and
at

gas

flow

potential

as the

result

inadequate

centralization

as

early

15

accordingly

ordered

additional

15 centralizers

See

Cocales

Depo

04/26/11

68815-19

and

85810-

14

Depo
to

Ex

1517

at

BP-HZN-2179MDL00033080
Testimony
six at

Tr

of

USCG/MMS

Investigation

10/7/2010
direction

AM
realign

Walz
to

18321-1847

18710-19

When

we went
plans
in

to the
in

the

had the contingency

place

the event
90

something went

wrong.

Azar Report

BP
Review

at

lack
91

of centralization

39 opining that any failure relating to eccentricity caused by would have resulted in flow up the annulus not the shoe track
of the

See
at

e.g 69

Production

Casing
at

Design

for the

Macondo Well
at

Expert Report

Report

by David

Lewis

10/17/2011

BP

Azar Report

BP

34-35

Sabins

BP

34

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

Macondo
liner

well.92

BP
on

selected
its

the

risky that

long

string

design

over
in

the

safer best

design

based

conclusion

doing

so would
again

result

the
of that

economic

case

for the

Macondo
not alone placed

well93
in

once

prioritizing

economics
long

ahead
string

of safety

am
of

my
the

conclusions

that at

BPs
risk

use

instead

liner

cement The

job

and

BPs

motivation

for doing

so

was money

Plaintiffs

expert

Mr

Pritchard

agrees

with

me on

both issues.94

BP unreasonably
adequately increasing the

chose

not to circulate

bottoms up or

to

condition the wellbore for

risk

cement placement
have adhered

of channeling

and contamination
should
to the

As discussed
widely recognized cementing.95

in

my Opening
practice of

Report
of

BP

good
majority

circulating

bottoms
also

The

the

experts

who have

prior to up addressed this

at least Calvin Barnhill Transocean agree with my conclusion including Dr Robert Bea and Dr William Gale Jr Plaintiffs Glen Benge Ian

USA

Frigaard

Cameron
prior to the

David

Pritchard

Plaintiffs
in

and
that

Kevin

Trahan

Cameron.96 BP appears
circulation

to stand

alone

suggesting

bottoms up

cement

job

was

not necessary.97
that

BPs
April

expert

Dr Azar suggests
days
prior to

BPs

bottoms job

up

circulation sufficient

on

16

2010
at

three

the

cement

was

92

Beck Report

39-46
at

Depo Ex 2659
Pritchard

BP-HZN-MB100143259
Plaintiffs at iv

Report

See Beck Report

96

VII.G

Barnhill

Report bottoms

Transocean
up volume up
at prior to

at for

20
the

The
well
job

volume

of

SBM..
Report

.did

not
xviii

total

up

to to

complete
circulate

Bea-Gale
is

at of

Refusing

full

bottoms

cement
pre-job

one

the failures

Benge

Report

USA
did not at

22

The

circulation

volume

on

the

BP on Macondo Macondo well was

at

very small and

circulation

approach
better

bottoms

up
the

Frigaard

Report
for

Cameron

More
Pritchard

would have
18

conditioned choice

drilling

mud

displacement
circulation at

Report

Plaintiffs that

BPs
volume

to forego

bottoms Report
to
it

up

increased

the
to

likelihood circulate

the cement

job would

fail Trahan

Cameron
prior to

20 Failure

cbottoms
the
risk

up
the

or anywhere

close

pumping

cement

increased Sabins

risk

of

contamination Azar Report

Report

BP

at

70-71

BP

at

35

35

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

disagree up

Dr Azars
is

suggestion

presumes
cuttings circulating of

that the

sole purpose of bottoms operations annular

First

circulation
in is

to

remove
for

from

drilling

But

as

explained

my Opening
prudent
in

Report

the

full

volume

prior to
likely

cementing accumulated and

of April gelled

number
over

reasons
three-day

gelled

mud

the

wellbore

the

period between

April

16

19 and mud
is

bottoms up
prior to

circulation

would

have

cleaned the wellbore

the
risk

cementing and as
lost

reducing

of

cement
up were
This

contamination
circulation

channeling

circulation

Second
here

bottoms

important

when
into

was

the

case

hydrocarbons

observed
fact

to

be seeping
that

the wellbore should

during logging operations.98

alone

dictated

the well

have
not

been

fully

circulated

prior to for

cementing.99

BPs

expert

Dr

Azar

did

address

these

purposes

bottoms up circulation and my opinion have performed bottoms up circulation

well prior to the

remains unchanged
to properly

that

BP

should the

clean

and

condition

cement job

BPs
decision
to

expert forego

Mr

Sabins suggests up reviewed

that

Halliburton prior to

was

involved

in

the

bottoms

circulation indicates

the

cement job
prior least to at

The
the
full

evidence

that

have

otherwise

namely
lower 18

cement job
be

Halliburtons

Nathaniel by

Chaisson
site

suggested

one

bottoms up but

was

told

BP

well

leader that
in

volume
log

would
the the

pumped
and

Also

Mr

Chaisson
listed

noted

his

April

job

that that
up.101

volumes

pump

rates

were

as
would
of

per

co

man

reflecting

company man BP had made

The
wellbore only acceptable
prior to that

the decision to not circulate

that

bottoms

event
is

preclude

full

circulation

of the

cementing

loss

circulation

BPs
during

experts the

do

not

suggest
circulation

there

was any
the should

lost

circulation

event

bottoms

prior to that

cement job
have

and

accordingly
to the

my

opinion

up remains

unchanged
98

BP

adhered

good

practice

of circulating

BP-HZN-2179MDL3541-45

at

BP-HZN-2179MDL3543

Depo

Ex

3188

at

BP-HZN

BLYOO61 515 Beck Report

100

at

77
Chaisson

CCR
to

at

91
this

Depo
at this

03/17/11
rate

at

70411-70514
by
at

definitely

were Tr
of

going

pump

volume

as

dictated

Bob

Kaluza

USCG/MMS
101

Investigation

8/24/2010

Chaisson Testimony Tr
of

4373-4388
8/24/2010

CCR

at

91

Chaisson Testimony

BP-HZN-CEC 21448 at 4373-4388

USCG/MMS

Investigation

36

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

bottoms up

prior to cementing.102

BP unreasonably
scheduled
with

canceled

the

cement bond

log previously

Schlumberger
Report
log

As discussed
cement
as bond
log accurately
to

in

my Opening
cement
of

BP

should

have

conducted

bond

would

have

permitted

BP

to

determine the top

general
quality of

cement and would have

zonal
isolation

yielded information by the

the

the
in

achieved
to

cement
accurate
of

placement assessment
conducting

This would
of the

have

turn

permitted

BP

make

more
flow

annular

cement as
log

potential

barrier to

Instead

cement bond
to

however
the

crew

who was prepared

The
majority

conduct
experts

BP sent test home

the

Schlumberger

testing

early.103

of the

who have
bond
log

also considered

whether

BP

should
including

have
at

conducted
least

cement
Barnhill Ian

agree

with

Calvin

Transocean
Frigaard

Dr

my conclusion Robert Bea and Dr

David
Pritchard to

William

Gale
and
in

Jr

Plaintiffs

Cameron

Plaintiffs

Kevin

Trahan
that

be alone

suggesting

BP appears Cameron.104 Significantly cement bond log was not necessary.105

in in

Additionally suggestion
that
it

as discussed

Section

II

above

disagree
log

with

BPs

was

justified

canceling

the

cement bond

because

102

Note

that

the

pre-cementing the

bottoms
for

up

circulation

discussed

here which

serves from
isolate

to the

condition circulation

and

prepare

wellbore

the

cement

job

is

distinguishable

of spacer

and other

fluids during

the cement
this
in

job which any

serves

to

the

cement
expert

from

possible
to

contaminants
Displace

Given

distinction to

reference
is

by
to

BPs
pre

Mr

Sabins

3D

modeling

regard

spacer

irrelevant

cement
103

bottoms

up
at

circulation

Beck Report
Barnhill

87-88

104

Report

top of bonding Report

of the

the cement

Transocean at was in the right

at
xviii

21

CBL would have down

Report
to the

been

able

to

see

if

the

general

area and the general area

log of
is

quality

of the

cement

from the top of the

Plaintiffs

cement
to run

the

float

collar Bea-Gale
knowing
these
failures
it

failure

cement

bond

one 29

of the
all

BP Macondo
cement

team

Frigaard
to evaluate

Cameron
job

at

For
with

reasons

would have

been advisable

the cement

further

some

form of logging
at
in all

e.g
Report

bond log before proceeding Pritchard Report Plaintiffs 10/17/11 at 29 CBL been at either point run Cameron Had would have been prevented.
Report

19 Trahan
likelihood

the blowout
105

Sabins

BP

at

78-80

Azar Report

BP

at

39-40

37

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE was

BECK

Halliburton

did

not

indicate

that

it

needed.106

As BP was
the

itself

correctly for

acknowledges
making bond
this

BP
in

specifically
fact

its

drilling

engineers
to

responsible

and

did

make
as
not
for

the

decision

cancel

planned cement had no

input
into

log.107

Halliburton

BPs
part

cementing
of

contractor

decision

and no

was

BPs

decision
other than

tree.108
its

As
to

have save
log
it

ascertained approximately
is

basis

BPs
of
rig

decision

desire

eight

hours

time by not running the test

the
in

cement bond
interest

apparent

that

BP decided
again
at the

not to conduct

the

of saving

time and

money

expense

of safety.109

BP chose As
similarly risky

risky

temporary abandonment
Report have

plan

explained

in

my Opening
plan for the

temporary abandonment concluded

that

BP failed to provide safe Macondo wellY Other experts have

and
should

BP

could

have
at least

designed and

less

temporary abandonment
Calvin
Barnhill

procedure

including

William Abel

Cameron111

Transocean2

Dr Robert Bea

Dr

106

Sabins

Report

BP
at

at

79-80 see
also that at Sepulvado Depo 3/10/11 even BPs own well site leader

107

Azar

Report

39
that

14617-14916
does
that not

testimony by
the discretion

BP
to

Well

Site

Leader
call

have

make

the cement

bond

log

unless

its

within

decision

tree
108

CCR

at

94

citing

BP-HZN-MBI 143304
it

and BP-HZN-CEC
experts

21665
mention
of

109

Additionally practices stating

is

find that

notable

that

BPs
log the

make no
run
in all

BPs
where

written top of

cement
feet of

bond

should

be

instances

cement
5.3.1

less

than

1000

above

shallowest
to follow

hydrocarbon these

zone i.e ETP

standards
internal
at

10-60
it

and

533109
explained
at

or

BPs
bond

failure

internal

when
standards

canceled

the planned
is

cement
in

log

BPs

failure to follow

these

and others
110

my

Opening Report

See

e.g Beck Report

20-31

Beck Report
Abel Report

12-13
opining
that

at 8-11

BP

failed

to

set

second
that

barrier

before removing decided

it

hydrostatic

control

during
to

temporary

abandonment

and

BP

apparently which

was more
drill

cost effective depth

of

use the
feet

DWH
the
that

to set

the wellhead

packoff

required
.Yet

pipe

8367

for

plug

and
is

abandonment
considered
to

procedure..

no

consideration
if

was

given

to the fact

8367

feet

be

poor

position

the well were to kick..

38

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

William Gale Plaintiffs113 and

David

Pritchard

Plaintiffs.114

The
last

safer alternative
in its

to

BPs
to

plan to set

the

lock

down
casing

sleeve

as the
to set

step
lock

temporary abandonment
sleeve
first

procedure would
against the the

have

been hanger
issue

the

down

guard
during

seal

assembly

becoming Most

unseated
experts

temporary
this

abandonment agree
plan to

procedure.115
including

who
to stand

have

considered

William Abel

Cameron116 and
alone

Calvin Barn hill

in

TransoceanY7
that

BPs
112

expert

Dr Azar appears

suggesting

BPs

Barnhill

Report

Transocean
un-necessarily
to set

at

22-26
the

42 stating

that at
risk

net

effect

BPs

decisions opining that

was
using

to

place

Macondo
in

Well

during

the

TA

and

BPs
and
under
If

plan

the cement standing temporary

it

plug

water pipe

coupled

with

the desire to set the

LDS

last

the

already

back

drill

morphed
procedure

the

TA

procedure
not

into

higher

risk

that

BPs
level

abandonment see also

simply

did

have

to at

be 25 an
fact

conducted
opining overview
that

the

of risk within to

was
BP
less

Barnhill

Report

Transocean
and
considered
with the

that

someone
barriers

had

stepped

back

of the entire flow

situation

include

the history
flow

of the well barriers

coupled
not

adequate

much
with

redundant
that

had

been
to
to

tested

nor out

confirmed

further

coupled

the fact

the
the

TA
well

operations

about
it

be carried

would deeper

potentially

significantly

underbalance other options

by displacing

significantly

depth

than

normal

could

have

been

explored

that

would

have

significantly
113

reduced

the risk.
at xi
its

Bea-Gale

Report

Plaintiffs for

xviii

xxiii

58 73

opining

that

BP
and

did that
is

not

have

risk

management
install

process

temporary

abandonment
temporary

procedure

to

additional failures of

physical

barriers

during

abandonment

one

of

the

knowing
114

BP on Macondo
Plaintiffs for at

Pritchard

Report
details

86

BPs

procedures
testing or

were

woefully

inadequate

negative
identified

pressure
risk

displacement

and

managing

those
115

known

and previously
at

of uncontrolled

blowout

Beck Report
Abel Report

91
at 8-1 to

116

Cameron
the
feet for the that

opining
set

that

BP

apparently which

decided
required..

it

was more
drill

cost effective depth

of

to use

DWH
8367

the wellhead

packoff

pipe

8367

plug and
feet
is

abandonment
considered
to

procedure..

no consideration
if

was

given

to the fact

be

poor position..

the

well

were

to kick..
117

Barnhill

Report

to

un-necessarily
to

Transocean at 22-26 42 The net place the Macondo Well at risk during
plug
drill in

effect

BPs
set

decisions
that
last

was

the

TA
to
into

and opining
the

BPs
using

plan

set

the cement

water

coupled

with

the

desire

LDS

the already standing

back

pipe morphed

the

TA

procedure

higher

risk

39

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

set the
that

lock

down

sleeve

BPs

decision could

operations

He instead suggests was not more risky.118 was made out of concern for the potential that the down sleeve.119 As stated in damage the LDS
last

my Opening
lifting

Report
during

however
the the

the

risk

associated
test

with far

the

casing

hanger any
risk

off-seat with

negative

pressure

outweighs
cost
to well

associated

damaging

lock-down
is

sleeve

as the
to

repair control

damaged
incident
In
120

lock-down

sleeve

marginal

compared

addition

to

setting

the

lock

down
state

sleeve

first

BP
to

also could

have

designed would have as

the well

much
been

safer temporary kept

in

abandonment

plan

under which

the well

balanced
placing

as

opposed would

underbalancing

BP did

while

second

upper cement plug have

both

Under
set

this first

much

safer by

alternative establishing tests

the

lock

down
setting

sleeve by

been

followed negative the

well

integrity

conducting

positive barrier

and

pressure

and then

cement
from
taking well

plug as
riser

prior to

removing

of the

balancing
further

drilling

mud
by the

the the

BP

then

could
prior

have
to

shown

appropriate

caution
filling

additional

step

setting

the

cement
float

plug

of

with

heavy

mud from
the
well

the

seafloor to the
fluid

collar

which would

then allow the removal of the the

drilling

from the been

riser

without
left in

underbalancing

welli.e

would

have

kept and expert

balanced

state.121

BPs
at

Dr Azar suggests
feet

that

BPs
did
is

plan not

to set the

cement
the

plug
of

about

3000

below

the This

mudline
suggestion

increase
to

risk

underbalancing

the well.122 by

contrary

my view and
the
feet

the

view expressed
the surface

most

of the

experts
to set the

who have
cement

considered plug

issue of

plug.123

BPs
40 43

plan

3000

below the

118

Azar Report Azar Report Beck Report Beck Report Azar Report
Abel Report

BP BP
at

at

119

at

120

91 88
at

121

at

122

BP

42
at

123

Cameron
Barnhill

8-1

opining

that at

8367

feet

is

considered

to

be
that

poor

position...

Report

Transocean

22-26
than

42

opining

BPs
the

abandonment
well

operations.. would

potentially

significantly

underbalance

by displacing

it

to

significantly

deeper depth

normal..

40

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

mudline exposed

with

displacement
well of to

all

the

way

down
degree chance

to

there
of

with

seawater
the

the

much
were

higher greater

underbalance
failing

consequences
inducing kick

which

of

barrier

and

also disagree
its

with

Dr Azars
plan

opinion124

that

BPs
well

failure to finalize April

temporary abandonment
of

for the

Macondo
In

until

20

the

day

the

blowout

was reasonable
because
time and

my

opinion
to

BPs
been
at the

last-minute motivated

changes
solely

were

unreasonable
desire to save
to

they

appear

have

by

BPs
In

money and made between

April

expense

of

safety.125 selectively

attempting

suggest
to
its

otherwise
plan

Dr Azar appears

to focus

on

BPs

revisions

15 2010
April 15 that

without

addressing

the

multiple

revisions

12 2010 and April made by BP between

and

the April 20 blowout.126

its

BP
in

revised

Moreover although Dr Azar suggests temporary abandonment plan between April 12 and April
information acquired
of

15

response and

to

by

BP
the

during

drilling

he

fails

to

provide
initial

any explanation
final

whatsoever have

how

differences

between
gained should should

BPs
from

plans
If

could

resulted results
all

from

new knowledge
operations operations

logging the well placed

anything the
alert

of logging

have have as

BP on

heightened
to

and
risk

subsequent

been

designed

reduce the
3.3.1.127

to

as

low

as reasonably
by

practical
clearly to

required by massively

DWOP
thick
if

The

well

logs obtained
with

BP

show
high given

high-porosity placed
in

reservoir

the

potential

deliver

volume

flow

an

underbalanced
to offer

condition
credible

Accordingly
justification for

BPs
before

and

Dr

Azars
to

failure
its

any

BPs
just

multiple

revisions

temporary abandonment

plan

in

the
of

days

the

blowout

and

ignoring that

requirements 20
to finalize
its

any suggestion plan should be rejected

management BP was reasonable in waiting

BPs

change
until

April

124

Azar Report
In

BP
to

at

40
several substantive plan
deficiencies that

125

addition

the

and
deficient

other This

experts
is

have

noted

BPs

temporary
list

abandonment

was

procedurally

evidenced

by the two

in page my Opening Report all of which were made by BP without following its internal management of change process Beck BP does not disagree that the management of change process was Report at 26-28 not followed for BPs various decisions in the temporary abandonment procedure

of last-minute

changes

set forth

126

Azar Report

BP

at

40

127

Depo

Ex 6121

at

BP-HZN-BLY00034519

DWOP

3.3.1

41

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

VII

The Cement
Halliburton

Job As
Is

Other

Parties Experts For

Agree BP

Not

Responsible

Any

Failure

Of The Primary

Cement Job To Achieve Zonal

The
pumping
concerning
isolation.128

Isolation Halliburtons
offer

experts

who
the the

have

criticized well

cement
to

design

and

work

on

Macondo
cement
this

drastically failed

different

opinions zonal theory

to the

how
In

job

supposedly
lack
of

provide

my

opinion

an

accepted

cohesive
opinion that

undermines

their respective

views and

supports
with

my own

extent that there were

of

problems associated
well

the downhole

performance caused
by

cement on
or

the

Macondo

any such

problems were
by

likely

one

more

of the following

decisions

made

BP
the well

BPs
of

decision

to inadequately single

centralize

and

its

decision

not

to perform

even

bottoms-up which

circulation

prior to the

pumping
in

the

cement

both

of

likely

caused

channeling

the

annulus BPs
the decision
to

use

long string the

light

production

casing

which

increased

risk

of contaminating to

cement
weight
drilling

BPs
risked

decision roping

leave

mud

in

the

rathole

which
the

where
in

the the

light

weight
track
to the

mud

migrates

up

through
in

heavier

cement
from

shoe

forming

channels
float

the

unset

cement

the reamer shoe

up

unconverted

collar

128

the nitrogen Report

See generally Sabins Report formed channels that

BP

at

24 cement was unstable and porous

act

because
Frigaard

could

as flow

paths

for

hydrocarbons
channeling

Cameron
and was
flow

at not

20-28
fully

cement
Calvert

was

contaminated

by

and

fluid

swapping
created

set
at

Report

channels

through

the shoe track

at 14-20 hydrocarbons Weatherford cement as the cement was setting and to pinpoint the

Trahan cement

Report
failure

Cameron
but failure

10

19-29

impossible
to

exact
rate

cause

of

was

likely

due

low cement

volume
of the

the low

at which

the cement
129

was pumped
at

contamination

and/or

movement

cement

as

it

set

Beck Report Beck Report Beck Report

53 77 39 82

130

at

131

at

42

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

BPs

decision

not to wait on before

cement

for at least additional with

the
rig

industry

accepted

twenty-four

hours

performing

as other parties

agree
to

risked
its

interfering

the

operations which cement setting

log

BPs
with

decision

cancel

planned have

cement
put

bond

which
of

as

recognized the

by other parties could

BP on

notice

problems

cement

job and
pressures
far
in

BPs

decision to apply

excess

of those

recommended
collar

by the manufacturer

when
the

attempting

to convert track to

the

float

which
float

may have
collar
All

caused

entire

shoe

separate

from

the

and put the cement job

decisions

at risk.134

of the foregoing of

at risk

resulted Hall

any one or more of which put the cement job BP alone Any consequences that failing were made by BP and from these decisions are thus due to BP and not attributable to

burton
Lastly
in

addition

to

BPs

decisions

listed
it

above
also the
in

BPs
float

failure

to

convert

the

float

equipment

without

damaging
to

could

have

caused

problems
without

with

the

cement
allowed

job.135

This failure to convert

equipment have

damage
is

u-tubing
for the

occur
track

which

turn

would

extended the time required

in

shoe

cement

to set.136

My

opinion

this

regard

shared by

Camerons

expert

Mr

Trahan.137

132

Beck

Report

at

85
test of

Pritchard only

Report hours

Plaintiffs after

at

33

BPs

decision

to

perform

the

positive

pressure the
risk

10

increased

compromising the cement

collar

pumping the cement job Trahan Report

from
setting

plug

recklessly at 14

Cameron
of

an

unconverted

float

can

prevent Report
at

cement

up because
Expert Report
at

ongoing
of

movement
Bolado
133

see

also

Lewis

Halliburton Hughett

45-47

David

10/17/2011

Halliburton

38-41

Report
at

Halliburton

35-39

Beck

Report

at

87

Pritchard

Report

Plaintiffs

33 Trahan

Report

Cameron

at

29
134

Beck Report Beck Report

at

83-85

135

at

62
Halliburton

136

Sam

Lewis
if

cement

expert

has concluded have been

that set

the cement
at at

Halliburton

left

undisturbed
of the well

likely

would
Lewis

the

time

pumped by BP and

Transocean
137

lost

control

Report

Halliburton

45

See Trahan Report

Cameron

at

14

43

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

VIII

Cement Remediation

The Only Reasonably Foreseeable Failed Cement Job Is Cement Repair Job Consequence Of Which BP Did Not Allow For Because The Results Disregarded
It

Of
If

Its

Negative

Pressure Test
interpreted that

BP had
would zones

correctly

the

results

of

the
of

negative the

pressure

test

it

have had

recognized not point

zonal

isolation that

hydrocarbon
steps

bearing

been
the

achieved

and

corrective

were

necessary would

At that

only reasonably zonal

for isolation

foreseeable through the

the failure to achieve job

complete
the

consequence of primary cement

have

been

need

cement

remediation

e.g

squeeze

job

whereby

additional

cement would be added

the

As
job would

recognized not have

by other experts138

need
site

for

such

cement

repair that

been

surprise

BPs

well

leaders were aware by

cement

remediation

management of
If

needed as demonstrated change documentation from April 14 2010

occur
during the

may have

been

BPs

losses

cement

job

rossible

cement
prior to

evaluation

includinci

remedial

cement
will

orerations

disrensations and/or
performing

MMS

arovals
to

be
than

required required

TA
the
in

operations

due

lower

Top

of

Cement
left

in

annulus

Possible

hydrocarbon

zones

could

be

exposed
single

the annulus with

for

only the casing

hanger seal as
decision
tree

the

barrier

the

TA
to

The
add

addresses
operation

these could

options

perf

attached

and

sgueeze
in

be

performed

second

barrier

the

annulus

138

See

Sabins issues

Report

BP
be

at

73
by

potential

channeling

that

causes
Calvert

long

term

isolation

can
13
failed

addressed

remedial
failure

cementing
of
in

Report
test
this

Weatherford
demonstrates
situation

at

In

my

opinion casing

the

the
the

negative

pressure

production

cement

job

Macondo Two

Well

In

industry actions

standards

require
to

and

prudent
well

operator

should possible

insist

that

remediation
actions

be undertaken

establish or set

integrity

remediation

were

to perform

squeeze job

bridge

plug emphasis added

CBL
the
likely

Trahan

Report

Cameron at
the

29

The
test

information

gained

by the

would have revealed

after the

issues that issues with could

would have caused

negative

BP

to take to test

remedial the

actions
of

Even

subsequent job BP
in all

used

integrity

Macondo cement
run
at

have made the decision

the blowout

to run

the

CBL Had

CBL been

either point

likelihood

would have been prevented

44

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

Depo Ex 2659
failed

at

BP-HZN-MB100143259
test
well

emphasis
have

added
the

Following

its

negative
to

pressure the

BP

should

displaced

mud back

into

the

well

return

to

balance

pressure
to

and

below the and

repair

fracture

i.e mud weight above the pore BP then could have proceeded gradient
The
the
well

evaluate

the

cement job
control

would

have
could

been have

kept

balanced prevented
pressure

and

hence

under

and

blowout
the

been

Instead test

BP

imprudently
to

disregarded

results of the

negative

proceeded

underbalance

the

well

and

the

blowout

occurred

IX

Mudlogging Sperry acted reasonably while monitoring the

displacement
After

final

reviewing
alters

the

reports

of that

the

other
April

parties

to

this

action by

see

nothing

that

my

opinion

on

20

2010

decisions

BP
non
any
set

Transocean and
standard

M-I

SWACO
during the
that

to

conduct

multiple

simultaneous and
frustrated

operations

final

Macondo displacement
Joe
Keith

reasonable
the kick
of

opportunity

Sperrys mudlogger Joe Keith

reports recognize

had

to identify

As many of

these

was

second

eyes monitoring the well and he had access to far less information than the BP company man and the Transocean crew because of drilling decisions made by BP Transocean and M-I SWACO
Other
drilling

experts

improperly

lump
Keith

Joe

Keith

in

with

the
of

Transocean ongoing
rig

crew

even and
April by

though
the the

Mr

was

kept
test

uninformed

operations

time

the

sheen

909 PM on

20
M-I

Sperry

flow-out

was complete soon after sensor was bypassed per BPs

instructions139 to

Transoceans crews Hitec

and

SWACOs
sensor

approved

while the

drilling

flow-out

remained

available

Transocean

and

BP

Mr
is

Keith

could
that

clear

It not per BPs instructions access the Hitec flow-out data BP and Transocean knew the limitations of the mudloggers

monitoring involved

capability yet they the

pits

designed gas
to

and

executed and Sperrys

pits

displacement
flow-out could

that

bypassing

sensor
with allow

sensor been
for

These same experts

configured
in

while agreeing

me
Joe

that the Keith pits to

have

closed system
to shift

monitor the
to

well

gains attempt Sperry were

the responsibility
authority

for the or

configuration for

Sperry
the
pits

however
configured

has no
or

over

responsibility

how

how

the

displacement

was

conducted

The

139

Depo

Ex 967 see

also

Depo Ex 607

45

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

responsibility

for those

decisions

falls

squarely on

BPs

Transoceans

and

M-l

SWACOs

shoulders
position

The Sperry mud logger was not in the same and the Transocean drilling crew

as

BP

common
reports
is

mischaracterization
position

throughout Sperry

the

other

parties
relative

expert
to the to
in

the comparative
drilling

of the
in

mudlogger

Transocean lump these

crew
into

BPs
Sperry

experts

particular

improperly

attempt
outlined

individuals

single

category.14

However as
the

my Opening
crew were
better

Report

the

mudlogger and
the
fully

and

Transocean

drilling

not on equal

footing

on the evening
well

of April
rig

20

Transocean
In

had

information

about both the

operations
of
rig

particular at
all

not only

was

the Transocean
after all

drilling

crew and

aware

operations

timestheywere
they could

directing

conducting

those

operationsbut
diverting Keith
in

also monitor the flow-out data

right

when

they

began

returns could direct the

of

overboard
not.141

as

it

appears the
control

well of

started

kicking also

while Joe puts

The

drill

crews
to

operations
of

them To

hands-on mudlogger
rig

position
sits
in

be

aware

ongoing
the

operations
floor

whereas
stay abreast
drilling

small

room away from

drill

operations the mudlogger must receive understand the

drilling

updates from the

called

crew
April

crew never once

site

Joe

Keith

on

20

2010.142
specialist

Nor
or of

did

the

BP

well

leader

the

M-l
to

SWACO
keep
the

compliance mudlogger had no

well

drilling

fluids

engineer
decisions

attempt
In

informed
ability

any

ongoing
to

operations

addition regarding
or

the
rig

mudlogger

or

authority

make

configuration
activate

control
this

actions
is

displacement
reserved are
all

procedure

whether

to

the

BOP

authority

for the

BP company man and

to

the
in

Transocean
well

drilling

crew

who

required by regulation

be

certified

control

140

See e.g Bourgoyne

and Azar Report

Report
at

20
141

BP
by

BP

at

10 and

64-66

Grace Report

BP

at

and

18-

11 44-45
experts that
of at

and

50
Keith

Any
is

implication belied

BPs

Joe

had access

to

Transoceans
Bly

flow-out at

data

by

the findings 1/27/2011

BPs own

investigative

team

Report

42
E-mail

Robinson
relating to

Depo

34825-34923
concluding

see

also

TRN-INV-01824082
sensor

Transoceans overboard

investigation but

the

Sperry

was

bypassed

when
142

diverting

the Transocean
Keith

paddle

sensor

was

not
at

Tr

of

USCG/MMS

Investigation

testimony 12/7/2010

19311-15

46

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

As

described
drilling

in

Appendix
shut

to

my Opening pumps
Sperry
to

Report conduct

at

908 PM
sheen Joe

the test

Transocean

crew

down
later

the the

the

Approximately conducted and Flow

then

one

minute and

mudlogger
Sperry yet

Keith

flow check

visually

observed flow from the

the
well surviving

well

decrease
data.143 or

stop

This

is

confirmed

by

flow-out

either

stopped

because

the

was
returns

not

underbalanced
before

because sheen

Transocean
test

improperly
If

diverted
well

returns

overboard
diverted
this well

the

was
only

conducted
the
drilling

were

overboard
the Sperry

prematurely mudlogger
having
just

crew have

would

have

known
the gold

would passed

reasonably

concluded
flow

that

was secure
in

successful
after

checkthe
had
confirmed

standard

kick

detection

Accordingly he had

Joe
to

Keith

the well data

was

static at

909

PM

no reason

believe any
kick or at

mudlogging need

collected

and

observed up

to that

time indicated

for well

control the

When
returns were
lost

the

displacement overboard spacer spacer

flow-out

resumed
at the

914
line

PM

after

sheen

test

routed

bypass

to dispose

of the

weighted

circulation to

material
this

When
sensor

BP
it

Transocean
did

and

M-l
that

SWACO
it

decided bypass

dump

overboard

so knowing

would
pit

both

Sperrys

and

the

Deepwater

Horizons

system
kick

effectively

blinding

the Sperry

mudlogger from and

the

his primary well

flow

indicatorspit gain increased While

the Sperry flow-out

flow-out

high gas content.144

pits

sensor

and

were

bypassed sensor

and

unavailable
still

to monitor well

flow the Transocean

of flow out of the

Hitec flow-out

was
have

able

to

monitor the

rate to

well.145

Although the Sperry

Sperry
did

mudlogger

had

access

some Transocean

data

not

143

Exhibit

604
that

144

understand

Transocean
that

and

flow-out

moved

See e.g Depo at 5428-5438 Gisclair Depo Depo 4/15/2011 Clark Depo 7/29/2011 at 2094-2106
Keith
145

sensor and at any time

Transocean

BP had and BP

to

could

approve the location have requested

at
at

for the

Sperry

the

sensor

be

3/28/2011 3/14/2011

1755-17615 10320-10515

Gray and

See

e.g
at

Sepulvado

Depo

5/11/2011

at

3/10/2011
flow-out

26311-26424
should

Tiano accurately

Depo
65

8/25/2011

37515-3768 Sepulvado Depo at 2632-2644 Transocean

measurements overboard
the

sensor

have
Report

transmitted flow

on

April

20

2010
flow-out that

and

Bourgoyne

BP

at

When
was

pumping
passing

Sperry-Sun
flow

meter
part

was bypassed
of the rig sensor

However

flow

through

second

meter

was

package

47

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

access

to the

Transocean
drilling

flow-out data

even did

though the

BP company man

and the Transocean

crew

certainly

As
the

described

in

my Opening
to
if

Report

BP

told

Sperrys mudloggers

on

Deepwater sensor.146 The

were diverted
monitoring test

Horizon vast by

use the Sperry

not
all

flow-out sensor
kick

and not the Hitec

after well

majority

of the

occurred

returns

BP and Transocean As
the could
rate147

out of the
well

mudloggers
increased

flow and

gas

capability

flow from the

after the

sheen

BP and Transocean
in

have which

and
is

should
classic

have
kick

seen
indicator

significant

increase
that

the

flow-out

The

fact

the

Transocean

drilling

crewand
is in

the

BP Company
reflection

Mandid
on the job
drilling

not
that

appear to catch this kick Joe Keith did that night

primary
responsibility

indicator

no

way
the

especially

given the

Transocean

crews

for monitoring that

well.148

As

far

as Joe and

Keith

was
he

concerned he had

confirmed

the well

was

not flowing

nothing

saw

after that point

find
it

would
that

have

reasonably experts
cite

lead him to conclude otherwise

to results

telling

BPs
do

from the

the

OLGA

and

Transocean mudlogging Report

that

simulations

for well

flow149

rather

than

surviving
in

Sperry

data

They
no
clear

so

because

as

described
in

my Opening
Sperry data

there are
Keith

indications

of well

flow

the actual

Joe

was

monitoring

The
volume

OLGA model
actually

however
by

does Joe
18

not Keith
of

accurately

illustrate
in

what
figure

was

detectable

As shown
Emilsen

the

below which
146

was

modified from Figure

the

BPs
and

Report5
Keith

only

See
for it

e.g Appendix
at

to

Beck
get

Report
their

at

see also

Depo
you

3/28/2011

1807-22

We

dont
but

ask
147

We

did

at

one time

--we dont get their flowout didnt want us to use it.. they
5/11/2011 Tiano
at

Could

See

e.g
at

Sepulvado

Depo
and

3/10/2011
148

26311-26424
at 102-1

Depo

8/25/2011

37515-3768 Sepulvado at 2632-2644

Depo

See Beck Report

07

149

See

e.g

Grace

Report
at

BP
67
best

at

and

18 Azar
pits

Report Sperry

BP
600
in

at

and

50

and were
is

Bourgoyne

Report
the

BP
kick

because
10
the
pit

the

and

flow-out

sensor
pit

bypassed when
misleading

occurred
at

Dr Bourgoynes
barrel
pit pit

reference to gain recorded

barrel
pits

gain

as there

was

the

prior to

the

sheen

test

This would

have

been
as

only

gain

The

rest of

mud was

diverted

overboard
150

and thus undetectable and Conclusions

gain.
Horizon Incident
at

Summary

Deepwater

prepared

by

Morton

Emilsen 10/17/2011

BP hereinafter

Emilsen

Report

48

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

small percentage
rig

of

BPs
By

simulated

pit

gain would

have
out
of

even
the

reached

the

before

flow-out

was

diverted basing
that

overboard
their

and

mudloggers
data

monitoring experts
after
fail

capability
to

arguments
could

on

simulated

BPs
gain
were

acknowledge

Joe

Keith

not see any

of this
pits

910

PM

when

the
drill

Sperry

flow-out

sensor

and

the
in

bypassed
to actually

Only the

TO

crew and
majority

BP company man were

of

position

observe the

vast

flow out

of the

well

since the
rig

only
prior to

negligible

amount

of the

simulated

flow ostensibly

reached

diversion overboard

Figure the kick

BPs OLGA
volume was
simulation

simulation

shows

that

most

of

not detectible

by the mudlogger

BPs OLGA
predicted fixed
is

also

likely

overestimates

even

the

small

gain prior to 910 PM By BPs own admission OLGA assumed net pay from the reservoir even though BP acknowledged that
that
initially

possible

only the

small

channels
If

in

the

cement
used
flow
If

were
this

open
latter

between

reservoir

and

wellbore.5 concedes
in

OLGA
initial

assumption
significantly

however
less

BP
that

that figure

the

would
then

be even

than

shown

the

above.152

so

151

Emilsen Emilsen

Report Report

at at

14 see 14 see

also also

Bly Bly

Report Appendix Report Appendix

page page

vii

152

vii

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

this

corrected

gain would have

in

been

virtually

undetectable

by the

Sperry

mudlogger and
data
that

line

with

my

analysis 10 bbls

based
entered

upon
the

the
well

real time pit

volume sheen

indicates

at

most

before

the

test.153

The

simple truth

is

there were

no

clear

indicators

of

kick
lost

in

the data

available to the Sperry

material

mudlogger

before

BP

discharged

the

circulation

spacer

overboard

Such
did

indications

were

likely

present

in

Transoceans
Horizon and

Hitec but

data monitored
that

by the Transocean not survive the

drilling

crew and

BP

company man

data

sinking

of the

Deepwater

had not been

made

available to Joe Keith

The standpipe pressure increase during the sheen

at

test
in

is

best

subtle

indicator

of well

flow notable only

hindsight

As
expert154

noted the

in

my Opening

Report
M-l

and

confirmed operations

by

Camerons
at the of subtle

simultaneous and

non-standard

conducted
detection

behest
kick

of

BP

Transocean and
any were
to

SWACO
well

prevented the

indicatorsif

presentbefore
monitor flow

sheen

test

Because
available
in

the

mudlogger overboard Joe

Keith

was unable
after the that

once
kick

returns were
indicator

diverted
to

sheen
other

test the only arguable

parties
test.155

the the

have

cited

is

the

increase

standpipe

pressure

during subtle

sheen
of

This
in

parameter
real-time

would
is

have
notable

been
only

at
in

best

indicator

well

flow

and

hindsight

The 200
alerted

psi pressure

increase
that visual

during the
kick

sheen

test

would

not have

reasonable
did

mud logger
after

was ongoing
that with

especially the
of well

coming

as

it

immediately

confirmation

was

not

flowing.156

Joe Keith

seasoned

mud logger

years

experience as

153

Beck Report
Abel Report

at

114

154

Cameron at 14
Grace
at

155

See

e.g
Report

Report

BP
at

at

18

and
of

Report
Barnhill

Cameron
prepared
at

14-15

Expert Report

20 Bourgoyne Report L.V McGuire 10/17/2011

Report
for the

BP

at

66

Abel

Cameron at
United States of

Transocean
by

34-35

BP-Macondo P.Eng

America

Richard

Heenan

8/31/2011

hereinafter

Heenan

Report
156

21
at

See Beck Report

113-114

50

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

mudlogger on the Deepwater

testified
it

Horizon
for

and

18 years

in

the

Gulf of

Mexico
to

was

not

abnormal
the

the

Transocean and
that
off.157

drilling

crew expect an

leave
slight

trapped pressure

pressure
rise

on

standpipe reasonable

he

would

after the

pumps were

shut

When
could

using

excessive
typical

amount
pressure

of

heavy spacer responses to be magnified mudloggers

with kick

mud logger

expect such

Further standpipe

are kick

not

trained

to

associate
in

increases

in

pressure standard
in

As

described are

my Opening
taught
to

Expert
is

Report decrease

indicator

mudloggers

likely

expect

stand pipe or Keiths

pump pressurenot an
psi
if

increase.158

On Joe
be
difficult

5000
Even
to

pressure

scale159 detected the

200

psi

increase

would
the
at

to detect

he had
normally

increase

because

pressure

appeared
the

behave

once

the

displacement

resumed

914

PM

reasonable mudlogger
during

may have
By
the

discounted time

the minor pressure

significant
drilling

anomaly

sheen

test

more

pressure

anomalies were present

already detected
this

around
with

930
Drilling

PM

the Transocean
halted

crew had
At
for

problems

the well

and crew

the displacement.16 sole

responsibility
in

point

the
to the

Transocean

had

responding operations

kickthe mudlogger does

assists with
in

not participate

well

control

he merely

monitoring.161

As
several

thoroughly
of

discussed
parties

my Opening
the
is

Report
driller

and has

supported
primary set of

by
well

the

other

experts162

monitoring

responsibility
drilling

and

the

mudlogger
traditionally

just

second
more

eyes

on

the

well

crew

has

training

than

157

Keith

Depo
drill

3/28/2011

at

10316-25

90 percent

of the

time when they

off
158

crew do shut the pumps off they do not bleed the stand pipe pressure and sometimes the pressure will come up little bit and then level out. See
also

e.g HALOO51 189

HAL0051030

Surface

Data

Logging

Core

Fundamentals

at

159

SeeJ

Gisclair

Depo
114

3/14/2011

at

691-12

160

Beck Report

at

161

590
162

See e.g Transocean at TRN-MDL-00286786 See e.g

Beck
Report

Well

Control

Handbook

Section

Subsection

5.15

Exhibit

at

103-107

see also Azar Report

BP

at

11 and

Grace

Report

BP

at

51

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

mudlogger
data not
activities
drilling

has

higher
to

certification

requirements such
arise

and

is

able
of

to

access
rig

available

the

mudlogger
an anomaly
is

as knowledge
in

ongoing data

Also
not

should the

the

mudlogging
action to

the

crew

mudlogger

able

to

take

diagnose

and

correct any problems

Joe

Keith

properly monitored

all

data available

to

him and

would not have been expected

to stop the
that
if

displacement
mudlogger

BPs
not aware

expert
of
all

Dr Azar appears
parameters
at

to
all

suggest

the

was

well

times he should
with

have

stopped the
that the with
is

displacement.163

While
to

do not disagree
continuously

the general

assertion

mudlogger any and

available

is

required
that

monitor the well obligated M-l

to

do disagree
data
that

implication to

the

mudlogger

is

monitor

not

him

BP

Transocean
that

and

SWACO
total

knowingly
to

designed
of his

executed
kick

displacement
indicators164

blinded
that

the
pit

mudlogger

some

traditional

and
not

knew
be
to

gas concentration
they discharged the

and
the not
to

Sperry

flow-out

data

would

available the

when
he

spacer overboard expected

to

As
all

backup

driller165

mudlogger would be

was

stop

operations

simply

because

unable

monitor each
well
site

and

every

possible drilling-related parameter

this.166

BPs Macondo
BP and
M-l
material

leader

has

confirmed

Indeed
the

because
lost

SWACO

appeared
it

determined
is in

to that

discharge

circulation

spacer overboard would have resulted

by the mudlogger any concern raised any change to the overboard discharge procedures
that

doubtful

Dr Azar BPs expert suggests

normal
163

simultaneous operations

are

part

of drilling

do not disagree
and 44

However when

contemplating

Azar Report

BP
it

at 11

164

See e.g
is

Sepulvado
isolates

Depo
flow

5/11/2011

at

37424-37620
Sepulvado

that

dump
3225-

valve

open
swing
pretty

their

flowmeter
shows
over
will

Depo
crane

3/10/2011

at

3410

and 53322-5348
the crane quick

The
with

change

the

operations

make them

change
volume
well
165
in

load

the side
thing

And

thats the

same

30-barrel increase in you may get see when kick out of the you you get

the

well.
at 103-1

Beck Report

07
leader
flow-out

166

BPs Macondo
inform

well

site

Ronnie Sepulvado
sensor

would

not

expect

the mudlogger

to

him
at

if

the Sperry

was bypassed

See

Sepulvado

Depo

3/10/2011

1263-1276

52

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

simultaneous
impact
until
it

operations
safety
is

the

operator
or else

must

ensure

that

any

adverse

on can

rig

mitigated

must delay the proposed operation

is

be

conducted
require

safely
that

This

specified

in

BPs own
of or field

written

practices operations
to identify

which and
the

risk

assessment on each

simultaneous
in

threats

shall

be performed

facility

order

risks across

the complete

range

of well

activities.167 prior to

have
the
final

seen

no evidence

such

an

assessment

was conducted

Macondo

displacement.168 the suggestion by

Further
relied
influx
in

some
pit

of

BPs
and
is

experts

that to

BP

reasonably
if

on Sperry and

Sun

to monitor

levels

flow rates

determine

an

of formation

fluids

had

occurred169

misleading since procedures

that

drafting

approved
opinion

the displacement
difficult
is

BP made

assisted
pit

level

and

flow rate
In

monitoring

before

910 PM and
by

impossible

after that

time.7
for
its

my

this

yet another attempt

of
its

BP

to shift the

blame

own poor

decisions to one

contractors
all

Nevertheless evidenced
by the

Joe
four

Keith

monitored

data

available

to

him as
the
final

anomalies
data
of

he

communicated
none
the well

during

displacement.171 indicators

The
Keith

available

exhibited

of the

traditional
until

kick after

Joe

had

no

way

knowing

was

kicking

167

Depo Ex 1575 BPs ETP GP 10-75Simultaneous Operations see also Depo Ex 6121 at BPHZN-BLY00034593 2197MDL00408287
and
Well Operations
shall

at

BP-HZN
Drilling

BPs
place

Practice

Major Depo

Accident

Hazards
mitigations

as

result

of

Simultaneous
in

Operations the Well

activity

be identified so that

controls

and
at

can be

put

before

takes

place
transfers

and

Ex

590

TRN-MDL-00286819
in

Control

Handbook
pit

noting
to the

individuals

involved

rig

activity critical

should

Transoceans all mud well.

treatment
168

and

absolute

minimum during

sections of the

See

Bellow

Depo

05/03/11

at

6274-16

and 63422-63519

169

Grace Report

BP
Billon

at

170

See e.g 857-887 and 23225-2337

171

Depo

6/24/2011

at

36521-36711
9/14-15/2011
at

Keith

Depo

3/28/2011

at

1363-7 2439-24421
at

Lindner

Depo

12523-1307
3/10/2011
at

23110-17

and 4495-14

Sepulvado

Depo

476-481

See Beck Report

110

53

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

the

Transocean

drilling

crew

had

already

recognized

an

anomaly

and

stopped the

pumps around 930

experts
that

PM.172 the primary

BPs
control
drilling

conclude
kick

that

reason
in

for the

loss

of well

was
crew

the the

was

not

detected

time

by

the

Transocean
kick

and
in

Sperry

mudlogger.173

partially

agreethe
of

not detected

time by Transocean

and

BP
not

with

the data available to kick

in

was them
after

The
to

Sperry

mudlogger
that

had

no data
steps

clearly

indicative

Moreover
well

the

extent

proper

were

taken

to

shut

the

930 PM
and Joe

and

blowout
shoulders

ensued

that

responsibility

falls

squarely

on

Transoceans
had the
Keith

because

they were

aware

of the

pressure

anomaly

ability

and

the responsibility

to activate

the

blowout preventer

had neither

Joe

Keith

could

not have reasonably set flow pit or

pressure alarms that would

have

indicated should
alerted

kick have him

set

Some
his InSite
in

experts

have

implied that Joe

that Keith

Keith

set alarms
to

in

monitoring
well

software

would
did

have have

any
the not

slight

change
alerted

status.174

Joe no
fact

alarms
that

to of
is

monitor

the

displacement

there
to

is

indication
that

however

any
It

alarms always

Mr
to

Keith

the

the

well kick

was

flowing For

possible

set alarms for potential the

well

indicators

example
pit
pit

when
will

pumping
constantly

into

from

an

unmonitored
set
to

sea

chest
slight

volume
gain

increase sound

An
final

alarm the

detect are

would

continuously

because

pits

continuously
of flow-out

gaining

mud
at over

Similarly during the

displacement
If

the rate

peaked
to

1200
172

gallons

per

minute.76

Joe

Keith

had

set an

alarm

monitor for

Some
Keith

have suggested
took

that

an 8-10 minute

Joe

some
at

time between

830

PM
break

restroom coffee and cigarette break that and 900 PM was improper See e.g Abel

Report
entirely

Cameron
reasonably
implication

44

completely restroom
is

disagree

When
April

working

12

hour

shift

it

is

to take

provided

proper safeguards

are taken such

Keith

Mr

Abels

otherwise
the

disingenuous
driller

On

20

Joe

Keith

took

proper

safeguards 3/28/2011
173

by
at

alerting

assistant

he was

taking

break

Depo

15117-1 5217
Report

and 23616-22
at

See e.g Azar See e.g Azar

Keith

BP BP
at

and 50 and Bourgoyne Report and Bourgoyne Report

BP
65

at

66-67

174

Report

at 12

BP

at

175

Depo
Ex 620

3/28/2011

33119-24

176

Depo

54

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

excessive

flow during the per

displacement and
the

he would
in

have
at

set

it

higher than

1200

gallons

minute

increase

flow

908

PM177 which
his

kick indicator would not have some have cited as this flow was less than 1200 gallons per minute to reset flow-out nor common practice practical

triggered
It

alarm as been
the time

would

not have

alarm every
the

Transocean

drilling

crew
is

changed
of

pump speed
exhibited

during

displacement
the
final

The

same

thing

true

standpipe

pressure
frequent

During

displacement expected minutes circumstances

later

standpipe
it

pressure

and

significant

fluctuations
for

would
to set

have

been

impractical

under

the

Joe

Keith

alarms which

would

be meaningless only

Moreover
Opening
values
to

without the

pressure/volume mudlogger would

his

schedule

as described have

in

my

Report78 use

not necessarily

known what

when

setting

alarms during
in

complex

displacement

Sperry had no say displacement

how

the

rig

was plumbed or how the

was

to be

run
agree
that closed-pit

As
is

described

in

my Opening
of

Report conducted
expert

system
that

the

preferred

method have

operating

displacement
in

and

the

displacement
closed Sperry
pit

could

been

manner which

utilized

system.179
to

Camerons
in

alleges that

both Transocean closed

and
pit

failed

maintain

material
to

balance180meaning

system as described

Appendix
is

my Opening

manner

in

which

the

rig

plumbed

during

However the displacement was not Sperrys

Report

177

Note
result of

it

is

not

clear

whether the increase

in

flow-out

was due

to or

flowing

well

was
by
rig

the

trip

tank

dump

which

began

around

959
at

PM

was caused

movement and
178

crane

operations
at

See e.g Beck

Report

110-112
5/11/2011
at

See Beck

Report

113

See also

Sepulvado

Depo
would

2098-25

and

2131-6
179

Note
Sperry

there were meter

to

alternate

routings online at

available

that

have

at

least

allowed

the

flow

remain

while

displacing

overboard

See

5125
180

and Heenan Report

Report

US

e.g

Depo

Ex

18

Abel

Cameron at 14

55

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

decision.181

BP
the
fluid
in

Transocean
and

and

M-l

SWACO made
to divert active

the

decisions

to

pump

from

unmonitored
into

sea

chest

overboard
pits.182

and
Sperry

to

move
no Joe

additional

out of the designated decisions

had

involvement Keith the

these

which
simply

complicated monitored available to

well

monitoring
situation

Sperry
with

mudlogger

the

he

was

presented

using

the sensors

made

him
by the surviving

BPs
In

expert

makes claims not supported

data

mudlogging
his

opening

report
in

BPs

expert

Robert

Grace

identified

three

anomalies

that

do not see
stated

the Sperry

data

Mr
drill

Grace

852
remained

PM

the

mud pumps were slowed and

At
this

the

string

pressure This

constant

time

the

well

was

flowing.83 flowing well

seems to imply the pressure response was caused by when in fact the reduction in pump rate was on the booster
is

pump
the

which

not connected
In

to the

standpipe the

and

thus

has no

effect

on

the standpipe pressure This

pressure
in is

truth

when

pumps slowed around 852

as expected
it

PM

the

well
in

also

decreased

did

not

remain

constant

shown

the data

below

181

See e.g 857-887 and 46912-22

Tr
182

Billon

Depo

6/24/2011

at

36521-36711
9/14-15/2011
at

Keith

Depo

3/28/2011

at

1363-7

Lindner

Depo

4425-4511

14924-1504

47215-21

of

USCG/MMS
of
is

and 47921-4806 at 476-481 Sepulvado Depo 3/10/2011 Guide testimony 7/22/2010 at 161 24-1624 Investigation

See e.g Tr 1624 But

whether
or
is

USCG/MMS
Transocean
certain

Investigation that

it

operates are

this

Guide testimony 7/22/2010 at 161 24and BP that makes the decision as rig
to

to

not that

operations That
is

going

be performed
Billon

and

when
at

they

are

performed

correct

36711
15/2011

Keith at

Depo

3/28/2011

at

correct 857-887

Depo

6/24/2011

36521-

12523-1307

23110-17
at

Lindner Depo 9/141363-7 and 2439-24421 23225-2337 4495-14

and

Sepulvado
183

Depo

3/10/2011
at

476-481

Grace Report

BP

18

56

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

LU

9r

-I\
rfl

.1

.1
rTJ

.1

FT

rTl

cc

cc

Q_

TI Fl

211511

21

1111

2i

ii

2i

Figure

Sperry mudlogging data interpreted

incorrectly

by

BPs

expert

Mr Grace

Mr
to

Grace

also stated

roughly
drill

859

PM
to

the

pumps were
The
analysis

further

slowed and the pressure have been

on the
this

string
184

began Again

increase

well
is

had
not
at

flowing during the

time
data

Mr Graces

consistent

with

mudlogging decreased
reveals
is

When

the

pumps were slowed

close
at

859
of the
this

PM

the

pressure data

as would

be expected
beginning

analysis

surviving

pressure

increase

900
of

PM

but

pressure detected

increase
in

not

something
especially
including well

reasonable
given the the
pits

mudlogger

would
several

have

real

time

simultaneous
the then
trip
pit

fluid

transfers switching
in

dumping

presence sand traps and

10

emptying
pit

tanks

and

returns from
Report.185

to

and

as discussed

my Opening
what

Finally

Mr

Grace

identified

he believes
the

is

an

inconsistency

describing rates the

that
drill

after the string

sheen

test during increased

periods

of constant

pump
then
it

pressure

until

about

926
were

PM

and

began he
is

to decrease.186 referring

am

unsure what timeframe

periods
the

of constant

pump rates
the

to

During

this

drillers

staggering

pumps and ramping them up gradually as can be seen in the data above According to Joe Keith this was abnormal behavior and Mr Keith called to Between 914 PM and 926 PM there are no periods where investigate.187
184

Grace Report

BP BP

at

18
to the

185

See e.g Appendix

Grace Report
at

Beck Report

at

35-39

186

19

187

See Beck Report

at

110

57

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

the

pump

rates

are sufficiently pressure

steady

to

draw

any conclusions
the
rate

about

well

flowing

from the
is

response.188

Rather

observed increases
in

pressure pressure begins

to

response
generally

as one

would

expect

as

total

pump

increases

Once pumps
is

level

off

pressure

the well

decrease as heavy spacer

displaced

by lighter seawater

Summary
My
of

opinions

and
In

conclusions

as set

forth

in

my Opening
conduct

Report

remain unchanged
the well

my

opinion

BPs
did

reckless failure to maintain control

and

to

lesser extent

Transoceans
not
in

caused and
are

the not

blowout

Halliburton

and

Sperry

any

way cause
thereof

responsible

for the blowout or any

consequences

188

C.f

Heenan
rig

Report

US
is

at

23 Noting
from

that

pressure
to

particularly to

in

real

time for the

personnel

difficult

2115

2130 due

changes

in

pump rate.

58

CONFIDENTIAL

REBUTTAL

EXPERT

REPORT

OF

DR

FREDERICK

GENE

BECK

reserve
additional

the

right

to

modify

this

report

and
in

to

supplement
to

my

opinions

if

data

becomes

available

and

response

reports served

by

other parties

Dated

Frederick

Eug

ne Beck

59

CONFIDENTIAL

MDL NO
In

2179
the Gulf of

re

Oil Spill

by the

Oil Rig

Deep water Horizon in

Mexico on

April

20 2010

DR FREDERICK

BECK REBUTTAL SOURCE

RELIANCE APPENDIX

BP-HZN-21 79MDL00269659-269673

HAL_0048974

BP-HZN-MBIOO1

28708-128756

BP-HZN-21 79MDL03082878-30831

51

IBP-HZN-21

79MDLO1

591 521-1591535

of

Pages

TRN-INV-01

747442-1

747659

3808 4021 4091

6/20/2011

Macondo
Application E-mail

Well Incident
for

Transocean
to Drill to

Investigation

Report

Volume

BP-HZN-SNR00000122-150 BP-HZN-21 79MDL00247793

Permit
Hafle

New

Well Subject

from Mark

Brian

4/2/2010 as Confidential and Subject

Morel

Macondo

9-78

LOT

FIT Worksheet.xls

marked

BP-HZN-MBI

00125958

4242 4842

4/12/2010

April

12 2010 Macondo

E-mail

string

from David

Sims

to

Brian

Morel

from

Brian

Morel

to

David

Sims

times

marked
job

as Confidential

Presentation

re designing

cement

TRN-INV-02514877-2514881 BP-HZN-BLY00034504-34604 BP-HZN-2179MDL00339799-339820 BP-HZN-21 79MDL000221

59-22208

5125
6121 6291 6320 6321 60071

9/30/2010

E-mail

string

among
Well
Drilling

Bob Walsh and

Operations and

Wesley

Bell

et

al
practice for

BP
3/31/2009

Drilling

and

Practice

EP

Defined Operating

GP

10-00
of

BP SPU G0M Change

March

Completions marked as

DC

Recommended

Practice

Management

31 2009
of

CONFIDENTIAL

Contract for Gulf 4/6/2010

8/31/201 E-mail

Mexico
to

BP-HZN-2179MDL00032979-32981

from

Mr

Daly

Mr

Inglis

Expert Report of Glen

Transcript of

Benge
Lewis

USA
before

60079 60080
60081

6/11/2010 10/17/2011 10/17/201 10/17/2011 4/16/2010 8/31/2011 10/7/2010 8/24/2010 12/7/2010 9/23/2011 11/8/2010

Jesse

Gagliano

US House

of

Representatives

Expert Report of

Sam

Halliburton

Expert Report of Frederick Hallibu rton

Beck on Well Design Control P.E

Drilling

and

Monitoring

60082 BP-HZN-2179MDL00003541-3545 60095 60110 60118 60120

60121

Expert Report of John

Hughett

Halliburton

BP

Daily

Operations

Report

Partners

Completion

Expert Report of Richard Heenan

Transcript Transcript Transcript of of of

USA
USCG/BOEM USCG/BOEM USCG/BOEM
Investigation Investigation Investigation

Testimony Testimony Testimony

of Joint of Joint of Joint Barnhill the

60124

Expert Report of Calvin

TO
BP Deepwater
30
Part

HAL 0506948-507095

The 60504

National

Commission on

Horizon

Oil

Spill

and

Offshore

Drilling

Hearing

Transcript

Code
60521

of

Federal Regulations Shelf Subpart

Title

250

Oil

and

Gas and

Sulphur Operations

in

the

Outer

Continental

30
PIs

CFR
08-26-1

250
08-26-1

60659 60660 60662

60811

8/26/201 8/26/201

Expert Report of Bea-Gale Expert Report Expert Report

of of

David

Pritchard

PIs

Dr Alan Huffman

Submitted

on

Behalf of the United

States

Department

of

8/26/201 Justice

7/22/2010 8/27/2010

Testimony

of Joint

60815

2010 0827 Testimony

USCG_BOEM Investigation of Joint USCG_BOEM

Investigation

of

Pages

BP-HZN-BLY00061

224-61227

5/1

1/2010

Handwritten
Halliburton

Notes

BP-HZN-CEC021441-21452 BP-HZN-CEC021665-21667 BP-HZN-CEC022666-22668 BP-HZN-MBIOO1 BP-HZN-MBIOO1 BP-HZN-MBIOO41 HAL_001 HAL_0051

TRN-INV-01 0592-1061 030-51276

4/18/2010 4/14/2010 4/17/2010 1/27/2010 4/14/2010

7/8

Production

Casing
Initiate et

BP BP BP BP

Drilling

Completions Cocales
to

MOC

Email from

Walz
for

al

re

Cement Procedure

92552 92559 3304

Supplemental
Authorization

Authorization
for

Expenditure

Expenditure Casing Casing Design Fundamentals

Roller
re

Macondo
4/15/2010 01/00/2001 9/16/2010 5/11/2010 3/8/2010 4/16/2010 10/25/201 10/17/2011
10/1 7/20

Production

7/8

Production Logging

Report for Brian

Morel

Surface Data Email from

Transcript
Insite Insite

Core
to

824082

TSC
of

Conrols

Flow

Line

Sensor Committee

Senate

Energy

and

Natural

Resources

Data Data
for

Expert Report Prepared

M-l

LLC by George

Medley

Jr P.E

Expert Report of Gordon Cain Expert

Drilling

MOEX
Anadarko 7/8
Production Casing String on the

Report of Roger Vernon Cementing on the

Evaluation

of the

Macondo

10/17/2011
3/10/201 10/1 7/20

Well

Expert Report by Fred Sabins

Sepulvado
Report

Ronald Burch

Deposition

Transcript

of Morris

BP
Sutcliffe

10/17/2011 10/17/201 10/17/2011 10/17/2011 10/17/2011 10/17/2011 10/17/2011

10/1 7/20

Expert Report of Kathleen Expert Report

of

Ph.D

Chuck Schoennagel
Behalf of

L.L.C

MMS

Regulatory

Regime

Expert Report on

BP

Robert

Grace

P.E

Expert Report of David Expert Report ofJ.J Expert Report of

Calvert

Weatherford

Azar Ph.D

BP BP
VVeatherford

Adam
\Nilliam

Bourgoyne

Expert Report of Gregory Expert Report of

McCormack
Abel

Cameron
P.E LA and

10/17/201 10/17/2011

Expert Report of Donald Review

Frigaard of the

Weintritt

TX Retired
Casing Cementation Operation by Ian

Macondo

9-7/8

Production

Cameron
Trahan
Lirette

10/17/2011 10/17/2011 10/7/2011 4/21/2011

Expert Report of Kevin

Cameron
on Behalf of Weatherford

Expert Report ofBrentJ Expert Report

of

U.S

L.P

Marion

Woolie
Deposition

Weatherford
Transcript

Walz

Gregory Stephen

of

Pages

_________

4/22/201

Walz
Review

Gregory Stephen
of the

Deposition

Transcript

10/17/2011 3/17/2011 5/11/2011 8/25/20 3/28/2011 10/17/201 10/17/2011 3/14/2011 6/24/2011

9/14/201 9/15/201 6/2/201 5/9/201
7/1

Production

Casing Design
Transcript Transcript

forthe Macondo

Well

Expert Report by David

Lewis

Chaisson Sepulvado

Nathaniel

Deposition

Murry Deposition
Deposition Deposition

Tiano Robert
Keith Joseph

Transcript Transcript

Summary and

Conclusions

Deepwater

Horizon Incident

prepared

by Morton

Emilsen

BP

Expert Report of L.V McGuire

Gisclair Billon

Cameron

John Brad Leo Leo

Deposition

Transcript Transcript

Deposition

Lindner Lindner

Thomas Thomas

Deposition Deposition

Transcript Transcript

Lacy

Kevin

Deposition Deposition

Transcript Transcript Transcript Transcript

Guide John

5/20

OBryan
Breazeale Corser

Patrick Martin

Deposition Deposition

5/16/2011
2/10/201 10/1 1/201

Ken

Deposition

Transcript Transcript

Douglas Scherie Cocales

Deposition

4/26/201

Brett Deposition

Transcript

10/17/2011
4/15/201 7/29/201 5/3/201

Expert Report of David

Bolado
Transcript Transcript Transcript simulation

Gray

Kelly

Deposition

Clark Skip Deposition Bellow Jonathan

Deposition

Beck

Rebuttal

Figure

BPs OLGAs

shows

that

most

of the

kick

volume

was

not

detectible

by the mud logger

Figure

Beck Grace

Rebuttal

Sperry

mudlogging

data interpreted

incorrectly

by

BPs

expert

Mr

of

Pages