Deposition Testimony of: Robert Bodek - Broadcast Interactive Media

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Deposition Testimony of: Robert Bodek - Broadcast Interactive Media

Deposition Testimony of:

Robert Bodek

Date: April 11, 2011

Created by:

www.indatacorp.com


Page 15:15 to 15:23

00015:15 having been first duly sworn, testified as

16 follows:

17 EXAMINATION

18 BY MR. WATTS:

19 Q. What is your name?

20 A. My name is Robert Joseph Bodek

21 Jr.

22 Q. You go by Bobby?

23 A. I do, sir.

Page 18:07 to 18:08

00018:07 How old a man are you?

08 A. I am 30 years old.

Page 18:12 to 19:14

00018:12 Q. How does a boy from Binghamton,

13 New York end up in Houston, Texas?

14 A. I went to graduate school in

15 Virginia, and the company I'm with now, BP,

16 they -- they recruited me from graduate

17 school to work for them in their Houston,

18 Texas office.

19 Q. You went to college where?

20 A. I went to undergrad at the State

21 University of New York college at

22 Brockport.

23 Q. Okay.

24 A. And I went to graduate school,

25 got my masters at Virginia Tech.

00019:01 Q. So SUNY Brockport. What did you

02 graduate with?

03 A. A degree in geology.

04 Q. Okay. So you got an

05 undergraduate degree in geology in what

06 year?

07 A. 2003.

08 Q. And then you went off to get a

09 masters in what?

10 A. I got a master's degree in

11 geology.

12 Q. Okay. And you got that master's

13 degree in 2005?

14 A. 2006.

Page 19:17 to 22:05

00019:17 Q. And at that point in time, was

18 your first job in the private sector, if

19 you will, with BP?

1


20 A. I had a small internship

21 prior --

22 Q. Full-time job?

23 A. -- but my first full-time job

24 was with BP, yes, sir.

25 Q. So you moved out to Houston

00020:01 immediately?

02 A. Yes, sir.

03 Q. Okay. When in 2006 did you

04 begin your job with BP?

05 A. I began my job with BP

06 August 28th of 2006.

07 Q. And in what position?

08 A. As an -- my first position was

09 an operations geologist onshore.

10 Q. What does an operations

11 geologist onshore do?

12 A. Help deliver -- plan and deliver

13 wells, national gas wells.

14 Q. Onshore wells?

15 A. Onshore. It was Wyoming.

16 Q. Okay. And how long did you do

17 the Wyoming onshore wells?

18 A. A little bit over a year.

19 Q. Okay. That would take us to the

20 fall of '07?

21 A. Yes, sir.

22 Q. And what did you begin to do at

23 that time?

24 A. At that time, I transferred jobs

25 to Gulf of Mexico exploration.

00021:01 Q. Uh-huh.

02 A. I worked in deep gas exploration

03 mapping shallow hazards that overlie some

04 of the -- some of BP's deep gas prospects.

05 Q. Okay. And what was your

06 official job title when you were working in

07 the deep gas exploration section mapping

08 shallow hazards as you were going deeper?

09 A. I was an exploration geologist.

10 Q. Okay. And how long did you

11 continue in that position?

12 A. Approximately a year.

13 Q. Till the fall of '08?

14 A. Yes, sir.

15 Q. Okay. And in the fall of '08,

16 what position did you take?

17 A. In the fall of '08, I took on a

18 new position as an operations geologist in

19 Gulf of Mexico exploration.

20 Q. And how did that job differ from

21 the one you had the previous year?

22 A. From the -- I was involved in

23 well planning and well delivery as opposed

24 to just prospect mapping.

2


25 Q. Okay. How long did you work in

00022:01 well planning and well delivery?

02 A. Till current.

03 Q. Okay. You're still in that

04 position?

05 A. Yes, sir.

Page 24:08 to 24:16

00024:08 Q. When did you first get involved

09 in this Macondo 252#1 well plan?

10 A. The late stages of -- of

11 planning. I would typically come on to a

12 well just prior -- you know, a couple of

13 months before we begin it.

14 Q. Okay. When would that have

15 been?

16 A. August, September 2009.

Page 25:19 to 26:07

00025:19 Q. Okay. Were you familiar with

20 that area before you began well planning in

21 August or September of 2009?

22 A. Yes, sir.

23 Q. Okay. And what was the basis of

24 that familiarity?

25 A. I had worked a previous well in

00026:01 the area as an operations geologist.

02 Q. And what well was that?

03 A. That was the H-2 well.

04 Q. Okay. And when did the H-2 well

05 get drilled?

06 A. That was fall 2008 through

07 spring 2009.

Page 27:19 to 27:22

00027:19 Q. Are you familiar -- or is it in

20 your area with respect to MMS compliance

21 and MMS permits?

22 A. No, sir, it's not in my area.

Page 28:13 to 28:15

00028:13 Q. Well, what is the -- the premise

14 behind going offshore, a much harder well,

15 than as opposed to just drilling on land?

Page 28:18 to 29:07

00028:18 A. Prospectivity.

3


19 Q. Okay. And when you say

20 prospectivity, is that a BP term or an

21 industry term for the size of the

22 reservoirs that are down there may be

23 larger and more productive?

24 A. In general, yes.

25 Q. Okay. So the idea is that even

00029:01 though it's more expensive and perhaps more

02 risky and more time consuming, once you get

03 down there and you punch the hole in the --

04 the seabed you get to a reservoir that may

05 have more product and, therefore, more

06 profit?

07 A. It's not necessarily more risky.

Page 29:10 to 29:17

00029:10 Even though it's more

11 expensive and perhaps more time consuming

12 than just putting an onshore well, an

13 offshore well is perhaps justified because

14 the size of the reservoir and the amount of

15 the product that can be extracted from it

16 is greater?

17 A. Yes, sir.

Page 29:23 to 30:15

00029:23 Q. Well, what area of the Gulf of

24 Mexico is it that -- that you're doing this

25 geological research before you drill down?

00030:01 A. In Mississippi Canyon.

02 Q. Okay. Explain for the jury what

03 the Mississippi Canyon is and why it is --

04 it was believed, before you even drilled

05 the well, that it would be prospective?

06 A. Mississippi Canyon area is off

07 shore Louisiana. We have drilled many,

08 many other wells in the area. We have

09 producing fields in Mississippi Canyon. We

10 have drilled countless wells in Mississippi

11 Canyon, both exploration wells and both

12 development wells that are on production.

13 Q. Okay.

14 A. We were very familiar with --

15 with this plate type.

Page 31:09 to 33:20

00031:09 Q. Okay. In terms of the

10 particular formation that you-all were

11 attempting to explore, what is that

12 formation called?

4


13 A. It doesn't have a particular

14 nominal name. We refer to it as the M56,

15 the Miocene 56.

16 Q. What is the Miocene?

17 A. The Miocene is a time in earth's

18 history.

19 Q. Okay. And just for the jury,

20 how far back in time is the Miocene a time

21 in earth's history?

22 A. A few million years.

23 Q. Okay. And the concept is that a

24 few million years ago, what happened to

25 create the Miocene formation?

00032:01 A. The concept is, is there was

02 channels that were coming off land, rivers,

03 streams, fluvial systems that were

04 emptying, draining land, emptying in the

05 Gulf and carrying sand into the Gulf of

06 Mexico across the shelf and down into the

07 basin.

08 Q. Okay. And that sand, when it

09 went down in the basis (sic), what happened

10 to it such that it would -- became

11 hydrocarbon prospective, if you will?

12 A. Eventually that -- that sandy

13 formation or that sand-prone interval will

14 get -- will get buried. Subsequent --

15 subsequent to burial -- as you bury things

16 they continue to heat. As you heat the

17 source beds, which are much older than the

18 Miocene, they are Jurassic, Cretaceous in

19 age. As you begin to continually bury

20 those source beds, heat and pressure upon

21 those source beds with these organic rich

22 shales will expulse hydrocarbons.

23 Q. When you say expulse

24 hydrocarbons?

25 A. Produce hydrocarbon.

00033:01 Q. Okay.

02 A. Okay. The hydrocarbons will be

03 produced from these organic rich shales

04 that were deposited back in the -- in the

05 Mesozoic. The -- the hydrocarbons being

06 lighter than the pore fluids, lighter than

07 the rocks will migrate upwards. They will

08 tend to collect in porous medium such as

09 sandstones. Where -- where prospect and

10 geologist can superimpose or superpose

11 hydrocarbon migration to sandstone

12 reservoirs, and the sandstone reservoirs

13 have a geometry in such that they will trap

14 hydrocarbon -- hydrocarbon accumulations.

15 And these -- these hydrocarbon

16 accumulations are overlain by impermeable

17 formations, such as shales. Then the

5


18 hydrocarbon will -- will sit in fissure in

19 these topographically high sand point

20 intervals.

Page 34:11 to 35:01

00034:11 Now, why is it that the

12 Gulf of Mexico and particularly this

13 Mississippi Canyon area is prospective as

14 opposed to you guys going and drilling in

15 some mountain in Colorado?

16 A. You needed to have vertically --

17 it's the vertical stacking of the

18 aforementioned components. So the -- the

19 source needs to be, A, present. It needs

20 to be buried to the point where it's heated

21 and pressurized to the point where it emits

22 or expulses hydrocarbons. And the

23 migration pathway from those expulsed

24 hydrocarbons needs to be overlain by the

25 aforementioned sandstone or porous

00035:01 permeable reservoir to trap and to seal.

Page 35:05 to 35:09

00035:05 Q. Okay. And the Mississippi

06 Canyon has those formations that you're

07 looking at geologically -- I mean, that

08 you're looking for geologically?

09 A. Yes.

Page 35:13 to 35:25

00035:13 Q. The hydrocarbons must be

14 present. What does BP do to determine that

15 it is likely that there are hydrocarbons

16 present at a given depth?

17 A. We have petroleum systems

18 analyst and geochemists that work for us in

19 exploration. And predominantly what

20 they'll do is they will look at a lot of

21 seismic data.

22 Q. Okay.

23 A. So that's the -- the first thing

24 is, you know, you go out and you shoot a

25 seismic survey. You have seismic data.

Page 37:08 to 37:17

00037:08 Q. And they're basically shooting

09 an impulse down into the ground to see what

10 bounces back up and how long it takes,

11 right?

6


12 A. Yes, sir.

13 Q. And by virtue of how long the

14 sound wave takes to bounce back up, what

15 does that tell you all as geologists?

16 A. You can get the -- the depth and

17 orientation of -- of sedimentary layers.

Page 39:12 to 42:07

00039:12 Q. Okay. Now, once the geologists

13 and the subsurface exploration teams

14 identify, hey, we think down at 17,250 feet

15 there may be a pay zone down there, how do

16 you get involved at that point in terms of

17 well planning and well delivery?

18 MR. MONICO:

19 Objection, form.

20 A. Could you repeat that, sir?

21 Q. Sure. Once somebody else within

22 BP identifies a prospect --

23 A. Uh-huh.

24 Q. -- at different depths, you said

25 about a month before the -- the well begins

00040:01 to be drilled you're brought in as an

02 operations geologist to begin well planning

03 and well delivery. And my question is:

04 How does that transition take place?

05 MR. FIELDS:

06 Objection, form.

07 A. I'd begin to engage the

08 different teams. It's a multidisciplinary

09 team that delivers the well. So my first

10 step is to engage the team in

11 communication, facilitate communication

12 between the prospect team who defines the

13 prospect, the new well delivery team, which

14 I work on that helps plan the well in

15 accordance to -- and -- and the drilling

16 team.

17 Q. Okay. You told me that in order

18 for hydrocarbon to be produced you've got

19 to have sands that are buried in heat and

20 pressurized. What is your understanding as

21 to the pressures that can be seen when

22 you're drilling beneath the seabed

23 17', 18,000 feet?

24 A. It can vary greatly.

25 Q. Okay. When you have something

00041:01 that can vary greatly, what steps do you

02 get involved with in order to make

03 projections for the drilling team? You're

04 likely to see the following pressures at

05 the following depths?

06 A. We have people on our team

07 that -- that do that work. I -- I don't do

7


08 pressure prediction.

09 Q. Okay. But you have people at BP

10 that do pressure prediction; is that right?

11 A. Yes, sir.

12 Q. And what group would that be?

13 A. That would be the exploration

14 Tiger Team that I work on.

15 Q. All right. And the exploration

16 Tiger Team that you work on -- and we'll

17 get into the Tiger Team later -- makes

18 projections as to what likely pressures are

19 going to be. And then once you have those

20 projections of likely pressures, how do you

21 communicate that to the drilling team?

22 A. It is sent to the drilling team

23 as a -- as a depth versus pressure plot.

24 Q. Okay. Depth versus pressure --

25 pressure plot.

00042:01 A. Uh-huh.

02 Q. And let me just ask a very blunt

03 but not articulated question. Who cares?

04 Why do you have the depth versus

05 pressure -- pressure plot?

06 A. The drillers utilize it to plan

07 the well.

Page 42:18 to 43:08

00042:18 Q. Sure. As you go down, sometimes

19 you're going through hard rock; is that

20 right?

21 A. Yes, sir.

22 Q. Sometimes you're going through

23 something that's a lot more sedentary,

24 that's not as rigid or hard to drill

25 through?

00043:01 A. Yes, sir.

02 Q. I've read e-mails in this case

03 that some of the BP people said that we're

04 drilling into a weak goo. It doesn't

05 strike me as a very scientific term.

06 What are they referencing

07 when they talk about drilling into a weak

08 goo?

Page 43:11 to 43:21

00043:11 A. Shallow sediments.

12 Q. Okay. And shallow sediments,

13 why are they characterized as a weak goo as

14 opposed to something else?

15 A. They -- the shallower the

16 sediment, the less burial it's been

17 subjected to. As you bury a rock, it

8


18 becomes harder and more indurated. So

19 typically, the shallower sediments are

20 considered less cohesive. They're

21 unconsolidated for the most part.

Page 44:24 to 45:05

00044:24 Q. Okay. What is the golden zone?

25 A. I've never heard that term

00045:01 before.

02 Q. Never?

03 A. Golden -- you said golden zone?

04 Q. Yes, sir.

05 A. I never heard that term before.

Page 46:13 to 48:11

00046:13 Object to form. I'm sorry.

14 Q. Does BP consider deepwater

15 offshore drilling to be a risky

16 proposition?

17 MR. FIELDS:

18 Object to the form.

19 A. BP considers offshore drilling

20 to contain inherent risk.

21 Q. Okay. What are the inherent

22 risks that you were trained to understand

23 would be inherent when you're going into a

24 well formation or a well drilling process

25 deep -- deepwater in the Gulf of Mexico?

00047:01 A. I'm trained to identify risks

02 associated with -- with drilling.

03 Q. Okay. What are they?

04 A. Pore pressure.

05 Q. Okay.

06 A. Fracture gradient.

07 Q. Okay.

08 A. Shallow hazards.

09 Q. Okay.

10 A. Depth uncertainty.

11 Q. All right. Any others?

12 A. That's what immediately comes to

13 mind.

14 Q. Let's go through each of those

15 just real briefly.

16 One of the inherent risks

17 that you're trained to identify is pore

18 pressure?

19 A. Yes, sir.

20 Q. What is pore pressure and why

21 does it matter? Why is it a risk?

22 A. Pore pressure is the -- the

23 pressure that's -- sedimentary rocks are

24 made of particles. The pore pressure is

9


25 the fluids in those particles -- are under

00048:01 a certain pressure.

02 Q. So what? Why is that a risk?

03 A. When you're drilling your well,

04 you need to have hydrostatic mud weight

05 that's approximately in line with the pore

06 pressure.

07 Q. Why?

08 A. If your hydrostatic mud weight

09 is too low, the well will flow. If your

10 hydrostatic mud weight is too high, you can

11 fracture the rock.

Page 48:19 to 50:18

00048:19 When you say if the

20 hydrostatic mud weight is too low, that the

21 well will flow. When you say the well will

22 flow, why is that a bad thing? I thought

23 that was the goal of exploration?

24 A. I should clarify it. The well

25 can flow.

00049:01 Q. Okay. When you say the well can

02 flow, why is that a bad thing?

03 A. When you're drilling you want to

04 keep your mud system -- mud and your

05 hydrocarbons in the formation.

06 Q. Why?

07 A. From -- from my standpoint, it's

08 so your -- your mud stays -- you stay -- it

09 stays -- your -- your mud properties stay

10 the same.

11 Q. Why is it important that your

12 mud properties stay the same?

13 A. To control the well.

14 Q. Okay. You use the phrase "to

15 control the well". When your hydrostatic

16 mud weight is too low relative to your pore

17 pressure, you said the well will flow?

18 A. Can flow.

19 Q. When the well can flow, that has

20 certain well control implications that BP

21 does not want to see?

22 A. Yes, sir.

23 Q. Okay. When the hydrostatic mud

24 weight is too low relative to the pore

25 pressure, the well can flow and create well

00050:01 control issues. Why is that a bad thing?

02 A. Could you repeat that, sir?

03 Q. Sure. When the well flows, why

04 is that bad?

05 A. It provide -- it's dangerous.

06 It's a risk.

07 Q. Why is it dangerous?

08 A. 'Cause you don't want to bring

10


09 hydrocarbons to the surface.

10 Q. Why don't you want to bring

11 hydrocarbons to the surface?

12 A. I just know that it's a risk.

13 Q. I know. But putting on your

14 common sense hat for a second --

15 A. There's some --

16 Q. -- why don't you want to bring

17 hydrocarbons to the surface while you're in

18 the middle of a drilling project?

Page 50:21 to 50:24

00050:21 A. It's -- it's dangerous.

22 Q. Why is it dangerous?

23 A. Because hydrocarbons are

24 hazardous.

Page 51:20 to 52:07

00051:20 Q. If you bring hydrocarbons up on

21 the rig in an uncontrolled situation, what

22 is that called?

23 A. A well flow or a blowout.

24 Q. A blowout? Okay.

25 If you have a blowout, if

00052:01 it's not contained, you can cause certain

02 environmental damage as the well

03 hydrocarbons go into the water, right?

04 A. Yes, sir.

05 Q. You can have a fire if there's

06 an ignition of those hydrocarbons, right?

07 A. Yes, sir.

Page 52:15 to 55:08

00052:15 Q. Sure. The risk, a well blowout

16 causing environmental damage or the

17 hydrocarbons being ignited and causing a

18 fire, are two of the reasons that you say

19 it is a bad thing for your hydrostatic mud

20 weight to be too low relative to your pore

21 pressure?

22 A. That can contribute to it, yes.

23 It's not the sole cause.

24 Q. You also told me that if your

25 hydrostatic mud weight is too high relative

00053:01 to your pore pressure, that that can

02 fracture the formation?

03 A. It can, yes.

04 Q. When you say fracture the

05 formation, what do you mean?

06 A. I'm referring to losing drilling

11


07 fluid into the formation.

08 Q. Why is losing drilling fluid

09 into the formation a bad thing?

10 A. You lose your ability to -- to

11 drill the well.

12 Q. Why?

13 A. 'Cause your mud's not coming

14 back to surface. So when your mud comes

15 back to surface, it carries the cuttings

16 that are being produced by the -- that

17 macerating the rock.

18 Q. Sure. Let me just give an

19 example to the jury. If -- if we had a

20 drill bit and we started drilling through

21 this Sheetrock right here, what would come

22 out of the hole as the drill is rotating is

23 little cuttings of what used to be the

24 Sheetrock; is that right?

25 A. Yes, sir.

00054:01 Q. What happens when you're doing

02 deepwater offshore drillings is you're

03 drilling downward. But same principle, you

04 have a rotating drill bit that is cutting

05 something. And if you had the proper

06 hydrostatic pressure relative to your pore

07 pressure, the idea is that your mud goes

08 down and brings back up your cuttings; is

09 that right?

10 A. That's correct.

11 Q. If that mud goes down and

12 fractures the formation, it will go

13 sideways into the geology as opposed to

14 coming back up; is that right?

15 A. Yes, it can.

16 Q. And when you say that -- when

17 you lose that drilling fluid because it

18 goes sideways into the formation, that's a

19 bad thing.

20 Is it a bad thing because

21 your cuttings also go into the formation?

22 A. I don't think that's a bad

23 thing.

24 Q. Okay. Why is it a bad thing? I

25 mean, why isn't it okay to have hydrostatic

00055:01 mud weight, you know, too high relative to

02 the -- the pore pressure such that you

03 fracture the formation?

04 A. It prevents us from -- from

05 drilling.

06 Q. Why?

07 A. We can't drill without --

08 without returns.

Page 55:16 to 56:03

12


00055:16 Q. Lost returns is a situation

17 where you're injecting mud down, you expect

18 to get it back up with the cuttings, but

19 you're not getting it back, you're losing

20 it to the formation?

21 A. Sure.

22 Q. Lost returns, to put it bluntly,

23 is a bad thing, right?

24 A. Yes.

25 Q. Okay. And it's a bad thing

00056:01 because you have fractured the formation

02 and you cannot drill when you lose returns?

03 A. Yes.

Page 56:22 to 57:06

00056:22 Q. All right. With respect to this

23 issue of drilling into weak goo or possum

24 shit and leaves as opposed to hard rock,

25 why is that relevant or important to keep

00057:01 an eye on when you're drilling?

02 A. The less consolidated formations

03 will be more susceptible to fracture.

04 Q. Why?

05 A. They have a lower tensile

06 strength.

Page 58:10 to 58:15

00058:10 Q. Sure. And I don't mean to

11 oversimplify or demean the, you know,

12 importance of what you do. But the idea

13 that your hydrostatic mud weight needs to

14 be in line with your pore pressure, I mean,

15 that's just basic physics, isn't it?

Page 58:18 to 59:25

00058:18 A. I don't know how physics applies

19 to it necessarily.

20 Q. If you put something into the

21 well that is heavier --

22 A. Yes.

23 Q. -- than the pore pressure, it's

24 not going to want to rise up relative to

25 the gas, is it? It's going to want to

00059:01 sink?

02 A. There's, perhaps, other factors

03 in play. There's -- there's a certain

04 degree of uncertainty. I don't believe

05 it's that clear-cut.

06 Q. But in terms of what is

07 clear-cut, if your hydrostatic mud weight

13


08 is heavier or too high relative to your

09 pore pressure, you-all know that you're

10 likely to fracture the formation and send

11 mud into the formation as opposed to

12 getting returns?

13 MR. FIELDS:

14 Objection, form.

15 A. I don't know that I would say

16 likely.

17 Q. More likely?

18 A. There's an increased chance.

19 Q. Okay.

20 A. Yes.

21 Q. Conversely, you know that if

22 your hydrostatic mud weight is too low

23 relative to your pore pressure, you're

24 likely increasing the chances that the well

25 could flow?

Page 60:03 to 60:17

00060:03 A. It's not likely. There's other

04 factors. We are -- perhaps more likely.

05 Q. More likely.

06 A. I wouldn't say likely. I don't

07 want --

08 Q. So let me re-ask the question.

09 A. Okay.

10 Q. If you inject in mud with

11 hydrostatic mud weight that is too low

12 relative to the pore pressures that you are

13 encountering at a given depth, you are more

14 likely to cause a well to flow than if you

15 have that hydrostatic equilibrium with the

16 pore pressure, right?

17 A. Yes.

Page 61:10 to 61:15

00061:10 Q. Okay. In other words, what

11 you're saying is offshore wells don't have

12 to take any longer than drilling onshore?

13 A. There's a lot of factors that

14 determine the length of time it takes to

15 drill a well.

Page 61:20 to 61:22

00061:20 Q. And you got involved around

21 August or September of 2009; is that right?

22 A. Yes, sir.

Page 62:25 to 63:02

14


00062:25 Q. You have access to the well plan

00063:01 through your computers, right?

02 A. Sure. Yes, I do.

Page 63:11 to 64:25

00063:11 Q. Well, would you agree with me

12 that with respect to the well plan -- what

13 was the total depth that was supposed to be

14 achieved in the well plan?

15 A. 20,200 feet, what it was

16 permitted to.

17 Q. Okay. 20,200 feet. And was

18 there a given formation that was supposed

19 to be tested or explored at that

20 20,200 foot level?

21 A. Yes.

22 Q. What was the name of that

23 formation?

24 A. M56.

25 Q. Okay. And with respect to M56,

00064:01 what is the depth that M56 exists at?

02 A. I don't remember the exact

03 depth.

04 Q. Okay. Is it true that while

05 your primarily exploration zone is at

06 20,200 feet, there are other sands that

07 exist, as you're going down, that you also

08 want to test?

09 A. I don't believe that was the

10 case, no.

11 Q. Okay. In terms of the geology

12 program on the Macondo 252 -- I've read

13 e-mails about mud samples.

14 What's a mud sample?

15 A. I don't know what -- what

16 context. I would just say a sample is a --

17 a sample of -- of mud from -- from the

18 system.

19 Q. Okay. And why does -- why does

20 BP take canned mud samples at different

21 intervals on the way down?

22 MR. FIELDS:

23 Objection, form.

24 A. I'm not a geochemist. The

25 geochemist uses that data.

Page 69:05 to 69:17

00069:05 Q. What is a kick?

06 A. A kick is when hydrocarbons are

07 introduced into the wellbore.

08 Q. Is that the same thing of saying

15


09 that when my hydrostatic mud weight is too

10 low relative to pore pressure and the well

11 flows -- when the well flows, is that a

12 kick?

13 A. To my understanding.

14 Q. Okay. And a kick is a bad thing

15 for the same reasons that well flowing is a

16 bad thing?

17 A. Yes.

Page 70:03 to 70:19

00070:03 Q. Sure. A kick is a safety

04 hazard?

05 A. It can be.

06 Q. It can be a safety hazard for

07 the two reasons that we've discussed

08 before, one of them is it can create

09 environmental damage by polluting the Gulf

10 of Mexico, right?

11 MR. FIELDS:

12 Objection, form.

13 A. It can.

14 Q. The second is, is that you have

15 hydrocarbons coming up the wellbore under

16 pressure that are introduced onto the rig

17 itself which could be ignited by certain

18 ignition sources and cause a fire?

19 A. That's clearly a possibility.

Page 71:22 to 72:12

00071:22 And what I'm going to do

23 is, I'm just going to ask you to go to a

24 particular tab, and then we'll talk about

25 documents. And I'll start with Tab 59.

00072:01 A. 59?

02 Q. Yes, sir. This is an e-mail

03 chain between you and a lady named Tara

04 Kirkland from April 5 and 6 time frame.

05 Are you with me?

06 A. Yes, sir.

07 Q. If you would, on the lower

08 right-hand corner of each of the documents

09 there's a large Bates number. It says

10 BP-HZN-2179MDL00895056.

11 Do you see that?

12 A. Yes, sir.

Page 72:19 to 73:03

00072:19 Q. The first page is 5056. If you

20 would, start off with 5059, which is the

16


21 fourth page of the document.

22 Ms. Tara Kirkland, in the

23 middle of the page, writes you at 8:40 in

24 the morning on April the 6th. It says

25 she's with MudTech Services.

00073:01 Who is Tara Kirkland?

02 A. A girl I met at an industry

03 function.

Page 73:24 to 74:17

00073:24 Q. All right. If you go to Page 2,

25 which is 5057.

00074:01 A. Uh-huh.

02 Q. She asks -- well, she tells you

03 where her office is, in Gunspoint area.

04 You talk about that, and then you ask her

05 what do you do at work.

06 Are you with me?

07 A. That's -- yes.

08 Q. Okay. And if you go to Page 1,

09 she tells you a little bit about what she

10 does, and then she ends this e-mail at

11 9:57.

12 She says, what do you do at

13 your job?

14 And you respond to that at

15 3:26 in the afternoon on April the 6th; is

16 that right?

17 A. Yes, sir.

Page 75:19 to 76:22

00075:19 Sometime in the afternoon

20 on the 6th, you respond telling her what

21 you do at BP, right?

22 A. Yes, sir.

23 Q. Okay. And I want to start

24 reading from the fourth line where you say,

25 In reality, everyone mostly stands around

00076:01 and bullshits all day. That defines a

02 large chunk of what I do. From an actual

03 work standpoint, I work on a new wells

04 delivery team. We facilitate the drilling

05 of exploration oil and gas wells in the

06 deepwater Gulf of Mexico. I'm basically

07 attached to a rig, and I follow it from

08 well to well.

09 Are you with me so far?

10 A. Yes, sir.

11 Q. Okay. The rig that you were

12 attached to, following it from well to

13 well, was that the MARIANAS well -- rig?

14 A. Yeah, it -- it was the MARIANAS,

17


15 yes.

16 Q. Okay. I manage a lot of the

17 partner interactions as well as manage

18 third-party contractors that provide us

19 service on the wellsite. In terms of the

20 partner interactions on the Macondo 252#1,

21 BP was the operator of that well, right?

22 A. Correct.

Page 78:02 to 79:19

00078:02 Q. What third-party contractors did

03 you interact with?

04 A. I interacted with the -- the

05 mudloggers.

06 Q. Which were who?

07 A. Sperry-Sun.

08 Q. Okay. Anybody else?

09 A. LWD, MWD.

10 Q. What did they do?

11 A. Logging while drilling, measure

12 while drilling.

13 Q. Okay. Anybody else?

14 A. Schlumberger.

15 Q. What did Schlumberger do?

16 A. They were the wireline analysis.

17 Q. What is -- what is wireline

18 analysis?

19 A. They did the post -- after we

20 TD'ed, they -- they performed the

21 comprehensive reservoir evaluation after we

22 TD'ed the well.

23 Q. In the office, I act as an

24 intermediary between subsurface

25 (geologists) whom know nothing about

00079:01 drilling, and the drillers, who know

02 nothing about geology. I try to facilitate

03 communication between these two groups to

04 ensure that they have a mutual

05 understanding about each other's goals and

06 need for the well from a data acquisition

07 and performance standpoint. I'll also look

08 for ways to hi-grade, prioritize, or

09 optimize wellsite operations. Basically,

10 the rig we're using to drill the well cost

11 about $750,000 a day to operate, so

12 anything I can do to optimize anything can

13 save a lot of coin. Both of my degrees are

14 in geology, but since starting work, I've

15 found myself a lot more interested in

16 drilling, so this role suits me pretty

17 well.

18 Did I read that correctly?

19 A. Yes, Mr. Watts.

18


Page 81:24 to 82:04

00081:24 Q. Well, let me just ask you this:

25 Regardless of what the contingency is, what

00082:01 process does BP have in place whereby

02 anybody on your team, including a

03 29-year-old geologist, can make a decision

04 to change the well plan?

Page 82:07 to 84:03

00082:07 A. I don't have any decision-making

08 authority.

09 Q. Okay. Are there rules in place

10 as to who can change the well plan and

11 under what conditions?

12 A. I don't -- I don't know. That

13 is the role of the drilling team.

14 Q. Uh-huh.

15 A. The team I'm on provides input

16 as requested by the drilling team. The

17 decisions are made by the drilling

18 organization.

19 Q. Let me take you to Tab 1, which

20 is a Gulf of Mexico exploration and

21 appraisal communication plan,

22 September 2009, Revision 2.

23 Do you see that, sir?

24 A. Yes, sir.

25 Q. Do you know what a management of

00083:01 change is?

02 A. Yes.

03 Q. What is a management of change

04 at BP?

05 A. It's a process in -- in which

06 plans are -- are changed, and they're --

07 they're signed off on by the appropriate

08 decision-making parties.

09 Q. All right. This document is

10 several hundred pages long. And what I've

11 done in our tab is just put the pages that

12 I want to ask you about. And we can pull

13 out the big one if anybody's got any other

14 questions. But I don't think this will

15 take long. Go to Bates Number 71995, the

16 second page.

17 Do you see how it defines a

18 Tier 1 decision?

19 A. Yes.

20 Q. A Tier 1 decision is made within

21 the plan, minimal potential impact on

22 operations. And it gives examples, like

23 bit selection, minor mud weight changes,

24 this kind of thing; is that right?

19


25 A. That's what it says.

00084:01 Q. And then it will define who

02 makes the decision on a Tier 1 management

03 of change; is that right?

Page 84:06 to 84:22

00084:06 A. That's what it says on this

07 form.

08 Q. Go to the next page, Bates

09 71997. It's a Tier 2 decision.

10 A Tier 2 decision is made

11 outside the plan. It has an estimated

12 potential impact of less than $2 million of

13 unplanned activity or moderate potential

14 impact on quality. And then it's got a

15 couple of examples of Tier 2 decisions,

16 including cement casing early due to lost

17 returns and significant changes to the mud

18 weight program yet within the min-max

19 range.

20 Are you with me?

21 A. That's what it says here, yes.

22 I'm with you.

Page 85:25 to 86:08

00085:25 Q. Right. Now, it says significant

00086:01 changes to the mud weight program yet

02 within the min-max range.

03 What is the min-max range?

04 A. The individual or individuals

05 that construct the pore pressure forecast

06 define a depth versus a pressure curve.

07 They define a minimum, a most likely, and a

08 maximize curve.

Page 89:19 to 89:23

00089:19 Q. Okay. You knew that if the

20 static mud weight was lower than the

21 estimated pore pressure, that that can

22 cause the well to flow and cause a blowout,

23 right?

Page 90:01 to 90:04

00090:01 A. In some instances. There's

02 other factors. But, yeah, that's one of

03 the factors that can cause the well to

04 flow.

20


Page 90:12 to 90:17

00090:12 Q. Sure. If BP injects mud where

13 the static mud weight is lower than it

14 should be relative to the pore pressure,

15 that can result in the well flowing and a

16 blowout occurring that was induced by BP's

17 selection of the mud weight?

Page 90:20 to 91:03

00090:20 A. That can influence it.

21 Q. Okay.

22 A. It's not -- unless you have a

23 porous, permeable medium that's capable of

24 flowing that it can be flow.

25 Q. Okay. So just so that we're

00091:01 clear. Kicks, they aren't just something

02 that happen. They can be caused by mud

03 weight selection of people drilling. True?

Page 91:06 to 92:21

00091:06 A. In some instances.

07 Q. And good mud weight selection

08 can prevent kicks that would otherwise

09 occur but for the choice of an optimal mud

10 weight relative to the pore pressure,

11 right?

12 A. In some instances.

13 Q. Okay. Now, let's go back to

14 this document.

15 In terms of the Tier 2

16 decision, were you familiar with the

17 difference between a Tier 1 and a Tier 2

18 decision from the standpoint of BP's

19 management of change?

20 A. No, I wasn't.

21 Q. Let's go to the next page, which

22 is a Tier 3 decision. This is something

23 that has an estimated potential impact of

24 2' to $5 million of unplanned activities.

25 Are you with me?

00092:01 A. Yes, sir.

02 Q. Examples of a Tier 3 decision

03 would be a sidetrack versus -- versus

04 fishing following a stuck pipe.

05 That actually occurred

06 during the drilling of the Macondo 252#1,

07 right?

08 A. Yes, sir.

09 Q. You-all went down to a certain

10 depth. There was a kick. There was stuck

11 pipe. There was a decision made instead of

21


12 trying to dig the pipe out, that you-all

13 would drill a sidetrack well to just go

14 around it; is that right?

15 A. The drilling team made that

16 decision, yes.

17 Q. And that is a so-called Tier 3

18 decision that has to be made by a certain

19 level of management, according to this

20 exploration and appraisal communication

21 plan, right?

Page 93:04 to 93:13

00093:04 Q. Okay. In terms of the Tier 3

05 decision, there's something called remedial

06 cement jobs.

07 What is a remedial cement

08 job?

09 A. When your primary cement job was

10 insufficient.

11 Q. They've got to go back and do it

12 again?

13 A. Yes.

Page 93:24 to 94:08

00093:24 Q. Okay. Squeezes. What is a

25 squeeze?

00094:01 A. I know it to be a form of a

02 remedial cement.

03 Q. Your cement job is not good or

04 it didn't work, and so you have to do a

05 squeeze. That's kind of a remedial process

06 to try to fix a cement job that didn't

07 work, right?

08 A. That's how I understand it.

Page 94:17 to 95:09

00094:17 Q. Do you -- do you have a

18 rudimentary understanding of how a squeeze

19 is performed?

20 A. Yes, I do.

21 Q. Give me that.

22 A. Cement is pumped to the bottom

23 of the well. The well is pressured up.

24 And I understand that cement is squeezed or

25 displaced into voids that may have existed

00095:01 in the first cement job, is my

02 understanding, but I'm not -- this is not

03 my area of understanding.

04 Q. Okay. We talked about remedial

05 cement jobs and squeezes. Programs

22


06 following major losses. That would be the

07 lost mud that you and I talked about when

08 the formation is fractured and you're not

09 getting the mud back, right?

Page 95:12 to 97:07

00095:12 A. At which time?

13 Q. Well, at any time. I mean

14 that's what a loss is, a lost return,

15 right?

16 A. Yes, sir.

17 Q. Okay. Do you know what is

18 considered a major loss such that it's a

19 Tier 3 decision from the standpoint of BP's

20 management of change?

21 A. I -- I don't know what volume of

22 mud they would consider to be major.

23 Q. What would you consider to be a

24 major loss of mud in a program?

25 A. I don't -- I don't know.

00096:01 Q. Okay. Next page. Tier 4 is a

02 decision made with a potential impact of

03 greater than $5 million of unplanned

04 activities.

05 Are you with me?

06 A. Yes, sir.

07 Q. For example, a decision early

08 total depth, TD, of the well or individual

09 hole-sections.

10 You know what total depth

11 is, or TD; is that right?

12 A. I do.

13 Q. What is TD as it is defined in a

14 well plan?

15 A. The depth at which you cease to

16 drill any further.

17 Q. Okay. The planned TD or total

18 depth for this well, you mentioned earlier,

19 it's something on the order of 20,200 feet;

20 is that right?

21 A. That's correct, sir.

22 Q. There was a decision that I know

23 you were involved in, to not go down to the

24 first planned total depth but to cease

25 drilling at an area in the hole that's

00097:01 higher up; is that right?

02 A. That is correct.

03 Q. That decision is a Tier 4

04 management of change decision?

05 A. Yes, sir.

06 Q. And that is a decision that is

07 made by whom?

23


Page 97:10 to 97:14

00097:10 A. It says on this document in

11 front of me, the wells manager of E&A

12 operations.

13 Q. Do you know who that is?

14 A. I don't.

Page 98:16 to 98:21

00098:16 Q. Let's go to the next page.

17 Tier 5 decisions are

18 emergencies with respect to fire or

19 hydrocarbon releases or major spills; is

20 that right?

21 A. That's what this document says.

Page 99:23 to 100:08

00099:23 Was this management of

24 change communication process ever delivered

25 to you as you began your work in the well

00100:01 planning?

02 A. No, sir.

03 Q. Let's go to the well plan

04 itself.

05 I asked you before in the

06 well plan how deep was it intended to go,

07 and you told me 20,200 feet; is that right?

08 A. Yes, sir.

Page 101:22 to 102:02

00101:22 Q. All right. Your e-mail to

23 Ms. Kirkland said, hey, it cost $750,000 a

24 day. You're saying, hey, I don't really

25 know that. You may have been puffing or

00102:01 something like that?

02 A. Yeah.

Page 103:16 to 104:08

00103:16 Q. Okay. Now, I want to go to the

17 middle of October. And if you go to Tab 2,

18 please. It's Bates Page 884526. This is

19 an e-mail written by a George Gray to Earl

20 Fly.

21 A. Yes, sir.

22 Q. Importance. High.

23 Do you know who Earl Fly

24 is?

25 A. Yes, I do.

00104:01 Q. Who is he?

24


02 A. He works for Sperry-Sun.

03 Q. And George Gray, who does he

04 work for?

05 A. He formerly worked for BP.

06 Q. Was -- what group was he in?

07 A. He was with the drilling

08 organization.

Page 104:14 to 104:23

00104:14 Q. Okay. George tells Earl, I'm

15 out here on the MARIANAS. Alex is not

16 getting the job done for the team.

17 Who is Alex?

18 A. Alex was a mudlogger.

19 Q. For which company?

20 A. For Sperry-Sun.

21 Q. So BP is telling Sperry-Sun that

22 its mudlogger is not getting the job done

23 for the team, right?

Page 105:03 to 105:06

00105:03 A. Can I have a second? Let me --

04 I want to read this entire -- entire

05 document before I speak on behalf -- is

06 that -- is that okay, Mr. Watts?

Page 105:19 to 105:22

00105:19 Q. All right. George Gray of BP is

20 telling Earl Fly of Sperry-Sun that its

21 mudlogger, Alex, is not getting the job

22 done for the team; is that right?

Page 105:25 to 106:16

00105:25 A. That's what it says here.

00106:01 Q. We have real concerns as we are

02 less than two weeks from drilling into a

03 zone that can be anywhere from high losses

04 to a well control situation.

05 Did I read that correctly?

06 A. That's -- yeah, you read --

07 that's what you read on this document.

08 Q. Now, we're in the middle of

09 October. BP has begun it's drilling. It's

10 less than two weeks from drilling into a

11 zone that could be anywhere from high

12 losses to a well control situation. This

13 was copied to you on October the 14th at

14 the top of the page.

15 Do you see that?

25


16 A. Yes, sir.

Page 107:08 to 107:13

00107:08 You were working with Alex

09 at the time, right?

10 A. I know who Alex is, yeah.

11 Q. And -- and he was pulled off the

12 rig?

13 A. I believe he was, yes, sir.

Page 107:18 to 109:19

00107:18 Q. Tab 5. They're not going to be

19 in order. I'll try to tell you where we're

20 going.

21 Tab 5 is an e-mail that you

22 wrote on October the 21st to three

23 gentlemen. One is Martin Albertin.

24 Who is Mr. Albertin?

25 A. Martin Albertin is a

00108:01 geophysicist on my team.

02 Q. We got Kate Paine with QuaDril

03 Energy LT and Craig Scherschel.

04 Who is Craig Scherschel?

05 A. Craig Scherschel is also on the

06 Tiger Team. He is a shallow hazards

07 assessor.

08 Q. And Jorge Viera. Who is that?

09 A. Jorge Viera is a wellsite

10 geologist.

11 Q. What is the so-called Tiger

12 Team?

13 A. The Tiger Team is a group of

14 individuals that specializes in providing

15 specialized input that is used to deliver

16 wells.

17 Q. Specialized input with respect

18 to what?

19 A. For example, we have individuals

20 that are operations geologist, such as

21 myself.

22 Q. Yes, sir.

23 A. We have two other operations

24 geologists on my team that perform a

25 similar role. We have geologists that do

00109:01 pore pressure predictions from various

02 methodologies. We have basin modelers that

03 do broader -- that understand the scale --

04 broader scale basin -- understand the

05 broader scale of geology. We have

06 biostratigraphers who look at nannofossils

07 to try to figure out what age different

08 cuttings are from, to try to figure out at

26


09 which -- at what depth or what age we're --

10 we're drilling in.

11 Q. Okay.

12 A. And we also have an individual

13 that does shallow hazard mapping. So the

14 top few thousand feet of -- of section to

15 be drilled, he will -- this -- this fellow

16 here, Craig Scherschel, will analyze the

17 area right below -- right above a prospect

18 for any potential problems that he -- he

19 foresees.

Page 110:22 to 111:01

00110:22 Q. Right.

23 A. So my team, the Tiger Team is

24 not -- not concerned with -- with -- not

25 wholly concerned with personnel issues on

00111:01 the rig.

Page 111:20 to 112:02

00111:20 Q. Let's go to Tab 5. This is an

21 e-mail that you wrote October the 21st.

22 It's entitled Macondo well flow event.

23 You-all had a well flow

24 event in the middle of October of 2009 that

25 you analyzed; is that right?

00112:01 A. Could I have a -- just a moment

02 to look at this e-mail string?

Page 112:13 to 113:01

00112:13 Q. The subject matter of your

14 e-mail is Macondo well flow event, right?

15 A. Yes, sir.

16 Q. You write, I agree. It seems

17 like we're tip-toeing the underbalanced

18 line at a 9.0 to a 9.2?

19 A. Uh-huh.

20 Q. What is an underbalanced line?

21 A. I take that as the -- the

22 estimated pore pressure at -- at that

23 depth.

24 Q. Okay. Underbalanced. When a

25 well becomes underbalanced, can the well

00113:01 flow?

Page 113:04 to 116:01

00113:04 A. It can.

05 Q. When you were underbalanced, you

06 can have a well flow event, right?

27


07 A. It's possible you can.

08 Q. It seems like we're tip-toeing

09 the underbalanced line at a 9.0 to a 9.2.

10 A 9.0 to a 9.2 refers to

11 the hydrostatic mud weight, right?

12 A. Yes. I believe that's what I

13 was referring to.

14 Q. When we circulated out the

15 cuttings after total depth and our ECDs

16 dropped, we saw a bit of flow.

17 What's an ECD?

18 A. Equivalent circulating density.

19 Q. And after the ECD is dropped, we

20 saw a bit of flow. If the pore pressure

21 was a 9.9 EMW --

22 What is EMW?

23 A. Equivalent mud weight.

24 Q. If the pore pressure was a 9.9

25 equivalent mud weight, you'd think we'd

00114:01 have an underwater old faithful?

02 A. Yeah.

03 Q. In terms of underwater old

04 faithful, are you saying that that would be

05 the result of fracturing the formation? Is

06 that what you're referring to here?

07 A. No.

08 Q. What are you referring to when

09 you say you'd have an underwater old

10 faithful?

11 A. We are in open water section

12 here, not risered up at this point. So we

13 have -- we've set the -- the surface

14 casings. So when we're drilling, we're

15 drilling with seawater, and then we're

16 drilling with -- with water-based mud. And

17 as we're pulling down, the returns are

18 coming back to the seabed. So we're

19 drilling with -- so typically, when we have

20 a flow at that depth, it's water.

21 So what I'm referring to is

22 when you have -- when we're drilling the

23 open water section, we'll have an ROV down

24 next to the wellhead, and we're trying to

25 look at the wellhead on connection to see

00115:01 if there's any flow. We don't want flow

02 because it has -- that -- that -- in the

03 open water section, a water flow has

04 implications of the stability of -- of the

05 casing string that are, essentially, at

06 this point, sitting in less than

07 consolidated shallow sediments.

08 Q. Sure.

09 A. So we're trying to -- we're

10 trying to -- trying to combat what we think

11 is the incipient onset of pore pressure

28


12 increase. So in the first shallow section,

13 everything is hydrostatic up until a point,

14 and then pore pressure starts to come up.

15 So when pore pressure starts to come up, we

16 start pumping a little bit of a heavier

17 water-based mud to try to prevent that --

18 that shallow water flow which could

19 cause -- which could jeopardize our -- our

20 incipient first couple of casing strings.

21 Q. And this well flow event

22 resulted when you had mud losses at that

23 point in time on that day?

24 A. We didn't have mud losses --

25 Q. Let's go to --

00116:01 A. -- I don't believe.

Page 117:07 to 117:15

00117:07 Q. Start with Tab 5. It's -- the

08 e-mail is October 21 that you wrote.

09 A. October 21st.

10 Q. Okay.

11 A. Yep.

12 Q. Now, if you look down at the

13 bottom of the attachment on Tab 89, we're

14 looking at stacked sieve data on

15 October 21.

Page 117:17 to 117:17

00117:17 A. Okay. So --

Page 117:19 to 118:12

00117:19 October 22nd? Oh, I see.

20 21. Okay.

21 Q. No. Down at the bottom.

22 A. Yep.

23 Q. Way bottom.

24 A. Way bottom.

25 Q. There you go. October 21, '09,

00118:01 right?

02 A. Yep.

03 Q. That's the same day that the

04 e-mail that you wrote about the Macondo

05 well -- well flow event, right?

06 A. Yeah. There -- they're the same

07 date.

08 Q. Okay.

09 A. I'm just struggling to figure

10 out how these two -- I've never seen this

11 document. I'm just struggling to

12 conceptualize how they're connected.

29


Page 121:02 to 121:07

00121:02 Q. Does that describe what happened

03 when you had the well control event back in

04 October of 2009?

05 A. These -- this e-mail, Tab 5,

06 refers to the open water flow event before

07 we set our riser.

Page 122:09 to 122:12

00122:09 A. So there's a little confusion

10 about 22-inch casing versus the 22-inch

11 hole. So this 5 is -- is kind of

12 temporarily disconnected from 89.

Page 123:04 to 125:09

00123:04 Q. That's all right.

05 So when we look at Tab 5,

06 we had a Macondo well flow event on October

07 the 21st, right?

08 A. Yes, sir.

09 Q. Okay. When we look at Tab 89

10 and they're looking at October 21 sieve

11 data, they're talking about 431 barrels

12 lost during this Macondo 22-inch open hole

13 mud loss event, right?

14 A. One thing -- one thing is for

15 sure, when you're in open water, you --

16 you -- everything is lost. You have no

17 returns. So you can't quantify mud loss in

18 open water where all your -- where

19 everything is going back to the seabed.

20 Q. No, I get you. You're saying

21 the temporarily disconnect issue?

22 A. Right.

23 Q. But what I'm saying is, when we

24 have the 22-inch open hole mud loss, we

25 lost 431 barrels; is that right?

00124:01 A. That's -- that's what this said.

02 Q. Okay.

03 A. I -- I didn't perform the

04 analysis. I don't have the data. But this

05 is what -- it appears this is what

06 Mr. LeBleu is saying.

07 Q. Let's go to Tab 6, please. And

08 I'd like to start you with an e-mail that

09 you wrote on the bottom of Page 2. This

10 e-mail is October 22nd. It's an e-mail

11 from you to Kemper Howe and Bryan Ritchie.

12 Who are they?

13 A. Kemper Howe is the -- he's the

30


14 commercial land negotiating team lead.

15 Q. Now, they're saying we're

16 looking for a few drilling reports from the

17 exploration -- the original exploration

18 well at Rigel, top hole location MC 252,

19 bottom hole location, MC 296. It was

20 originally drilled by Texaco.

21 A. Yes, sir.

22 Q. We think they took a kick and

23 stuck their BHA.

24 What's a BHA?

25 A. A bottom hole assembly.

00125:01 Q. On around October the 13th of

02 1999. We are trying to discern the

03 sequence of events that led up to the stuck

04 pipe issue. We're currently drilling

05 through the same interval on the Macondo

06 well and are having some operational

07 issues.

08 Are you with me?

09 A. Yes, sir.

Page 129:07 to 129:25

00129:07 Q. All right. In October, the way

08 that the author of the previous e-mail knew

09 you were two weeks away from going through

10 a troublesome zone, is that you were going

11 through a zone that Texaco had previous --

12 I mean, Texaco has previously gone through

13 that caused a kick where they stuck their

14 pipe, right?

15 MR. FIELDS:

16 Objection, form.

17 A. Yes. The -- the comparable

18 stratigraphy that we were drilling through,

19 we noticed in a scout ticket that there was

20 an issue on an adjacent well that we wanted

21 to further investigate.

22 Q. You guys were having a well

23 control situation or, at the very least,

24 a -- a mud loss incident of some sort at

25 this time, right?

Page 130:03 to 130:05

00130:03 Q. You had a well flow event of

04 some kind?

05 A. Yes.

Page 130:23 to 135:01

00130:23 Q. October 26th, his second

31


24 e-mail -- I mean his e-mail that you're

25 copied on, BP request for MC 252, MC 292

00131:01 drilling information. My other issue with

02 Eni trying to hammer us with a forced trade

03 when we have a well drilling that is in

04 trouble and we need an old well's drilling

05 info from the area to help us get us past a

06 troublesome zone.

07 Did I read that correctly?

08 A. Yes, sir.

09 Q. All right. In the middle of

10 October, we've already gone through two

11 documents with respect to this, either mud

12 loss incident or well flow incident.

13 Mr. Staggs, that's a BP

14 person, right?

15 A. Mr. Staggs does work for BP.

16 Q. And he says, We got a well

17 that's in trouble.

18 That's what this says,

19 right?

20 A. That's what this e-mail you put

21 in front of me says, yes, sir.

22 Q. All right. And so we're in the

23 middle of October. We're going through a

24 troublesome zone. Mr. Staggs says we've

25 got a well that's in trouble, and you guys

00132:01 are seeking information from Texaco to help

02 you learn how it is that you can get the

03 well out of trouble, right?

04 MR. FIELDS:

05 Objection, form.

06 A. I don't -- this -- trouble is

07 the word that Mr. Staggs used. Mr. Staggs

08 is a non-technical person. He's a scout.

09 Q. You guys were having a rough

10 time?

11 A. We had an incident.

12 Q. You were having a rough time?

13 A. We were having trouble, sure.

14 Q. Go to Tab Number 7. You wrote

15 an e-mail on October the 29th to a

16 Christopher Casler.

17 Who is Christopher Casler?

18 A. He was -- he was a geologist

19 that was -- that was -- helped work -- work

20 up the prospect before -- before he -- he

21 moved out of the team before the well was

22 drilled. So he was just knowing -- he knew

23 that I was with the team, so he wanted to

24 see how -- how the well, that he helped

25 plan, was progressing.

00133:01 Q. Yeah. And so down at the bottom

02 he's kind of like, you know, que paso on

03 Macondo. What's going on on Macondo,

32


04 right?

05 A. Yes.

06 Q. And you answer, We're at the

07 18-inch casing point now -- right now and

08 running the hole with casing. We had a,

09 quote, rough time --

10 A. Yep.

11 Q. -- this past hole-section. Got

12 a shitty leak-off test, tried to tip-toe

13 around some of the charged sands and got

14 bit. We took a small kick, but we were

15 able to kill the well, drill ahead past the

16 sand where we took the kick, and set our

17 18-inch casing in a shale. We had to set

18 our 18-inch casing well short of the

19 planned depth because of the shitty

20 leak-off test, but hopefully we can get a

21 good LOT at a 18-inch shoe since we're in a

22 shale now, and be able to get to our

23 planned 16-inch casing depth and get back

24 on track. I'll forward you updates

25 periodically. Chuck is working it as well.

00134:01 Did I read that correctly?

02 A. Yes, sir, you did.

03 Q. Let me get you to decipher some

04 of that.

05 A. Okay.

06 Q. We're at the 18-inch casing

07 point right now and running in the hole

08 with casing.

09 A. Yes sir.

10 Q. We had a rough time this past

11 hole-section.

12 The rough time is what

13 we've been talking about with respect to

14 the well flow event and the mud being lost,

15 this kind of thing, right?

16 A. Yeah. I wasn't privy to the --

17 the mud loss portion. I knew we took -- we

18 took a kick at that depth. John LeBleu,

19 he's -- he's the drilling fluid engineer.

20 The fact that the mud loss thing, it's --

21 that was -- that was kind of news to me. I

22 didn't know that detail of the event.

23 Q. So at the time that you're

24 writing this e-mail, you were not aware

25 that you-all had lost 431 barrels of mud in

00135:01 this mud loss event?

Page 135:04 to 135:24

00135:04 A. I was not, to my knowledge.

05 Q. So you had a rough time?

06 A. Uh-huh.

07 Q. You got a shitty leak-off test.

33


08 What's a leak-off test?

09 A. A leak-off test is -- the

10 leak-off test I'm referring to in this

11 e-mail is a leak-off test that was at the

12 22-inch casing shoe.

13 Q. Yep. And when you say you got a

14 shitty test, that wasn't done improperly,

15 you got a shitty result?

16 A. The result was less desirable.

17 Q. Correct.

18 A. In general, the higher the

19 leak-off test you get, the more desirable.

20 If you don't achieve what you want, that's

21 what I commonly refer to as a -- as a --

22 the colorful adjective I used. And I

23 apologize. I am embarrassed sitting in

24 front of it now.

Page 136:12 to 136:18

00136:12 Q. You got a shitty leak-off test.

13 You tried to tip-toe around some charged

14 sands.

15 Now, this is the same

16 discussion that we had earlier with respect

17 to tip-toeing with the 9.0 and the 9.2. Do

18 you remember that e-mail?

Page 136:21 to 136:23

00136:21 A. That -- this is a -- this is a

22 different hole-section. This is the --

23 this is the next hole-section.

Page 137:05 to 138:17

00137:05 Q. Tab 5. It seems like we're

06 tip-toeing the underbalanced line at 9.0 to

07 9.2 --

08 A. I used the term "tip-toeing" in

09 two different senses.

10 Q. Yeah. So here you're saying we

11 tried to tip-toe around some charged sands.

12 What that means is that your pore pressure

13 was higher than expected.

14 That's a charged sand,

15 right?

16 A. That doesn't necessarily mean --

17 charged means that it could -- it could

18 have hydrocarbon charge. It doesn't have

19 any -- it doesn't have any connotation as

20 it being overpressured.

21 Q. With respect to tip-toeing

34


22 around some charged sands, what's the

23 connotation there?

24 A. Tip-toeing is we -- we were

25 control drilling. We saw the sands on the

00138:01 seismic. We knew that the seismic

02 amplitude at that -- at that interval

03 could -- could potentially indicate that

04 there was sand there.

05 Q. So you tip-toed around it. Does

06 that mean you're modulating your mud weight

07 as you go through it?

08 A. We are control drilling and

09 doing -- performing periodic flow checks.

10 We are trying to -- we're trying to get a

11 better assertation of the pore pressure

12 regime. A lot of the pore pressure --

13 Q. So you don't know what the pore

14 pressure is?

15 A. A lot of the indicators are all

16 going to be qualitative. They're not going

17 to be --

Page 139:01 to 139:17

00139:01 A. No worries.

02 A lot of the pore pressure

03 indicators aren't necessarily silver

04 spikes. They're going to be very

05 qualitative.

06 Q. Right.

07 A. So when I say we are tip-toeing

08 here, as we were. We're taking our time.

09 We were being diligent, and we are trying

10 to get a better sense of what our pore

11 pressure was at that particular juncture.

12 Q. We are tip-toeing around some

13 charged sands, and we got bit.

14 When we get bit, is that a

15 kick?

16 A. Yes, sir. And that's what I was

17 referring to in this case.

Page 140:03 to 141:03

00140:03 Q. Okay. Let's go to the next

04 document, Exhibit 11 -- or Tab 11, please.

05 This is an e-mail that you

06 wrote in January with an attachment,

07 Macondo 18-inch casing section review?

08 A. Uh-huh.

09 Q. And you say, Here's a slidepack

10 I put together a while back outlining the,

11 quote, festivities, close quote, of the

12 18-inch casing section?

35


13 A. Yep.

14 Q. Might serve as a good refresher

15 as we get ready for resuming Macondo.

16 Let's go to the attachment.

17 This is an attachment slide --

18 A. This is on --

19 Q. The attachment is in Tab 4. I

20 apologize.

21 A. Tab 4?

22 Q. Yes, sir.

23 A. Okay.

24 Q. This is a PowerPoint that you

25 put together outlining what went wrong

00141:01 during the drilling operations from

02 October 21 to October 28th of 2009, right?

03 A. Yeah. And this --

Page 141:06 to 142:03

00141:06 A. -- actually, right here, the

07 hole size, the 18-inch by 22-inch.

08 Q. Yep.

09 A. That kind of explains the

10 ambiguity between the two hole-sections.

11 Q. Okay. Go to Section 2 of the

12 PowerPoint.

13 A. Yep.

14 Q. We talked about the leak-off

15 test that you colorfully talked about in

16 the other e-mail.

17 A. Absolutely.

18 Q. We had drilling 18-inch --

19 18 and 1/8-inch times 22-inch hole with

20 narrow drilling window.

21 What's a narrow drilling

22 window?

23 A. A narrow drilling window is

24 where our pore pressure -- our estimated

25 pore pressure and our estimated frac

00142:01 gradient are close -- are -- are close in

02 value, maybe, relative to other

03 hole-sections.

Page 142:18 to 143:11

00142:18 Q. We're talking about a

19 hole-section?

20 A. Yeah.

21 Q. Where the pore pressure and the

22 frac gradient are close enough that you

23 have a low margin for error relative to

24 other areas where the spread is more?

25 MR. FIELDS:

00143:01 Objection, form.

36


02 A. Okay.

03 Q. Agree?

04 A. Okay. Yes.

05 Q. All right. You had a well

06 control event, a kick at 8970 feet, right?

07 A. Yes, sir, we did.

08 Q. You made a decision to drill

09 ahead past the kick interval to the total

10 depth hole-section in the shale, right?

11 A. Yes, sir.

Page 145:09 to 147:05

00145:09 Q. Go to Page 10.

10 Now, you-all had this kick,

11 the team was faced with the decision on

12 whether to drill ahead past the interval

13 that caused the well control event. And

14 then your outline says that you can either

15 stop and set the casing at the current

16 depth, or you can drill ahead approximately

17 a hundred feet in order to set 18-inch

18 casing shoe below the problematic sand

19 interval?

20 Do you see that?

21 A. Uh-huh. I do.

22 Q. Now, the reward of stopping and

23 setting casing at the current depth was to

24 avoid another, potentially uncontrollable,

25 well control event.

00146:01 Do you see that, sir?

02 A. Under risk or --

03 Q. Under reward of stopping and

04 setting casing it says, Reward. Avoid

05 another, potentially uncontrollable, well

06 control event.

07 Did I read that right?

08 A. Yes, sir.

09 Q. Stick BHA sidetrack and lose

10 well?

11 A. Yes, sir.

12 Q. That would be the reward. You

13 get rid of that risk by stopping and

14 setting the casing at the current depth,

15 right?

16 A. Yes, sir.

17 Q. The other option was to drill

18 ahead approximately a hundred feet in order

19 to set 18-inch casing shoe below the

20 problematic sand interval, and the risk of

21 that would be to drill into another

22 overpressured sand package that would

23 initiate a potentially uncontrollable well

24 control event.

25 Stick the BHA and lose the

37


00147:01 well, right?

02 A. Yes, sir.

03 Q. The team decided to go ahead and

04 drill ahead that extra hundred feet, right?

05 A. Yes, sir. That -- we did.

Page 147:19 to 147:22

00147:19 Q. The Macondo 252#1 drilling

20 process got interrupted with Hurricane Ida,

21 correct?

22 A. That is correct, sir.

Page 149:04 to 149:05

00149:04 Q. And if you go to page -- to Tab

05 9, this is an e-mail that you wrote --

Page 150:17 to 151:05

00150:17 Q. Okay. You say you're doing some

18 mapping, scary I know, for Brian's team for

19 eastern lease sale to keep me busy,

20 employed. The entire floor seems to be

21 obsessed with giving each other vice

22 presidential titles, since apparently most

23 everyone in the organization has been named

24 a VP in recent days. It's quite comical.

25 We all have our titles on our white boards.

00151:01 I'm the vice president of geological

02 operations for moored drilling vessels.

03 That's what you wrote,

04 right?

05 A. I did.

Page 152:09 to 152:18

00152:09 Q. Do you know whether any

10 alternative deepwater drilling rigs were --

11 were considered before the DEEPWATER

12 HORIZON was selected?

13 A. Not to my knowledge.

14 Q. Did you have any role in

15 evaluating whether the crew of the

16 DEEPWATER HORIZON was capable of drilling

17 safely a well like this that was going down

18 to 20,200 feet in this field?

Page 152:21 to 153:24

00152:21 A. No, I wasn't. This -- this rig

22 and this crew on this rig were -- were

38


23 trial tested.

24 Q. Okay.

25 A. We -- we used the DEEPWATER

00153:01 HORIZON for the previous 16 exploration

02 wells we drilled in the Gulf of Mexico.

03 Q. And you had no problem with the

04 crew of the DEEPWATER HORIZON in any of

05 those 16 previous exploration wells, right?

06 A. I cannot speak on all 16. The

07 previous one that I was on the team and --

08 and closely associated with enough, I did

09 not have any problems, no.

10 Q. Okay. When did the DEEPWATER

11 HORIZON get on location such that the

12 drilling could continue?

13 A. It was the second week of

14 February, 2010.

15 Q. Hurricane Ida blew through such

16 that you had to evacuate the MARIANAS when?

17 A. It was late November.

18 Q. Okay. So you were -- you were

19 down part of the month of November, the

20 entire month of December, and January. And

21 you got back up and running late February?

22 A. That's correct.

23 Q. So approximately three months of

24 interruption as a result of Hurricane Ida?

Page 154:07 to 154:08

00154:07 A. But, yes, we were down three and

08 a half months.

Page 154:11 to 156:17

00154:11 When did you say the

12 drilling resumed with the DEEPWATER

13 HORIZON?

14 A. I believe it was second week of

15 February.

16 Q. Let me take you to Tab 14, which

17 is dated February the 12th of 2010.

18 A. Uh-huh.

19 Q. This is Bates Page

20 Number 888541.

21 A. Yep.

22 Q. Gord Bennett sends a status

23 report that says, Preparing for a squeeze

24 job. Comments, Attempted LOT tests. Due

25 to unsatisfactory results, the decision was

00155:01 made to perform a squeeze job.

02 Are you with me?

03 A. I am, sir.

04 Q. The hole depth is at 9,076 feet,

39


05 right?

06 A. Yes, sir.

07 Q. The bit depth is 8957.

08 When -- when he says

09 attempted LOT test. What is a LOT test?

10 A. A leak-off test.

11 Q. And when you performed the

12 leak-off test you got unsatisfactory

13 results. What did that tell you when you

14 had a leak-off test with unsatisfactory

15 results?

16 A. It can have ambiguous meanings.

17 Q. What is an unsatisfactory result

18 in a leak-off test? Does that mean you're

19 leaking?

20 A. The pressure value is lower than

21 anticipated.

22 Q. Okay. And so a decision was

23 made to perform a squeeze job. That is a

24 remedial procedure that's done after a

25 cement job, right?

00156:01 A. It can -- that -- that can be

02 one form of a squeeze, yes.

03 Q. And you ask him, Is this a

04 cement squeeze or LCM.

05 And he says, Cement. We

06 are POOH now.

07 A. That's an acronym for pulling

08 out of hole.

09 Q. Okay. And you say shit?

10 A. I did.

11 Q. All right. Because when you

12 have to do a squeeze job or a remedial

13 procedure to fix a cement job that didn't

14 work, you have to pull out of the hole and

15 it slows things down, right?

16 A. Yes, you do.

17 Q. That's not good news?

Page 156:20 to 157:22

00156:20 A. I was -- I was just

21 disappointed. I was -- you know, we had

22 been waiting three and a half months.

23 Q. Sure.

24 A. And here we are ready to get

25 back at it and we got an unsatisfactory

00157:01 leak-off test. So there's a couple of

02 ways -- I was asking him are we going to do

03 a cement squeeze or LCM, because if we

04 have -- if we use -- if we have a sand

05 exposed at our shoe, we do an LCM squeeze,

06 we can buy ourselves -- we can strengthen

07 that sand.

08 Q. Yep.

40


09 A. So I was just -- the cement

10 squeeze, it takes longer. It's -- it takes

11 longer when you have to pull all the way

12 out of the hole. It's the more full proof,

13 longer methodology and it takes longer.

14 I was just disappointed

15 that I'd been waiting three and a half

16 months to get back to activity and we were

17 going to be late -- delayed another couple

18 of days.

19 Q. Sure. Squeeze job delays, it

20 costs money. It's a Tier 3 decision

21 between two and five million of unplanned

22 activities, right?

Page 157:25 to 158:06

00157:25 A. According to that one document

00158:01 there. I don't know necessarily what --

02 what a squeeze job costs.

03 Q. But the bottom line is a squeeze

04 job or the need for it is a bummer because

05 it takes time and money and it slows down

06 the progress, right?

Page 158:09 to 159:02

00158:09 A. Yes, it does.

10 Q. All right. And so that led you

11 to respond in Tab 15, Bates Page Number

12 270472.

13 On February the 13th, the

14 next day, you write to Brian Morel. Thanks

15 for the shitty cement job, Trent.

16 A. I did. I wasn't -- this -- I

17 meant this as just kidding. Brian is a --

18 Brian is a friend of mine. Just

19 disappointed that we did get a poor

20 leak-off test. I wasn't sure that it was a

21 cement job. Like I said, you can get a

22 poor leak-off test -- there could be

23 several ways you can get a poor leak-off

24 test. A poor cement job is one of the

25 ways. And I used this expletive in this

00159:01 kidding statement when talking with a

02 friend at an expense of another co-worker.

Page 159:14 to 159:19

00159:14 Q. Let's talk about why you got

15 what you got. Go to Tab 26.

16 Now, this is an e-mail that

17 originally is sent to you. And you see the

41


18 subject says the event that started it all,

19 question mark?

Page 159:24 to 160:10

00159:24 Q. It's an e-mail from Albertin to

25 you. Subject line, the event that started

00160:01 it all, question mark.

02 Are you with me?

03 A. I am.

04 Q. If we go down to the preceding

05 e-mail, March the 8th. One of the things

06 that Mr. Albertin says to you is data from

07 2-17.

08 That's February 17th,

09 right?

10 A. Yep.

Page 160:25 to 166:04

00160:25 Q. Let's keep going. Data from

00161:01 2-17 --

02 A. A stand is a -- a stand is a --

03 I'm sorry to interrupt, but a stand is a

04 length of drill pipe to depth.

05 Q. Let me fix it. Data from 2-17,

06 February 17 --

07 A. Yeah.

08 Q. -- before drilling the last

09 stand --

10 A. Stand is correct.

11 Q. -- down from 12,242 to 12,350

12 seems like a likely candidate to explain

13 why the losses started when they did.

14 A. Uh-huh.

15 Q. Are you with me?

16 A. I am.

17 Q. Now, February 17th, did you-all

18 have losses that started within three,

19 four, five days of your leak-off test?

20 A. We are in different

21 hole-sections again.

22 Q. Okay.

23 A. Or as -- I just want to make

24 sure we were -- understand. The leak-off

25 test we were talking about previously was

00162:01 at our 22-inch shoe. This event at this

02 depth would be in our 16-inch hole-section.

03 So after we did a leak-off test, the

04 18-inch shoe. So we're in two -- we're in

05 a different hole-section now.

06 Q. So you had a squeeze job in the

07 22-inch section. You go down further,

08 you're in the 16-inch section --

42


09 A. Well, no. We -- we had a

10 squeeze job at the 22-inch shoe. We

11 drill -- we drill out of our 22-inch shoe,

12 set 18-inch casing, performed another

13 leak-off test, that we have not talked

14 about, at our 18-inch casing, and then

15 drilled this interval that is talked about

16 in this e-mail.

17 Q. This 16-inch casing?

18 A. Yes. This is the 16-inch --

19 this is the hole-section in which we put

20 the 16-inch.

21 Q. Okay.

22 A. So again, we're out of --

23 Q. I'm with you.

24 A. -- out of -- it's the next

25 hole-section in the previous e-mail.

00163:01 Q. I agree with you.

02 A. Okay.

03 Q. We're in the next hole-section?

04 A. Yes.

05 Q. You've got more losses in this

06 hole-section, right?

07 A. We do in this hole-section.

08 Q. If we look at the attachment,

09 Bates Page Number 284170, we see that

10 there's an ECD spike to 12 plus ppg right

11 before the losses began, right?

12 A. That's correct.

13 Q. ECD, again, is what?

14 A. Equivalent circulated density.

15 Q. What does that mean in English?

16 A. Basically what that means is,

17 our surface mud weight is what the mud

18 weight weighs at the surface. If you put

19 the same -- this is oil-based mud. If you

20 take the same -- say, we have a ten-pound

21 surface mud weight. We take that ten

22 pounds per gallon surface mud weight, take

23 it down to 12,000 feet. At 12,000 feet it

24 compresses, it becomes more dense. So a

25 10.0 pounds per gallon downhole static

00164:01 might be a 10.2. When we're actually

02 circulating, when we are pumping down the

03 drill stem, there's -- the hole is being

04 loaded up with cuttings that were generated

05 and there is also frictional factors at

06 play. So the -- the mud weight that the

07 rock is actually seeing, being subjected

08 to, is higher than the mud weight that

09 we're actually putting in the hole at

10 surface.

11 Q. Here it's more than 12, right?

12 A. Let me --

13 Q. You see where it says ECD spike

43


14 to 12 plus ppg?

15 A. That's what Mr. Albertin

16 suggests.

17 Q. All right. And he's saying that

18 you get downhole, you have an ECD spike to

19 12 plus ppg right before the losses began,

20 right?

21 A. That's what he's suggesting,

22 yes.

23 Q. And the hydrostatic mud weight

24 was less than 12 plus ppg at this point,

25 right?

00165:01 A. The hydrostatic mud weight was

02 less than the -- yes, it was.

03 Q. All right. And so what you had

04 is, you had a situation where your

05 hydrostatic mud weight was too low or too

06 high?

07 A. The hydrostatic -- I don't -- I

08 don't know.

09 Q. Well, did you fracture the

10 formation creating the losses?

11 A. The -- the 12 -- what Martin is

12 suggesting is the 12.12 plus is a data --

13 is a spike. So it's a spike in the ECD.

14 It's not necessarily what our hydrostatic

15 was.

16 Q. Okay.

17 A. So something operationally

18 caused that data spike. So it's not

19 necessarily what we were putting in the

20 well as our -- to control our hydrostatic.

21 It's -- something else happened to cause

22 that spike.

23 Q. But that spike being caused

24 created losses by fracturing a formation,

25 right?

00166:01 A. That's what Mr. Albertin is

02 suggesting. I don't know that for sure.

03 It's one data point. It could be -- it

04 could be noise.

Page 166:07 to 168:04

00166:07 Q. Let's go to Tab 17, Bates Page

08 Number 2974.

09 This is an e-mail that you

10 wrote on February 24th to Mr. Albertin,

11 right?

12 A. Yes. Give me a -- give me two

13 seconds to peruse this.

14 Okay. Mr. Watts.

15 Q. At Page 2, Mr. Wagner writes to

16 Mr. Albertin. I see from the PDW (sic)

17 that the gases started from a zone, while

44


18 pumping, where the ECD was 11.4 plus?

19 A. Okay.

20 Q. And then Albertin writes back,

21 So we now have 11.2 ppg from the surface

22 down to 8770, then 11.4 ppg surface from

23 8700 to TD. Things look stable, question

24 mark.

25 Are you with me?

00167:01 A. Yes.

02 Q. Does that give us 11.55 downhole

03 on bottom? Or do we decide to pressure was

04 a writ -- did we decide pressure was a bit

05 lower -- did we decide pressure was a bit

06 lower?

07 You answer at the top, Not

08 sure yet. We basically have a big-ass plug

09 of Form-A-Set in casing near the 18-inch

10 shoe, which probably has isolated -- has us

11 isolated from the nastiness below the

12 18-inch shoe.

13 Are you with me?

14 A. Yes, sir.

15 Q. Now, you're referring to the

16 nastiness where the losses occurred at the

17 section with the 16-inch casing, right?

18 A. I believe so. Yes.

19 Q. Now, nastiness is a phrase that

20 you use to describe --

21 A. As the lost zone.

22 Q. -- lost zone. Lost returns,

23 right?

24 A. Sure.

25 Q. Okay. And those were lost

00168:01 returns in the 16-inch casing area, right?

02 A. It was in the 16-inch

03 hole-section below the 18-inch casing shoe,

04 correct.

Page 168:12 to 169:09

00168:12 Q. Let me cancel the question. Let

13 me -- let me take you to Tab 19 and just

14 ask you directly. This is Bates Page

15 Number 3391. It's an e-mail that you wrote

16 on February the 25th of 2010.

17 You see where you say that

18 the --

19 A. Okay. Yeah.

20 Q. This was the depth where we took

21 the kick in -- near the base of the 18-inch

22 casing section?

23 A. Yes, sir. I apologize. I'm

24 getting casing size and hole size a little

25 bit --

00169:01 Q. All right.

45


02 A. -- a little bit misconstrued.

03 So if you can just bear with me.

04 Q. It's all right.

05 Where did we take the kick?

06 A. We took the kick at 90 -- 87 --

07 it was right -- it was right -- just above

08 where we ended up setting the 18-inch

09 casing.

Page 170:05 to 170:12

00170:05 Q. So what you're telling me is, is

06 first we had a situation where the

07 hydrostatic mud weight was too low and you

08 experienced a kick and well flow, and now

09 you've got it where it's too high and you

10 fractured the formation and sustained

11 losses in the 16-inch casing?

12 A. It may have been --

Page 170:15 to 171:14

00170:15 A. It may have been too low.

16 There's other things that go -- take -- are

17 a factor in either having a flow event or a

18 loss event. It's just not specifically

19 your hydrostatic mud weight. So there's

20 operational parameters that -- that could

21 be ongoing that could induce a kick or

22 losses. So in the second scenario, I don't

23 believe that the mud weight had anything --

24 that the mud weight that the BP engineers,

25 the rig was choosing to use, I don't

00171:01 believe that had anything to do with the

02 losses.

03 What I believe happened is

04 there were some -- something operationally

05 where we had to pack off and we searched

06 the bottom of the well, spiked the ECD, and

07 that may have -- it's -- it's really --

08 really not clear-cut as to whether or not

09 our -- our hydrostatic mud weight was

10 the -- was the silver spike in causing

11 losses.

12 Q. You may have had an operational

13 step that BP took that resulted in breaking

14 down the formation creating the losses?

Page 171:17 to 171:21

00171:17 A. I don't -- I do not know.

18 Q. Go to Tab 18. 18

And let's look

19 about -- what you were told about this.

46


20 This is Bates Number 6206.

21 A. Okay.

Page 172:02 to 173:17

00172:02 Q. Back to Page 1. Jianguo Zhang.

03 Who is Mr. Zhang?

04 A. He works in EPT, which stands

05 for exploration production technology.

06 He's -- you can see in his title there.

07 Q. Sure.

08 A. He's a rock mechanic specialist.

09 Q. Within BP?

10 A. Yes, sir.

11 Q. Based on the new information you

12 and Bob provided, I did further analysis on

13 the fracture characterization. It seems

14 that the induced fracture width is big,

15 about 4,000 microns. This helped to

16 explain why so many LCM pills did not work

17 efficiently even for the EZ-SQUEEZE with

18 size up to the 3,000 microns. It is very

19 difficult to explain why we had such

20 loss -- such big losses and not much flow

21 back if we just assumed that these losses

22 are caused by induced fractures. One

23 possible explanation is induced fractures

24 were generated at the early stage. Then

25 induced fracture are connected to the

00173:01 natural fractures, which caused big losses.

02 Have I read that right so

03 far?

04 A. Yes, sir, you have.

05 Q. When Mr. Zhang is talking about

06 induced losses, those are losses induced

07 either by the mud or the operations of BP,

08 right?

09 MR. FIELDS:

10 These induced fractures?

11 MR. WATTS:

12 Let me try it again.

13 Q. When it talks about induced

14 fractures, those are fractures that are

15 induced by either the mud that is pumped

16 down or the operations that are being

17 conducted by BP, correct?

Page 173:20 to 174:11

00173:20 A. Not necessarily.

21 Q. What is an induced fracture?

22 A. That is a fracture that is

23 caused by a drilling operation.

24 Q. And she -- Mr. Zhang -- then the

47


25 induced fractures are connected to the

00174:01 natural fractures, which caused big losses.

02 A. Uh-huh.

03 Q. Do you know what the big losses

04 were that were sustained?

05 A. Are you asking me for a volume

06 of mud that was lost?

07 Q. Right.

08 A. I -- I'm sorry, sir. I don't

09 have that figure. I may have had it --

10 been told at one point. I just don't

11 remember.

Page 175:05 to 175:17

00175:05 A. He's -- I don't -- I can't speak

06 for Mr. Bondurant. Mr. Bondurant is a

07 geologist, and he doesn't have -- he's not

08 intimately related with day-to-day

09 operations.

10 Q. Well, when you got this e-mail,

11 did you construe it to be he was drunk on

12 the job, or he was bummed out about the --

13 the formation breakdown?

14 A. I didn't construe anything.

15 It's just something he said. I don't -- I

16 haven't had a conversation with him about

17 it since. It's just --

Page 175:20 to 178:02

00175:20 Q. Okay. Let's go to Tab 21.

21 Bates Page Number 481787.

22 A. I'm sorry?

23 Q. Tab 21.

24 A. 21.

25 Q. And you see down at the bottom

00176:01 Mr. Michael Dunn sends out to about 60 or

02 70 people, including you, on that first

03 line, the DEEPWATER HORIZON updated

04 five-day planner. And he sent it out on

05 February the 28th?

06 A. Yeah. I have that in front of

07 me.

08 Q. Brett Cocales, at the top,

09 writes, Guys, just an FYI on this planner.

10 As I know, you are trying to plan other

11 operations around our finish date. Because

12 we had to set our 16-inch casing 1,000 feet

13 shallower than planned, it is very unlikely

14 we will TD this well with just one more

15 casing string as the five-day planner

16 shows.

17 Did I read that correctly?

48


18 A. You did.

19 Q. The fact that you had to set the

20 16-inch casing 1,000 feet shallower than

21 planned was a direct result of the kick

22 that you sustained during the 18-inch

23 casing, right?

24 A. I don't -- I don't know that for

25 sure.

00177:01 Q. Okay. You are familiar with the

02 fact that for some reason you had to set

03 the 16-inch casing 1,000 feet shallower

04 than planned, right?

05 A. I did -- I did know that, yeah.

06 Q. That is why I'm giving you guys

07 the heads up that the most likely case will

08 have an additional liner, 11-7/8, to finish

09 the well. So you will need to add one week

10 to the five-day planner time to get the

11 most likely timing. The planner is useful

12 for the earliest finish time which is

13 around March 25, but the most likely time

14 is around April 1 or later.

15 Did I read that correctly?

16 A. Yes, sir.

17 Q. The well plan did not assume a

18 kick would cause you to have to set the

19 16-inch casing 1,000 feet shallower than

20 planned, right?

21 A. Setting the 16-inch casing a

22 thousand foot shallower than planned was --

23 was -- was not in the base case, no.

24 Q. Okay. And that was a result of

25 well control problems you were having that

00178:01 you had to set the casing shallower than

02 planned?

Page 178:05 to 179:01

00178:05 A. That -- that may have been one

06 factor. I don't -- I don't under --

07 have --

08 Q. Okay.

09 A. -- complete knowledge as to the

10 breadth of factors that go into where the

11 drillers decide to set casing.

12 Q. When the drillers set casing

13 higher than was planned or not as deep,

14 than what Mr. Cocales is saying is, now

15 we're going to have to do an additional

16 liner than 11-7/8 in order to finish the

17 well, right?

18 A. Mr. Cocales is suggesting that

19 the -- the 11-7/8 contingency liner that

20 was not in the base case but was reserved

21 as contingency, would now have to be

49


22 implemented.

23 Q. Okay. And that would take time?

24 A. That's -- that's what he

25 suggests in this e-mail you put in front of

00179:01 me.

Page 181:14 to 183:21

00181:14 Q. All right. I'm going to keep

15 that one out, because we're going to come

16 back to it. But let's go to Tab 23, which

17 is Bates Page Number 1898.

18 This is an e-mail that you

19 sent on March the 7th to Charles Bondurant,

20 right?

21 A. Yes, sir.

22 Q. Now, if you notice, in the

23 middle, Mr. Bondurant is being told by you

24 at 11:48 a.m., We don't have our initial

25 leak-off yet. The 12.5 was a shoe

00182:01 integrity test. We need to clean out the

02 rathole, drill ten -- ten feet of new

03 formation -- drill ten new feet formation,

04 then pull back into the shoe and do a

05 leak-off.

06 What does that mean?

07 A. Chuck was sending out updates,

08 and in his most recent update on the 7th he

09 said that, in his update, that we performed

10 a leak-off test and got a 12.5 value. I

11 was pointing out that Chuck report -- Chuck

12 in reporting that the 12.5 was a leak-off

13 test, was an error in the fact that it was

14 a 12.5 was shoe integrity test or a casing

15 test. So Chuck reported the -- it was

16 actually -- he reported a leak-off test was

17 actually a casing test. So we -- we hadn't

18 got to the point yet where we drilled out

19 the cement, drilled a ten-foot formation,

20 and actually performed a formal leak-off

21 test. So I was just pointing out to Chuck

22 that there was a -- a small discrepancy in

23 his report.

24 Q. When you're saying, We need to

25 clean out the rathole.

00183:01 Why do you need to clean

02 out a rathole?

03 A. It's terminology. 'Cause

04 there's residual cement from the cement

05 job.

06 Q. Okay.

07 A. So when you go back and you

08 drill down through the last couple of

09 joints of casing, there's often residual

10 cement that needs to be cleaned out.

50


11 Q. And he writes back, Shat, I hope

12 I did not tell a fib?

13 A. Yep.

14 Q. You write back, Haha. I'm sure

15 they're not looking at it that hard. As

16 long as no one gets hurt and the rigs not

17 on fire. I'm sure they just glance over

18 it, exclamation point. Washing to botto

19 now. Lotsa gas. Like myself...

20 Right?

21 A. That's what I wrote.

Page 183:23 to 183:25

00183:23 A. Can I expand on that?

24 Q. You can when somebody asks you a

25 question about it.

Page 185:09 to 186:01

00185:09 Let me take you to the next

10 one, Tab 25. March 8th. This is Bates

11 Page Number 5606.

12 Are you with me?

13 A. Yep.

14 Q. Page 2. You write an e-mail on

15 March the 8th at 11:09 p.m. forward Macondo

16 kick.

17 A. What -- what's the -- I'm sorry.

18 What tab am I on? What --

19 Q. You're on Tab 25.

20 A. Okay.

21 Q. Second page of it. At the top

22 you say, Subsurface meeting at 7:00 a.m.

23 tomorrow. Currently shut-in. Took a kick

24 at 13,250.

25 Are you with me?

00186:01 A. Yes.

Page 186:09 to 186:16

00186:09 Q. You had to shut in the well?

10 A. We shut in the well on any kick.

11 Q. This kick was significant enough

12 that you were kind of deputized to do a

13 full analysis as to why it happened so that

14 we could create a communication plan of

15 lessons learned.

16 Do you recall this?

Page 186:19 to 187:10

00186:19 A. Yes, sir.

51


20 Q. All right. The kick takes place

21 at 13,250. It occurred on March the 7th or

22 March the 8th, or do you recall?

23 A. It was -- it was March 8th. It

24 was -- it was late in the evening at

25 9:30'ish on March 8th.

00187:01 Q. March 8th. You were at 13,250.

02 You were in the -- which casing

03 hole-section?

04 A. This was -- we -- we were to

05 set -- we were planning on setting

06 13-5/8-inch casing.

07 Q. Okay. So you're in the

08 13-5/8-inch casing section, you sustain a

09 kick, and you got stuck, right?

10 A. That is correct.

Page 188:12 to 189:03

00188:12 Q. I want to talk to you about the

13 lessons learned from the March 8th kick.

14 If you could, go to Tab 29, please, sir.

15 Bates Number 39111. And I'm going to start

16 at the bottom so you don't even have to

17 read it. We'll do it together. The bottom

18 is the first e-mail.

19 You sent an e-mail at 8:15

20 to Graham Vinson who you call Pinky?

21 A. Yes, sir.

22 Q. Graham Vinson, what role does

23 Graham play in BP relative to you?

24 A. Graham is my team leader.

25 Q. Your team leader of the Tiger

00189:01 Team, right?

02 A. He's the team leader of the

03 Tiger Team, correct.

Page 189:13 to 192:15

00189:13 Q. Let me start over.

14 You write, What do you

15 think about putting me on the wellsite for

16 the remainder of Macondo? The way I see

17 it, the past couple of well events have

18 been preceded by subtle indicators that

19 were either not recognized or not properly

20 communicated. I think we might benefit

21 from both having an extra set of eyes on

22 wellsite, and having different

23 communication dynamic from myself

24 communicating with Jon and Paul in the

25 office.

00190:01 Have I read that correctly

02 so far?

52


03 A. Yes, sir.

04 Q. Who are Jon and Paul?

05 A. Jon and Paul are my colleagues.

06 They're also operations geologists.

07 They -- they are following the well.

08 Q. From where?

09 A. They're in the office. They

10 sit -- we sit in the same area. They --

11 I'm kind of the figurehead for the well,

12 but they follow the well much the same as I

13 do.

14 Q. All right. So you're saying we

15 might benefit from having an extra set of

16 eyes on the wellsite as opposed to having

17 three guys talking in the office, right?

18 A. Yeah. That's -- yeah, that's

19 what I was saying.

20 Q. The head of the Tiger Team,

21 Graham Vinson, writes back, Awesome

22 suggestion and I agree. Opportunity to

23 reengage with the wellsite team, get us all

24 back on the same page.

25 A. Uh-huh.

00191:01 Q. And personally an opportunity

02 for you to take delivery -- or take

03 ownership of our delivery for the remainder

04 of this well.

05 Did I read that right?

06 A. Yes, sir.

07 Q. Up at the top Mr. Vinson also

08 writes that, Me, Paul, and Jonathan were

09 discussing these issues this morning. We

10 three were of the opinion that going out

11 next week late would put you in a position

12 to take the, quote, lead, close quote, and

13 display ownership to the onshore and

14 offshore wells team with surrounding the

15 issue of tightening up the PPFG detection

16 issues.

17 What is PPFG?

18 A. Pore pressure fracture gradient.

19 Q. Now, you've written below that

20 there are subtle indicators that were

21 either not recognized, not properly

22 communicated. Those subtle indicators

23 dealt with the PPFG issues, right?

24 A. The ones I was referring to,

25 yes.

00192:01 Q. And so he's saying if you go out

02 there and we can tighten up the PPFG

03 detection issues, I would -- I personally

04 would prefer to have this in play in a

05 section we've already drilled with you

06 there to make sure we implement this

07 appropriately. This would involve

53


08 conversations with the PPFG experts,

09 wellsite geologists, and mudloggers to

10 ensure all real-time PPFG detection

11 criteria are being monitored and

12 communicated to the entire well delivery

13 team.

14 Did I read that correctly?

15 A. Yes, sir.

Page 192:25 to 194:01

00192:25 Q. All right. We have a situation

00193:01 where you-all sustained a kick, and you

02 said the past couple of well events have

03 been preceded by subtle indicators that

04 were either not recognized or not properly

05 communicated. And now you're being sent

06 out there to help fix this problem, right?

07 MR. FIELDS:

08 Objection, form.

09 A. Yes. There's the -- the

10 indicators that I speak of,

11 retrospectively, when looking at pore

12 pressure detection indicators, they might

13 be more apparent than they are at first.

14 So when -- when there's first -- what I

15 refer to, as indicator on the rig, it's

16 more subtle. An indicator is probably more

17 subtle than when you look at it when you

18 have all the data retrospectively. So I'm

19 saying, okay, let's reengage the team.

20 Let's make sure our lines of communication

21 between the wellsite leader, the mudlogger,

22 the wellsite geologist, the pore pressure

23 engineer, and office are still well greased

24 and well moving, and let's put another set

25 of eyes on this to help improve our

00194:01 efficiency.

Page 194:09 to 195:09

00194:09 Q. Sure. You wanted to go on the

10 well to improve communications and the

11 ability of the people on the well to see

12 these subtle indicators in order to prevent

13 future kicks in the future?

14 A. I didn't want to improve the

15 ability of people on the -- on the well. I

16 know that the people on the well are

17 extremely capable. We've been working with

18 these individuals for a long time. I just

19 wanted to make sure there's -- that the

20 communication dynamic was still there.

21 When you're dealing with

54


22 scientists and engineers on the well,

23 there's a lot of different personalities.

24 There's a lot -- there's sometimes often

25 changeup between wellsite leaders.

00195:01 Q. Sure.

02 A. And I just wanted to make sure

03 that the lines of communication were --

04 were still -- were still up and were

05 running. People were communicating in the

06 way they should. And that -- that -- you

07 know, I was trying to strive for

08 operational efficiency, to make -- to make

09 things more efficient.

Page 196:17 to 197:05

00196:17 Q. Go to Tab 32. Bates Page

18 Number 44180. We're going to go forward

19 two days.

20 MR. FIELDS:

21 Mike, which tab again?

22 MR. WATTS:

23 32.

24 Q. Are you with me? Go to the

25 second page. There is an e-mail entitled,

00197:01 Some Thoughts and Help Requested, Pore

02 Pressure Detection, Macondo, March the

03 12th, 13:13 written by Jonathan Bellow.

04 A. I'm going to need -- need some

05 time to review this.

Page 197:15 to 199:14

00197:15 Q. All right. This is March the

16 12th. We are three or four days after this

17 kick that you-all sustained, the

18 13-5/8-inch casing at 13,250 feet, right?

19 A. Yes, sir.

20 Q. On Page 2, 44181, Jonathan

21 Bellow from BP writes an e-mail.

22 Who is Jonathan Bellow?

23 A. Jonathan Bellow is my

24 counterpart. He's also an operations

25 geologist at deepwater exploration.

00198:01 Q. And he writes an e-mail to

02 Stuart Lacy.

03 What was Stuart Lacy's

04 position?

05 A. Stuart Lacy is a wellsite

06 geologist.

07 Q. Gord Bennett, what was his

08 position?

09 A. Also a wellsite geologist.

10 Q. John Brannen?

55


11 A. Wellsite pore pressure engineer,

12 who I don't believe worked on this well but

13 collaborates with us. He's a contractor.

14 Q. Kate Paine?

15 A. Wellsite pore pressure engineer.

16 Q. DEEPWATER HORIZON MWDD. Who is

17 that? Who would that include?

18 A. DEEPWATER HORIZON M -- that is

19 the Sperry-Sun measurement while drilling

20 engineers.

21 Q. Okay. John Guide. Who is John

22 Guide?

23 A. DEEPWATER HORIZON team lead.

24 Q. Mark Hafle?

25 A. Drilling engineer.

00199:01 Q. Brian Morel?

02 A. Drilling engineer.

03 Q. And Charles Bondurant?

04 A. Geologist.

05 Q. All right. And he copies you,

06 Mr. Paul Johnston.

07 Who is Paul Johnston?

08 A. Paul Johnston has the same role

09 as myself and Mr. Bellow. The operations

10 geologist.

11 Q. And he copies your boss --

12 Vinson, Graham -- the head of the Tiger

13 Team, right?

14 A. Yep.

Page 200:10 to 200:16

00200:10 Q. So Jonathan Bellow is an

11 operations geologist, the same role as you,

12 and he sends out an e-mail to most of the

13 people response to -- responsible for

14 geological analysis and drilling on the

15 DEEPWATER HORIZON, including David Sims of

16 BP's management, right?

Page 200:19 to 202:20

00200:19 A. That's what it -- it would

20 appear.

21 Q. Have you ever heard the phrase

22 "a Clarion call"?

23 A. I don't -- I don't believe I

24 have, sir.

25 Q. Do you know what the phrase

00201:01 "soul searching" means?

02 A. Yes.

03 Q. Jonathan Bellow writes, As we

04 have some time while we recover from the

05 Macondo stuck pipe and kick event, I want

56


06 to spend some time reevaluating how we

07 manage real-time pore pressure detection

08 for Macondo type wells. By Macondo type

09 wells, I mean those wells without thick

10 salt sections that usually have narrow

11 drilling windows for a large part of the

12 well. I believe that we can learn from

13 Macondo to allow these kind of wells to be

14 successfully drilled without subsurface NPT

15 events.

16 NPT is non-productive time

17 events, right?

18 A. Correct, sir.

19 Q. If you would, go down to the

20 third page. The paragraph that starts,

21 specifically to the Macondo data. Are you

22 with me? About seven lines down from the

23 top.

24 A. Yes, sir.

25 Q. Specifically to the Macondo

00202:01 data, all three events are proceeded by gas

02 events. There are indications of a pore

03 pressure increase in the normalized gas

04 values prior to the kicks. The first two

05 kicks have elevated gas levels and

06 occurrences of C2 and C3 levels prior to

07 the kick event. This last event was

08 preceded by two connections gas peaks. In

09 this last event, there was a significant

10 event with the D exponent from the normal

11 trend at least 150 feet below the kick.

12 There were also cavings that, although not

13 PP -- pore pressure related, gave us an

14 indication of other issues that would

15 require more mud weight.

16 Let me stop there for a

17 second. If you don't have enough mud

18 weight relative to your pore pressure, you

19 get a kick and a well flow situation,

20 right?

Page 202:23 to 203:10

00202:23 A. That can be a factor which can

24 lead to a well flow in some circumstances.

25 Q. There were also cavings that,

00203:01 although not pore pressure related, gave us

02 an indication of other issues that would

03 require more mud weight. The sonic data

04 also showed an upward trend in the pore

05 pressure. All of these signs were present

06 but at 85 feet per hour, occur quickly in

07 real-time.

08 When he's talking about 85

09 feet per hour, what is he talking about?

57


10 A. The rate of penetration.

Page 203:16 to 204:05

00203:16 Q. You're drilling 85 feet per

17 hour -- all these signs were present, but

18 at 85 feet per hour occur quickly in

19 real-time. We just need to refine our

20 process to allow quicker conversations to

21 occur and ensure that we are monitoring all

22 relevant PP trend data.

23 Did I read that correctly?

24 A. Yes, sir.

25 Q. So Mr. Bellow's solution was,

00204:01 instead of slowing down the rate of

02 drilling so that you have more time to

03 analyze these signs, we need to improve our

04 ability to have quicker conversations to

05 keep up with the drilling schedule?

Page 204:10 to 204:13

00204:10 Q. That's what he's saying here,

11 isn't it?

12 A. I don't see Mr. Bellow saying

13 that we don't need to slow down.

Page 204:23 to 207:02

00204:23 Q. We're going to get to some other

24 things that you wrote.

25 You had a concern that

00205:01 you-all were drilling too fast, didn't you?

02 MR. FIELDS:

03 Objection, form.

04 A. At what point in time?

05 Q. At this point in time.

06 A. This hole-section? This

07 interval?

08 Q. Sure.

09 A. I had a concern that, close to

10 casing point where we're -- our drilling

11 margin is diminishing and we're looking for

12 casing point, I had a concern that we were

13 drilling too fast. That's documented, yes.

14 Q. All right. Once we recover from

15 this event, Bobby Bodek -- I'm sorry. I

16 didn't -- I'm not trying to mispronounce

17 your name.

18 Once we recover from this

19 event, Bobby Bodek is planning to be on the

20 rig to assist -- or to asset with

21 implementing the improvements through --

58


22 thought of in this conversation. I would

23 ask that all of you think of the last

24 events and offer suggestion and offer

25 improvements -- improvements to our

00206:01 process.

02 Did I read that correctly?

03 A. Yes, sir.

04 Q. Now, that e-mail sent -- sent by

05 a Jonathan Bellow was sent, among other

06 people, to Gord Bennett.

07 Do you see where it says

08 Bennett -- ?

09 A. Yes, sir, I do see that.

10 Q. For the record, again, who is

11 Gord Bennett and what position did he hold

12 at BP?

13 A. Gord Bennett is a contracted

14 wellsite geologist.

15 Q. He writes back to Jonathan

16 Bellow. Some thoughts, help requested,

17 pore pressure detection on Macondo. He

18 says he was at the wellsite for the second

19 event.

20 Do you see that?

21 A. I do, sir.

22 Q. In the second paragraph, he

23 says, I got to admit -- this is about six

24 lines down -- I was baffled by what was

25 happening mud-wise.

00207:01 So he was on site and was

02 baffled in a real-time situation, right?

Page 207:07 to 207:09

00207:07 A. I don't know what he necessarily

08 meant by baffled. It's his -- it's his

09 writing. I can't interpret it.

Page 208:07 to 208:16

00208:07 Q. So I was baffled by the mud

08 weight up program. It seemed to me that

09 there wasn't one or it wasn't being

10 followed. But since we were picking casing

11 point, that seemed to be the priority and I

12 didn't question why town wasn't following

13 their prognosis.

14 When the word "town" is

15 used, that means the guys in Houston,

16 right?

Page 208:19 to 209:21

59


00208:19 A. I'm not sure.

20 Q. You got rig on the one side and

21 you got town on the other. Does that make

22 sense to you?

23 A. I've seen it -- I've seen that

24 used before to represent the Houston

25 office, yes.

00209:01 Q. All right. But since we

02 weren't -- since we were picking casing

03 point, that seems to be the priority and I

04 didn't question why town wasn't following

05 their prognosis. However, we were unlucky,

06 and drilled a thin overpressured sand and

07 took a kick at that point.

08 Did I read that correctly?

09 A. Yes, sir.

10 Q. In the next paragraph, he

11 writes, I have not heard of anyone being

12 consistently successful in detecting

13 overpressured sands, even though everyone

14 talks about them after the fact.

15 Especially when drilling a section in two

16 days, you don't get any trends real-time as

17 things are happening pretty fast as you

18 mentioned.

19 Stop there. He's saying

20 we're drilling too fast to catch the signs,

21 isn't he?

Page 209:24 to 210:16

00209:24 A. It can be interpreted that way.

25 I don't know. I -- this is Gord's work.

00210:01 Q. You agree with him?

02 A. I -- I made that statement

03 relative to a certain point in the well.

04 Q. Okay. We would have to stop at

05 predetermined depths and to have the rig

06 and town teams analyze the data with a

07 preset number of criterias, including the

08 ones you mentioned in your e-mail. This

09 does not fit with the current drilling

10 practice on the rig.

11 Did I read that correctly?

12 A. Yes, sir.

13 Q. Mr. Bennett is saying we would

14 have to slow down, but that would not fit

15 with the present or the current drilling

16 practice on the rig, which is to speed up?

Page 210:19 to 211:09

00210:19 A. I disagree that that was to

20 speed up.

60


21 Q. Well, the current drilling

22 practice on the rig, did it call for being

23 able to stop at predetermined depths, have

24 the rig and town teams analyze the data

25 before you go further?

00211:01 MR. FIELDS:

02 Object to form.

03 A. I -- I don't know. It's the --

04 it's the drilling engineers, it's the

05 wellsite that determines how to drill a

06 well. My subsurface people onshore as well

07 as Gord on the rig, we provide them the

08 input, the subsurface input to make their

09 decisions.

Page 211:18 to 211:21

00211:18 Q. In other words, you can raise

19 the red flag, tell them you're drilling too

20 fast, our people do not have the time to

21 catch these signs, you should slow down.

Page 212:01 to 212:13

00212:01 Q. I don't know that the red

02 flag --

03 A. They make the decision -- in

04 general, these -- the faster you drill, the

05 faster indicators present themselves.

06 Q. And the harder they are to

07 detect?

08 A. They're not necessarily more

09 difficult. There's a greater quantity of

10 them.

11 Q. And there's less time to

12 deliberate about what they're telling you?

13 A. Yes.

Page 212:25 to 213:10

00212:25 Q. Well, we know from your e-mails

00213:01 that you thought, or maybe you were

02 bragging, that it cost $750,000 a day to

03 operate this rig?

04 A. I believe I was bragging.

05 Q. Call it $525,000 a day. It's a

06 lot of money per day to operate this rig,

07 right? You knew that?

08 A. Yes.

09 Q. Every day that the well takes

10 longer than planned, costs BP money?

Page 213:13 to 213:14

61


00213:13 Q. Right?

14 A. Yes.

Page 213:23 to 214:06

00213:23 Q. You knew it was behind schedule,

24 didn't you?

25 A. That statement -- I knew it was

00214:01 behind schedule, yes. I don't understand

02 the totality of factors that go into why it

03 was behind schedule. There's many --

04 Q. Fair enough.

05 A. -- there's many drilling issues

06 as well as subsurface issues.

Page 214:13 to 214:16

00214:13 Q. How far behind schedule was the

14 DEEPWATER HORIZON in terms of delivering

15 this well?

16 A. I don't know how far.

Page 214:19 to 215:20

00214:19 Q. In these short drilling

20 intervals, around 2,000 feet, where you

21 only have an hour or two, 200 feet of

22 possible change and possible detection of

23 overpressured sand, we can either stop

24 drilling and try to figure out what is

25 happening, why no indications of pressure

00215:01 like connection gases for example, or stick

02 to a weight up schedule and ignore the

03 absence of pressure indicators. Where to

04 stop would have to be arbitrary, say 500

05 feet. Do I think this is realistically

06 going to fly with you folks? No. You

07 mentioned in your e-mail that we need to

08 have more discussions, but in the case of

09 absence/subtle indications we will probably

10 drill through it/take kick before we can

11 have the discussion.

12 Did I read that correctly?

13 A. Yes, sir.

14 Q. Gord Bennett is saying we are

15 not going to slow down. We are not going

16 to stop. We're going to drill through

17 these signs and risk taking the kick.

18 That's what he just said he thinks BP's

19 going to do regardless of what he says,

20 right?

62


Page 215:23 to 215:23

00215:23 A. That's what Gord Bennett wrote.

Page 217:01 to 217:12

00217:01 Q. Okay. Did you agree with Gord

02 Bennett when you got this e-mail that it

03 was drilling too fast and that's what

04 caused the kick on March the 8th?

05 MR. MONICO:

06 Objection, form.

07 A. It's not what I believe

08 necessarily caused the kick. Do I believe

09 we -- our rate of penetration was too

10 high --

11 Q. Yep.

12 A. -- next to the kick? Yes.

Page 219:17 to 219:25

00219:17 Q. Let me show you another

18 response, which is Tab 31, Bates 32990.

19 Again, we see Mr. Bellow's

20 e-mail at the bottom of Page 1 and to

21 Page 2, but in the middle we see Stuart

22 Lacy writing an e-mail back to Jonathan

23 Bellow.

24 Who is Stuart Lacy?

25 A. He is a wellsite geologist.

Page 220:10 to 221:01

00220:10 Q. Okay. I'd agree with pretty

11 much everything you say, and I think we

12 were all a bit complacent having been

13 drilling sub-salt wells. This is a

14 different kettle of fish. One thought is

15 that we always used to flow-check sands in

16 exploration wells but the drive for

17 increased performance has seen the

18 abandoned.

19 Did I read that correctly

20 first?

21 A. Yes, Mr. Watts.

22 Q. Flow-check sands. What is that?

23 A. A flow check is when you stop

24 drilling, you shut in, and you use

25 pressures to determine whether the well is

00221:01 flowing.

Page 221:25 to 222:10

63


00221:25 Q. Do you have any thoughts as to

00222:01 how many hours or days we're talking about

02 if you chose to do a flow check of sands in

03 the exploration wells?

04 A. It's less than an hour.

05 Q. Okay. But the drive for

06 increased performance has seen this

07 abandoned.

08 When did BP abandon the

09 process of flow-checking sands in

10 exploration wells?

Page 222:13 to 222:22

00222:13 A. I don't know.

14 Q. Okay. Likewise, drilling like a

15 bat out of hell in these pore pressure

16 narrow-window wells is perhaps not wise,

17 especially considering the drilling is

18 relatively low percentage -- is a

19 relatively low percentage of the total time

20 in these wells.

21 Did I read that correctly?

22 A. Yes, sir.

Page 223:16 to 223:22

00223:16 Q. You told me this morning before

17 the lunch break that you thought BP was

18 drilling too fast. We had discovered

19 before that Mr. Johnston thought BP was

20 drilling too fast. And now we have

21 Mr. Lacy saying they're drilling like a bat

22 out of hell?

Page 223:25 to 224:15

00223:25 Were you finished?

00224:01 A. I don't necessarily know what

02 Mr. Lacy's referring to. I don't know that

03 BP abandoned flow checking. I don't know

04 that -- what he considers to be drilling

05 like a bat out of hell. It's just -- it's

06 a saying.

07 Q. What does that saying mean to

08 you?

09 A. It means fast.

10 Q. Okay.

11 A. But I don't know in reference to

12 what part of the well he's talking about.

13 Me this morning, specifically near the

14 13-5/8 casing point, I thought we were

15 drilling too rapidly.

64


Page 228:13 to 230:06

00228:13 Q. All right. If you would, go to

14 Tab 34.

15 This is an e-mail -- Bates

16 Page Number 6076 -- from you to Paul

17 Johnston, Jonathan Bellow, and Graham

18 Vinson dated March the 16th at 7:13 in the

19 evening; is that right?

20 A. Yes, sir, it is.

21 Q. You forward an attachment

22 entitled, Lessons Learned, Plan Forward

23 Macondo. And if you would, go to the next

24 Bates page number.

25 We have a list of four

00229:01 different lessons learned and path forward,

02 Macondo subsurface NPT.

03 That's non-productive time

04 events, correct?

05 A. Yes, sir.

06 Q. You wrote this document?

07 A. I did.

08 Q. If you would, go to the next

09 Bates Page Number 6078. One of the things

10 you say in Number 4 is, Better lines of

11 communication between the rig and Houston

12 office need to be established. Preceding

13 each well control event, subtle indicators

14 of pore pressure increased -- or increase

15 were either not recognized or not discussed

16 with the greater group. In retrospect,

17 after compiling the above list of

18 observations from various individuals, it

19 seems that the accelerated rate of

20 penetration and the resulting onslaught of

21 drilling indicators exceeded the ability of

22 all team members to effectively recognize,

23 properly communicate, and decisively act

24 upon available data.

25 Those were your words,

00230:01 correct?

02 A. Correct, Mr. Watts.

03 Q. When you say it seems that the

04 accelerated rate of penetration, that is

05 the speed at which the well is being

06 drilled by BP, right?

Page 230:09 to 231:19

00230:09 A. This is in reference to the last

10 well control event, the kick --

11 Q. March the 8th?

12 A. March -- this is -- right. This

13 is in support of my earlier statement that

65


14 I believe the rate of penetration was too

15 fast near casing point in the 13-5/8-inch

16 casing section.

17 Q. And when we say accelerated rate

18 of penetration, that is the speed of

19 drilling?

20 A. Yes, sir. They're synonymous.

21 Q. And the resulting onslaught

22 drilling indicators, is all that pore

23 pressure indicators that we've been talking

24 about before lunch, is that right, among

25 others, the PPFG stuff?

00231:01 A. Say that again. I --

02 Q. Sure. When you say the

03 resulting onslaught of drilling indicators,

04 that's all the PPFG factors that were

05 referenced in the preceding memos, right?

06 A. Refer me to what those are.

07 Q. Well, that's what I'm asking

08 you. Not specifically, but when you say an

09 onslaught of drilling indicators?

10 A. Yes. I'm referring to --

11 Q. Yeah.

12 A. -- indicators of pore pressure.

13 Q. And so what you're saying is, is

14 that because of the speed of drilling and

15 the number of indicators, those two

16 together exceeded the ability of the team

17 members to effectively recognize them,

18 communicate them, and decisively act or

19 respond to them, right?

Page 231:22 to 233:01

00231:22 A. I guess what I'm saying is that

23 due to -- due to the rate of penetration,

24 my team members weren't as efficient as

25 they could have been at detecting them.

00232:01 Q. Okay. And then you say, I would

02 like to propose the following.

03 There's one, two, three.

04 The third thing that you said -- or the

05 second thing that you said is that, The

06 rate of penetration is such that all of the

07 aforementioned indicators can be adequately

08 evaluated in real-time. But you write in

09 three, All indicators, no matter how

10 subtle, will be discussed cross-discipline.

11 For example, an observation made in the

12 office by a subsurface team member will be

13 communicated to the drilling group. Upon

14 cross-discipline consensus of the

15 noteworthiness of a feature, either on the

16 rig or in the office, the rig and

17 subsurface based teams will be assembled.

66


18 Did I read that correctly?

19 A. Yes, sir.

20 Q. So I guess what you're saying

21 is, is regardless of who catches the sign

22 or the indicator, what you're saying is, is

23 let's make sure we communicate that across

24 disciplines so that everybody learns about

25 it, right?

00233:01 A. Yes.

Page 234:18 to 235:19

00234:18 Q. All right. In addition to

19 that -- if go to Tab 36, Bates Page Number

20 15694 -- you send an e-mail on the 18th

21 across the team and to Sperry-Sun and to

22 the DEEPWATER HORIZON, and you sent the

23 memo with respect to the lessons learned.

24 You say, I've collated the

25 responses to Jon's e-mail below?

00235:01 That's Jon Bellow's e-mail

02 that we talked about before, right?

03 A. Yes, sir.

04 Q. Additionally, we on the Tiger

05 Team have had several discussions over the

06 past few days regarding lessons learnt from

07 the previous hole-section, and a way

08 forward, for not only the remainder of

09 Macondo, but future exploration wells.

10 Please browse the attached lessons

11 learnt/plan forward document and provide

12 feedback should you feel obliged.

13 Right?

14 A. That's what it says.

15 Q. Would it be fair that the

16 lessons learned document that we've already

17 discussed was distributed throughout the

18 geology and drilling groups at BP as well

19 as to Sperry-Sun and Halliburton?

Page 235:22 to 236:01

00235:22 A. They were on the distribution

23 list that I sent out for the e-mail. So

24 providing that other parties opened it,

25 they would have access to it. But they

00236:01 were definitely sent the document.

Page 238:06 to 238:18

00238:06 Q. Tab 37, Bates Page Number 21267,

07 is an e-mail that you wrote on March the

08 18th.

67


09 Do you see that, sir?

10 A. The e-mail I wrote was on six --

11 6-8.

12 Q. I'm sorry. We're lost. Are you

13 on Tab 37?

14 A. I'm on Tab 37. I see the -- I

15 see I wrote an e-mail on -- I wrote two

16 e-mails on -- within Tab 37. I just want

17 to make sure we're -- I wrote a -- I wrote

18 an e-mail on 1268 and 1267.

Page 239:04 to 241:10

00239:04 You start with this e-mail

05 chain by forwarding the lessons learned,

06 plan forward document that we discussed

07 before, right?

08 A. Yes, sir.

09 Q. Okay. And then Gord Bennett

10 responds. And I want to ask you about one

11 thing that he asked.

12 He says, What are the

13 subtle indicators preceding each event that

14 you alluded to in part four? And then

15 about half way down the next paragraph, he

16 says, The shales appear to be

17 undercompacted --

18 A. Uh-huh.

19 Q. -- and have allowed us to drill

20 without having to increase mud weights, at

21 least until we hit the sands, and is

22 resulting in serious problems.

23 Did I read that correctly?

24 A. Yes, sir.

25 Q. Now, when the shales -- shales

00240:01 are undercompacted --

02 A. Uh-huh.

03 Q. -- that is another way of saying

04 that they are not packed down like hard

05 rock, right?

06 A. That's not necessarily the case.

07 What I think Gord is referring to here is

08 the shales and sands not being in pressure

09 equilibrium.

10 Q. Okay.

11 A. A lot of our indicators, our

12 pore pressure indicators such as connection

13 gas, resistivity, sonic modelling, they are

14 all -- we estimate our -- our pore pressure

15 based only qualitative data that's used to

16 determine what shale pressure is. So

17 there's nothing that you can -- there's no

18 tools that we have where you can infer

19 pressure from sands. You can take the

20 pressure with a probe in the sand, but for

68


21 the most part, our -- our wells -- this

22 well in particular is 98 percent shale. So

23 what we do is, we use our indicators to

24 qualitatively estimate what our shale

25 pressure is. And then if we know what our

00241:01 shale pressure is and we know the

02 difference in sand versus shale pressure,

03 we can infer sand pressure.

04 Q. But when you were going through

05 shale, that's the problem?

06 A. Sands are -- are stringers. So

07 we'll be going through a shale -- when he

08 refers to a shale being undercompacted,

09 he's saying they're underpressured relative

10 to the sands.

Page 242:01 to 242:20

00242:01 Q. But whether it's goo or

02 undercompacted shale, the point is that

03 your instruments are calibrated, assuming

04 you're going through compacted shale, and

05 then you use the contrast between that and

06 the gas --

07 A. We are going through -- like

08 he's using undercompacted in terms of under

09 pressure. These are very much compacted,

10 indurated hardened shales.

11 Q. All right. He writes, Why not

12 have a weight up schedule based on the

13 forecast already made from the offset well

14 and that takes into account the LOT

15 pressures we obtained in this well?

16 A. Uh-huh.

17 Q. And then you respond -- you talk

18 about where the first kick was, and that

19 was between around 12,050 feet and 12,100,

20 right?

Page 243:01 to 244:14

00243:01 Q. You said uh-huh and I need a

02 yes.

03 A. I'm -- I'm sorry. Yes.

04 Q. Yes. The second kick around

05 13250, you saw 150u connection gasses

06 lagged up from connections at 12,933 and

07 13070; is that right?

08 A. That's what I wrote. I don't

09 remember the specifics of the data I was

10 looking at when I constructed this, but

11 I -- I don't question the fact that I wrote

12 that.

13 Q. And then you say, In hindsight

69


14 that should have raised the flag that the

15 pore pressure was in between ESD and ECD.

16 What is ESD and ECD again?

17 A. ESD is equivalent static

18 density, and ECD is equivalent circulating

19 density.

20 Q. So equivalent static density is

21 surface weight?

22 A. No, not necessarily. Static

23 density is at the -- it's at the bottom of

24 the hole. So when you -- when the pumps

25 are off and you're -- the mud weight is

00244:01 compressed at a depth, that's static

02 density. It's going to be slightly higher.

03 Q. And ECD is what?

04 A. Circulating density.

05 Q. And so if your pore pressure is

06 between the ESD and the ECD, does that put

07 you in an underbalanced situation when

08 you're circulating?

09 A. When we're circulating, no.

10 Q. When you're not circulating,

11 what does it do?

12 A. It puts us close to balance.

13 Q. Close to balance on the

14 underbalanced side, doesn't it?

Page 244:17 to 245:10

00244:17 A. I don't know.

18 Q. It was a subtle indicator. It

19 might not have warranted an MW inc.

20 That's a mud weight

21 increase, right?

22 A. Yes, sir.

23 Q. It was a subtle indicator and

24 might not have warranted a mud weight

25 increase and we might have gotten kick

00245:01 anyways. But having gas go from 50u to

02 150u on two successive connections after we

03 had seen nothing but 50u BGG for the

04 previous 1,000 feet definitely warranted a

05 conversation.

06 What is BGG?

07 A. Background gas.

08 Q. All right. So this is you

09 writing another subtle indicator that

10 someone missed prior to the kick, right?

Page 245:13 to 246:12

00245:13 A. Yes. I'm writing this

14 retrospectively --

15 Q. Sure.

70


16 A. -- after I see all of the data.

17 The subtle indicators are subtle even when

18 they are looked at after the fact. I'm

19 not -- I'm not condoning -- I'm not -- I'm

20 not trying to reprimand or discipline Gord

21 and say, this is obvious, you missed it.

22 I'm just trying to say that there was

23 something subtle that, you know, may not

24 have been picked up on by anybody before

25 the case, but, you know, it is something.

00246:01 So going forward, let's improve our

02 communication, let's improve the way we do

03 business and -- and talk a little bit more

04 about these things that, after the fact,

05 are even subtle.

06 Q. You're saying we've had a series

07 of kicks, right?

08 A. I wouldn't say we had a series.

09 Q. Well, we had more than one so

10 far we've talked about?

11 A. Two. I don't know if I'd say a

12 series.

Page 246:20 to 248:08

00246:20 Q. BP was drilling too fast at the

21 time that it got the kick on March 8th?

22 A. It is my perception. I can't

23 speak on behalf of BP.

24 Q. Your Tiger Team said with that

25 rate of penetration and the number of

00247:01 subtle indicators coming in at real-time,

02 people didn't have the time to properly

03 identify, communicate, and respond to those

04 indicators?

05 MR. FIELDS:

06 Object to form.

07 A. At that particular juncture,

08 yes.

09 Q. And so what you're doing is

10 you're trying to recommend new processes

11 and procedures whereby you would have

12 better communication so that if you do have

13 these indicators, they will be identified,

14 they will be communicated, and they will be

15 responded to before you get a kick? That's

16 the goal?

17 A. They would be acted on in a more

18 efficient manner. I'm trying to improve

19 communication.

20 Q. All right. Let's go to Tab 40.

21 You're trying to improve communications.

22 Kate Paine writes an e-mail

23 to you on March the 19th, Bates Page

24 Number 25882. And you see starting with

71


25 about the second line, the high gas we had

00248:01 at 12,035, once it was controlled the

02 decision was made to drill ahead. Everyone

03 was aware of the gas but we decided to

04 drill ahead to stay as close to the

05 prog-casing point as possible. The prize

06 was to skip the contingency liner.

07 Did I read that correctly?

08 A. Yes, sir.

Page 248:25 to 249:03

00248:25 Q. The prize, to skip the

00249:01 contingency liner.

02 That's not a prize. She's

03 being facetious here, right?

Page 249:06 to 249:25

00249:06 A. We would -- obviously, when

07 drilling a well, the team would like to

08 stay as close to the base plan as possible

09 as to not use the contingency liner. The

10 contingency liner is there in case we have

11 to set casing short and we need an extra

12 liner. It's not --

13 Q. Okay. I'm sorry. Go ahead.

14 A. It's -- it's not met in the base

15 plan.

16 Q. So you had to set casing short

17 as a result of the kick, you had to use

18 your contingency liner?

19 A. We had to use two contingency

20 liners.

21 Q. Two contingency liners.

22 After deciding to drill

23 ahead, we encountered the losses.

24 That's the lost returns we

25 were talking about, right?

Page 250:03 to 250:06

00250:03 Q. That's what losses means, right?

04 A. Yes.

05 Q. That's a bad thing?

06 A. It's not -- it's not good, no.

Page 250:24 to 251:15

00250:24 Q. We were aware of the upper limit

25 of the ECD.

00251:01 What's the ECD again?

02 A. Equivalent circulating density.

72


03 Q. We were aware of the upper limit

04 of the equivalent circulating density and

05 exceeded it because we didn't believe the

06 MWD LOT values.

07 What are the MWD LOT

08 values?

09 A. MWD is -- there's a pressure

10 transducer. There's a -- there's a

11 pressure gauge. MWD stands for measurement

12 while drilling. It's a piece of your

13 downhole BHA instrumentation.

14 Q. And LOT again?

15 A. Leak-off test values.

Page 252:04 to 252:23

00252:04 Q. Well, do you understand what

05 Kate Paine meant when she wrote to you, We

06 were aware of the upper limit of the ECD

07 and exceeded because we didn't believe the

08 MWD LOT values?

09 A. No, I really don't. I don't.

10 Q. She writes, I'm not sure -- I'm

11 not sure if it was a lack of communication

12 or awareness as much as a, quote, we can

13 get away with this, close quote, attitude.

14 A. I think Ms. Paine is -- was put

15 off by my e-mail that was suggesting that

16 the -- suggesting that we needed a higher

17 degree or higher level of scrutiny on the

18 wellsite. And I think a lot of this e-mail

19 is her firing back and -- with a little bit

20 of -- little bit of attitude. I -- I

21 don't -- I don't know what she -- what she

22 meant by a fair -- fair deal of information

23 in this e-mail.

Page 253:10 to 254:16

00253:10 Q. You don't see that at all in

11 this?

12 A. This is six words that Ms. Paine

13 said that I --

14 Q. Okay.

15 A. -- I don't see any connection.

16 Q. So her six words are

17 we-can-get-away-with-this attitude.

18 About two paragraphs down,

19 do you see where it says prior to the kick?

20 A. Yes, sir.

21 Q. Prior to the kick, it was an

22 active decision on the part of the drilling

23 team to drill with a high ROP.

24 What is ROP?

73


25 A. Rate of penetration.

00254:01 Q. With a high rate of penetration

02 and let the cuttings take up the mud weight

03 rather than drill at a moderate rate and

04 raise the mud weight.

05 Is that I -- is that what

06 she wrote?

07 A. That's what -- that's what's

08 written here.

09 Q. And in the last paragraph, I'm

10 sorry to push back on the lessons learned.

11 I know you got to get something out there

12 to make it look like we don't do this

13 again. But without obvious indicators and

14 with the real push to make hole and skip

15 the contingency liner, I don't see us

16 really learning.

Page 254:21 to 255:01

00254:21 Q. Is that what she wrote to you?

22 A. That's what she wrote, sir.

23 Yes.

24 Q. Now, did you respond to this

25 e-mail?

00255:01 A. No, I did not.

Page 255:07 to 257:15

00255:07 Q. Let's go to Tab 38, Bates Page

08 Number 22579.

09 Before you went out to the

10 well, you wrote this to your colleague,

11 Mr. Johnston?

12 A. Uh-huh.

13 Q. We're going up to a 12.3 so we

14 have a 12.5 ESD.

15 When you say you're going

16 up to a 12.3, is that mud weight?

17 A. That's surface mud weight.

18 Q. You're increasing surface mud

19 weight to 12.3 so you have a 12.5 ESD.

20 What is ESD again?

21 A. Equivalent static density.

22 Q. In other words, when you're down

23 the hole, it's a 12.5 equivalent static

24 density, right?

25 A. Uh-huh.

00256:01 Q. The moat the well -- the most is

02 what you meant to write, right?

03 A. Correct.

04 Q. The most the well has ever seen

05 is a 12.5. That's if the kick zone at

06 13,300 in the ghost well is communicating

74


07 back and across to the new wellbore. As

08 long as we have a 12.5 static, we can cover

09 all possibilities. Going to a 12.3 surface

10 will give us that.

11 I talked to Hafle, Guide,

12 Morel, and Gord and Kate. It was my call

13 to go to a 12.3. I told them I didn't want

14 to drill the sands around 13,000 without

15 anything less. I am the fucking man.

16 Is that what you wrote?

17 A. That is what I wrote.

18 Q. And again, putting aside the F

19 word. I don't care about that for right

20 now. What -- what this is saying is you

21 were the one that selected the surface mud

22 weight of 12.3, right?

23 A. It does say that.

24 Q. All right. And you knew with

25 the surface mud weight of 12.3 that that

00257:01 was going to give you an equivalent density

02 downhole of 12.5, right?

03 A. Yes. I collaborated with the

04 drillers on this one. It's never -- this

05 was meant to be -- it was my call to go to

06 12.3 was a little bit boastful on my part

07 to Mr. Paul Johnston, who's a good friend

08 of mine. It's never my decision on

09 making -- determining what mud weight to

10 use, so this was said -- this was said just

11 kidding. The fact that it was me that did

12 it was being boastful. It's not my call to

13 pick mud weights.

14 Q. Sure.

15 A. And it wasn't my call.

Page 259:11 to 259:21

00259:11 When you went out to the

12 well, your intention at the time that you

13 left was to be there until total depth,

14 right?

15 A. Yes, sir.

16 Q. There came a time when you were

17 called back in after about a week?

18 A. Yeah. I think it was a little

19 bit over a week.

20 Q. Okay.

21 A. It was two hole-sections.

Page 260:09 to 260:23

00260:09 A. Yeah. The first -- the first

10 was just to observe the dynamic 'cause,

11 like I alluded to earlier, there's a lot of

75


12 different personalities that go into

13 staffing the rig. There's engineers and

14 geologists that -- that typically sometimes

15 will have contrasting -- contrasting

16 personalities and ways of communicating.

17 So I just wanted to observe and see how

18 everybody is getting along with everybody,

19 and -- and do what I can to be there to

20 both add an extra set of eyes and to

21 improve the communication dynamic,

22 encourage -- encourage conversations

23 amongst the different groups.

Page 261:03 to 263:01

00261:03 If you would, go to Tab 42,

04 Bates Page Number 2160.

05 This is an e-mail that you

06 wrote on March the 24th to Robert Quitzau.

07 Who is that?

08 A. He was overseeing drilling

09 operations on the behalf of Anadarko

10 Petroleum Corporation.

11 Q. Okay. Copying Jonathan Bellow,

12 who wrote the March 12th e-mail that we

13 talked about.

14 A. Could I just read through this

15 real quick?

16 Q. Sure.

17 A. I don't recall this one

18 immediately. I just want to familiarize

19 myself with it. Okay.

20 Q. All right. You had 11-7/8-inch

21 liner section that you total depth at

22 15,103 feet, right?

23 A. Yes, sir.

24 Q. The shale pressure is coming in

25 as expected; however, as discerned from

00262:01 previous well control events, it appears as

02 if we have a 0.3 ppg sand overpressure

03 centroid at work. We find ourselves having

04 to respect these 0.3 ppg sand overpressure

05 in our mud weight program.

06 Question: What is a 0.3

07 ppg sand overpressure centroid?

08 A. As I mentioned a short while

09 ago, sand and shale aren't always in

10 pressure equilibrium. So depending on the

11 orientation of a sand body, if a sand body

12 is -- if you can imagine a lobe of sand

13 that's somehow plumbed in deeper, it will

14 transfer pressure up to a higher structural

15 level. So it appears that some of the

16 sands we were drilling through that were --

17 that were giving us problems are -- might

76


18 be plumbed in a little bit deeper and

19 transferring a pressure we might see a

20 little bit deeper up to our well location.

21 Q. In other words, that's a fancy

22 geological way of saying that the pressure

23 that you were seeing in the sands at a

24 given location was higher by 0.3 ppg than

25 you expected to because of that phenomenon

00263:01 you just described?

Page 263:04 to 264:07

00263:04 A. Than we were -- than we were --

05 what we were modeling in the shale.

06 Q. Fair enough. So you're saying,

07 look, it's coming in 0.3 ppg higher. We

08 got to respect that?

09 A. Yes, sir.

10 Q. All right. Now, three hours

11 later -- if you go to Tab 43

-- you write

12 an e-mail to your friend Paul Johnston.

13 Bates Page Number 890037, Tab 43.

14 And you're talking about

15 this particle size, and you say, By the

16 way, I'm going to get the rest of this well

17 done with no more SS NPT.

18 That's subsurface

19 non-productive time, right?

20 A. Yes, sir.

21 Q. I'm going to get the rest of

22 this well done with no more subsurface

23 non-productive time, and then I'm going to

24 walk on water back to land. Bitch.

25 That is two dudes smarting

00264:01 off to each other, and you're saying that

02 I'm on the well now, things are going to go

03 great, and we're going to get this thing to

04 total depth without any more slow downs,

05 right?

06 A. I had a strong desire to improve

07 the track record of this well.

Page 265:11 to 265:25

00265:11 Q. Who are the Pompano folks

12 upstairs?

13 A. The Pompano folks are -- they --

14 they're working -- they're geologist,

15 reservoir engineers, and production people

16 that work on our offshore Pompano

17 production platform. It would be a

18 platform that Macondo was slated to be tied

19 back to.

20 Q. And so in other words, the idea

77


21 is, is that the Pompano platform was going

22 to be the production platform after the

23 DEEPWATER HORIZON had finished the

24 exploration?

25 A. That was the plan. Yes, sir.

Page 266:21 to 268:12

00266:21 Q. All right. If we could go to

22 Tab 44 on March the 25th, Bates Page

23 Number 16499.

24 You mentioned that you went

25 through two contingency casing strings.

00267:01 This is where it says, We had to burn

02 another contingency casing string at

03 Macondo. It looks as if we'll be drilling

04 our reservoir section with an 8-1/2-inch

05 bit out of a 9-7/8-inch liner. Any bypass

06 core would be cut with an 8-1/2-inch bit.

07 Did I read that correctly?

08 A. Yes, sir, you did.

09 Q. Did the original drill plan have

10 a 9-7/8-inch liner in the plan?

11 A. I don't know.

12 Q. If it did not, why would you be

13 using it here? Is it because you had to

14 set the casing higher up than planned

15 because of the kicks?

16 A. We had to set the 9-7/8-inch at

17 the top of the reservoir.

18 Q. Why?

19 A. It was just -- I'm pretty sure

20 that we had -- we just didn't have any

21 margin.

22 Q. And when you say you didn't have

23 any margin, that would be the margin

24 between your pore pressure and your

25 hydrostatic mud weight?

00268:01 MR. FIELDS:

02 Objection to form.

03 Q. Right?

04 A. No.

05 Q. When you have no margin, what

06 does that mean?

07 A. To me, margin means the window

08 between pore pressure at TD of a

09 hole-section and the fracture gradient by

10 the shoe.

11 Q. Okay. And if you have no

12 margin, is it safe to drill?

Page 268:15 to 268:15

00268:15 A. I -- I don't know.

78


Page 268:24 to 270:05

00268:24 Q. Tab 46, Bates Page Number 1147.

25 In the middle you write an e-mail, at 1:59,

00269:01 to your boss Graham Vinson. And you say,

02 Might drill to TD this next hole-section.

03 Depends on LOT, lithology near the shoe,

04 and sand pressures from the GeoTap.

05 Do you see that?

06 A. Yes, sir.

07 Q. Your boss writes back, No

08 non-productive time. I will buy you

09 all-you-can drink.

10 And you write back, If they

11 want to push this next hole-section to TD,

12 it will all be in God's hands.

13 Did I read that correctly?

14 A. Yes, you did.

15 Q. Now, this next hole-section,

16 what was the casing diameter used in this

17 next hole-section?

18 A. What hole-section are you

19 referring to?

20 Q. This next one.

21 A. I believe it was the 7-inch.

22 Q. Okay. And you're saying if they

23 take a 7-inch casing and go all the way

24 down to total depth, it'll all be in God's

25 hands?

00270:01 A. No. I'm not referring to the

02 casing. I'm referring to --

03 Q. Going that deep?

04 A. I'm referring to drilling

05 further than we think we can.

Page 270:16 to 271:05

00270:16 A. I didn't know that at the time.

17 Q. Okay.

18 A. This is -- we hadn't drilled

19 anything yet.

20 Q. If they want to push this next

21 hole-section to TD, it will all be in God's

22 hands.

23 That means you don't know

24 what's going to happen, you got to rely on

25 the good graces of God to bring your well

00271:01 in for you?

02 A. I think I was just kidding with

03 my boss and making it light. I don't

04 really remember what I was thinking at this

05 particular juncture when I wrote that.

79


Page 272:09 to 272:25

00272:09 Q. Jonathan indicated that you were

10 going to stay to total depth. From a team

11 perspective, I was thinking it might be

12 better for you to come back after this

13 section, showing confidence in the team

14 offshore to deliver the TD section. My

15 concern is simply that they may be of the

16 opinion that by you coming offshore, they

17 could interpret that as the office lost

18 confidence in their ability to deliver. I

19 would think that by now they are tuned up

20 with your visit. And what better way to

21 show confidence in them by returning

22 here -- by you returning here.

23 Do you see that, sir?

24 A. Uh-huh.

25 Q. Yes?

Page 274:06 to 274:13

00274:06 Q. Your opinion was that you-all

07 should hit total depth, stop drilling on

08 the evening of March the 29th?

09 A. Hit total depth on the

10 9-7/8-inch casing section. So we would

11 be -- our TD would not be our final TD.

12 That hole-section of that TD above the

13 target.

Page 277:19 to 278:10

00277:19 Q. If you would, go to Tab 47, an

20 e-mail of chain of March the 29th of 2010.

21 Bates Page Number 116545.

22 At the bottom, Mr. Albertin

23 writes an e-mail that's copied to you.

24 Part of what he says in the third line, it

25 looks like, the way I picked it at least,

00278:01 that I've got some sonic -- I've got sonic

02 pressure -- I've got sonic showing higher

03 pressure, touching 13.9 at current TD.

04 Do you see where that is

05 written?

06 A. I do, sir.

07 Q. You respond, We're RMW to 14.0

08 ppg.

09 What is RMW?

10 A. Oh, okay. Raising mud weight.

Page 280:02 to 280:09

80


00280:02 Q. You write that we plan to manage

03 up -- manage to a 14.5 ECD. Then you say,

04 We can bump up another point if necessary,

05 but obviously we prefer not to, if you

06 believe we are sufficiently overbalanced.

07 So you're telling

08 Mr. Albertin we can go up another pound in

09 our mud weight, right?

Page 280:12 to 280:20

00280:12 A. Another pound? No.

13 Q. I'm sorry. Another point.

14 Let's use that.

15 A. Yes. So Marty -- Mr. Albertin

16 and I are -- are collaborating to try to

17 figure out where we are relative to pore

18 pressure so we could give the driller that

19 number. So my team, Tiger Team, we provide

20 the input to the drillers.

Page 281:14 to 281:20

00281:14 Q. Have you ever seen BP's golden

15 rules of safety?

16 A. I have.

17 Q. You have the ability, as a BP

18 employee, to say I stopped this job, you're

19 not going deeper, it's not safe. Right?

20 A. Yes, I do.

Page 282:03 to 282:15

00282:03 Q. Okay. And what Albertin writes

04 next is, At the current build rate it looks

05 like the shale PP will be 14.1 at

06 17,200 feet. The sand PP will be higher.

07 Hope to see another break in the build rate

08 soon.

09 You respond back at 6:01 in

10 the evening. If we really believe that

11 sand PP at 17200 could be as high as 14.4

12 ppg, then we need to start having some

13 serious discussions about pulling the plug

14 early.

15 Did I read that correctly?

Page 282:22 to 283:12

00282:22 Q. Let me ask it again.

23 Did you write, quote, If we

24 really believe that the sand pore pressure

25 at 17,200 feet could be as high as 14.4

81


00283:01 ppg, then we need to start having some

02 serious discussions about pulling the plug

03 early.

04 Did I read that correctly?

05 A. Yes, you did.

06 Q. You write at the end of the

07 sentence -- or the end of the paragraph, We

08 can't cover a 14.4 sand pore pressure at

09 total depth should a sand show up at

10 17,200.

11 Did I read that right?

12 A. Yes.

Page 283:19 to 283:22

00283:19 Q. Sure. But when we're talking

20 about -- what you're taking about in this

21 e-mail, you're saying we need to pull the

22 plug at 17,200 feet?

Page 284:06 to 285:06

00284:06 A. What I'm -- what I'm saying is,

07 I'm preparing the teams to have these

08 conversations. I don't -- I don't know

09 what's going to happen when we actually

10 drill it. We might see pressure regression

11 from our indicators. We might see a

12 pressure regression going into our

13 reservoir. So I don't necessarily know at

14 the time. I'm having a conversation ahead

15 of time to be able to have contingencies

16 and know what we're -- what we're looking

17 for.

18 Q. Except you've already told me

19 that the pore pressure does seem to

20 continue to increase with depth?

21 A. To a point.

22 Q. Go to Tab 55, you're sent a

23 summary by Kate Paine on April the 3rd.

24 And she says precisely that with respect to

25 this wellbore, the last sentence.

00285:01 The pore pressure does seem

02 to continue to increase with depth, though

03 the filtering function of the data shows

04 excessive swings at times?

05 Did I read that correctly?

06 A. Yes, sir.

Page 285:11 to 285:16

00285:11 Q. Now, that is -- is down at

12 17,835 feet, right? Right?

82


13 A. Yes, sir.

14 Q. You're 635 feet below where you

15 said we need to have serious discussions

16 about pulling the plug early, right?

Page 285:19 to 285:19

00285:19 A. Yes.

Page 287:18 to 288:09

00287:18 Q. Now, if you go to Tab 52,

19 three days later. Bates Page Number 6046.

20 On April the 2nd, Martin

21 Albertin writes -- at the very end of

22 the -- the e-mail, he says, At any rate, we

23 are probably all on the same page here. We

24 should manage drilling this last

25 hole-section with the expectation that the

00288:01 shales will fail at about the predicted

02 values, less than overburden, which is

03 about 15.5 ppg at the shoe.

04 A. Uh-huh.

05 Q. Did I read that correctly?

06 A. Yes, sir.

07 Q. And then if we take it -- the

08 next day. Tab 54, Bates Page

09 Number 247798.

Page 288:14 to 288:18

00288:14 Q. Now, if you go to the second

15 page, it's a little hard to read, but I

16 think I've deciphered it correctly. After

17 the bottom section, it says comments.

18 A. Uh-huh.

Page 288:21 to 290:03

00288:21 Q. And one of the things that's

22 written in the comments, starting with the

23 third line, is the -- the resistivity and

24 sonic models are showing a sharp increase

25 in pore pressure.

00289:01 The decision was made to

02 weight up to 14.5 ppg to prevent getting

03 caught behind and to give us a chance to

04 gather more info on what is happening. As

05 per the hole-section preview, greater than

06 14.6 ppg mud weight will require a consult

07 with Houston subsurface and drilling.

08 Did I read that correctly?

09 A. Yeah, I think that's what it

83


10 says.

11 Q. Now, on the 29th Mr. Morel had

12 told you that the plan was -- was to go no

13 higher than 14.0 ppg surface?

14 A. What -- what --

15 Q. Tab 48.

16 A. That was Tab 48.

17 Q. He says, Right now the plan is

18 to go no higher than 14.0 ppg surface.

19 Right?

20 A. He -- yes. That's what --

21 that's what Mr. Morel says.

22 Q. But by April the 3rd, the

23 PowerPoint shows that the decision was made

24 to weight up to 14.5 ppg to prevent getting

25 caught behind. And now, if you go greater

00290:01 than 14.6 ppg mud weight, that's going to

02 require a consult with the Houston

03 subsurface drilling group, right?

Page 290:06 to 290:07

00290:06 A. That's what Ms. Skripnikova

07 said.

Page 290:23 to 292:07

00290:23 A. It looks to me like we're in two

24 different hole-sections again.

25 Q. Okay. Let me ask you this:

00291:01 When the mud weight, hydrostatic mud weight

02 is too high relative to the pore pressure,

03 that's what creates fracture formation and

04 you get lost returns, right?

05 A. You can. Yes.

06 Q. On April the 4th, that precise

07 thing happened. You started seeing lost

08 circulation again, right?

09 A. We saw lost circulation. Our

10 estimated reservoir pressures were supposed

11 to be in the realm of 14.1, 14.2. Our

12 actual reservoir pressures were 12.6.

13 Q. And you weighted up. So what

14 did it cost?

15 A. We didn't know, at the time,

16 what -- what the reservoir pressures were.

17 So it was one of those situations where

18 we -- it was just the uncertainty that's

19 built into managing the mud weight.

20 There's always a degree of uncertainty.

21 And when your -- and when your reservoir

22 comes in a pound and a half underbalanced,

23 it kind of deals you a hand that you might

24 not necessarily be prepared for. And

84


25 not -- it wasn't necessarily mismanagement

00292:01 of mud weight that caused losses, but

02 that's, in fact, what happened.

03 Q. Well, in fact, you had weighted

04 up to -- in excess of 14.5 at the time you

05 had the lost circulation on April the 4th,

06 right?

07 A. Yes, sir.

Page 292:24 to 293:04

00292:24 Q. We are now 800 feet below where

25 you said we need to have some serious

00293:01 discussions about pulling the plug early

02 back on March the 29th?

03 A. That was in a previous

04 hole-section, sir.

Page 293:07 to 294:10

00293:07 Q. Okay. Let's go to Tab 58, Bates

08 Page Number 2081.

09 On April the 5th you write,

10 We just drilled the reservoir section.

11 Things are looking fairly good at this

12 point. I would lean towards not coring,

13 but a lot is probably left to be seen from

14 the wireline evaluation. Currently, we're

15 fighting both lost circulation and high

16 gas, so we may -- we might be at the end of

17 the line as far as drilling goes.

18 Did I read that correctly?

19 A. Yes, sir, you did.

20 Q. Now, is this the end of the line

21 as far as drilling goes in this section, or

22 the end of the real line for all drilling?

23 A. I believe this refers to the end

24 of the line as far as all drilling. The

25 fact that our reservoir came insofar

00294:01 underpressured we were fracturing our

02 reservoir and incurring losses at ECDs far,

03 far, far less than anticipated. So we got

04 to the point when -- we got to the point

05 where our reservoir was so underpressured.

06 Once that hand was dealt to us, we were --

07 we were resolved to discontinue drilling

08 once we -- once we -- once we were unable

09 to drill any farther without incurring

10 losses.

Page 297:19 to 298:12

00297:19 Q. April 4th, because of the fact

85


20 that your mud weight was heavier than the

21 pore pressures, you all fractured the

22 formation and lost returns, correct?

23 A. Yes, sir. With our reservoir

24 coming in so grossly underpressured

25 compared to our estimates, our planned mud

00298:01 weight did, in fact, fracture the

02 reservoir.

03 Q. And this fractured reservoir was

04 at total depth, right?

05 A. Yes, sir. We had to drill

06 through the reservoir before we could

07 employ the downhole instrumentation to take

08 the pore pressure.

09 Q. In terms of where Halliburton's

10 cement job was ultimately placed, you had

11 them do a cement job into a formation that

12 you knew you had fractured?

Page 298:15 to 299:07

00298:15 Q. True?

16 A. I don't -- I don't know.

17 that's -- that's not in my area of

18 expertise.

19 Q. Let's put it this way. At the

20 TD or total depth, you had an understanding

21 before anybody ever started the cement job

22 that that formation had been fractured,

23 right?

24 A. I don't know where we were

25 losing. I don't know where it was being

00299:01 fractured. We were -- we were having

02 losses. You can't debate that. It's not

03 always easy to tell where you're incurring

04 your losses.

05 Q. If mud can be lost into a

06 fractured formation, can Halliburton's

07 cement be lost there as well?

Page 299:10 to 299:15

00299:10 A. I do not know anything about

11 cement rheology, sir.

12 Q. In terms of your losses, can you

13 give the jury some sort of an understanding

14 of the magnitude of the losses that you had

15 seen on this well?

Page 299:18 to 301:25

00299:18 A. I really don't know the --

19 volumetrically, how -- what the degree of

86


20 losses were.

21 Q. If you would, go back to Bates

22 page -- I mean Tab 59, your e-mail

23 exchanges with Mrs. Kirkland that we

24 started with. If you would, go to the last

25 page of Tab 59, Bates Page Number 895060.

00300:01 On April the 6th of 2010,

02 at 7:00 a.m., did you write Tara Kirkland

03 an e-mail entitled, Good Morning,

04 exclamation point?

05 A. What Bates number?

06 Q. 895060. The last page of the

07 tab.

08 A. Yes, sir.

09 Q. Hey, there. Good morning.

10 Sorry I missed your e-mail last night. I

11 was lame and went to bed at, like, 9:30

12 last night. My week is off to a busy

13 start.

14 Did I read that correctly

15 so far?

16 A. Yes, sir.

17 Q. On April the 6th at 7:00 a.m.,

18 did you write to Tara Kirkland, quote, The

19 well I'm working is turning into a bit of a

20 problem. Long story short, and since

21 you're in the mud business you'd have an

22 appreciation for it, we've lost about

23 15,000 barrels of mud throughout the course

24 of the well and still having circulation

25 issues. Anyway, people are pretty uptight

00301:01 around the office so far this week. I'm

02 ready for this well to be done.

03 Did I read that correctly?

04 A. Yes, sir, you did.

05 Q. Now, April the 6th, when you're

06 telling Ms. Kirkland that you've lost

07 15,000 barrels of mud, that is two weeks to

08 the day before this explosion occurred,

09 right?

10 A. Approximately, yes.

11 Q. As we move forward -- go to

12 Tab 61, April the 7th. If you go to the

13 last page. Bates Page Number 15685. Naoki

14 Ishii writes to Michael Beirne.

15 Do you know who Naoki Ishii

16 is?

17 A. Yes, sir. He's a partner

18 contact.

19 Q. MOEX? Okay.

20 A. Yes, sir.

21 Q. MOEX is asking Michael Beirne,

22 Do you have any update on Macondo. Is BP

23 still trying to stabilize the wellbore?

24 You try to stabilize a

87


25 wellbore that you have fractured?

Page 302:03 to 303:09

00302:03 A. That's one instance where you

04 would if you're having losses. You

05 fracture the wellbore every time you do a

06 leak-off test.

07 Q. On the page before, Mr. Beirne

08 writes back, The wellbore is stabilized and

09 we're tripping out of the hole.

10 Do you see that?

11 A. What's the Bates number, please?

12 Q. 15684. At the bottom.

13 A. Yes, sir.

14 Q. And then the partner says, We're

15 glad to know that the wellbore is

16 stabilized.

17 And then at the top, Naoki

18 Ishii writes back to Michael Beirne. And

19 on Number 2, asking if BP will conduct a

20 flow test to find out if our discovery is

21 oil or gas.

22 Do you see that, sir?

23 A. I do.

24 Q. And then you write back on

25 Page 1, BP does not conduct drillstem tests

00303:01 in the Gulf of Mexico exploration wells due

02 to safety and environmental concerns.

03 Did I read that correctly?

04 A. Yes, sir.

05 Q. Now, at this point in time, was

06 there some desire by your partners to go

07 deeper in order to test another formation

08 that you were going to originally test at

09 20,200 feet?

Page 303:12 to 303:12

00303:12 A. Yes, it was.

Page 303:19 to 304:18

00303:19 Q. Tab 63, Bates Number 28569.

20 This is an e-mail from you to Paul Chandler

21 at Anadarko.

22 That's your other partner

23 besides MOEX, right?

24 MS. KUCHLER:

25 Object to the form.

00304:01 A. That is correct, sir.

02 Q. April the 9th at about three

03 lines down, you write, We've washed back to

88


04 bottom and are about to return to drilling.

05 Did I read that correctly?

06 A. Yes, sir.

07 Q. Who made the decision to return

08 to drilling after the e-mails that you

09 wrote a couple of days before?

10 A. The -- that decision is -- is

11 housed within the drilling operations team.

12 Q. To put it politely, that is a

13 decision that you would not have made,

14 agree?

15 MR. FIELDS:

16 Objection, form.

17 A. No, sir. That's not my

18 decision.

Page 304:25 to 305:01

00304:25 Q. You wanted them to stop drilling

00305:01 and they kept drilling?

Page 305:04 to 305:17

00305:04 A. No, I did not.

05 Q. We're about to return to

06 drilling. After a brief overview, I think

07 we're near the base -- we think we're near

08 the base of the reservoir. We've been

09 aggressively fighting losses.

10 Did I read that correctly?

11 A. Yes, sir.

12 Q. On April the 9th, 11 days before

13 this explosion, while you-all are

14 aggressively fighting losses, somebody made

15 the decision to drill deeper.

16 Can you tell me who did

17 that?

Page 305:20 to 305:20

00305:20 A. No, sir, I do not know.

Page 306:22 to 307:22

00306:22 Q. In the middle of the page,

23 Galina Skripnikova sends you a file for a

24 call tomorrow, April the 10th. It says,

25 Looks like there is no wet sand below M56.

00307:01 A. Yes, sir. I see that.

02 Q. At the bottom it says, As

03 there's no wet sand, Stuart's suggestion

04 for CMR turning is sand at 17820.

05 What is CMR turning?

89


06 A. CMR tuning.

07 Q. I'm sorry.

08 A. I -- I don't know.

09 Q. You write back, Sounds good,

10 Galina. Thank you. My money is on that

11 sand at 18,260 feet that we had previously

12 coined as wet, being full of drilling

13 fluid. Just a hunch.

14 Is that what you wrote?

15 A. Yes, sir.

16 Q. When you say full of drilling

17 fluid, what did you mean?

18 A. After we uncovered that sand and

19 it showed a different signature on the

20 logs, it was unlike the oil-bearing sands

21 above, I surmised that that signature might

22 indicate that that was a loss zone.

Page 341:18 to 341:21

00341:18 Q. The reference I'm giving you is

19 Tab 74, an e-mail from you to Mr. Lacy on

20 April the 15th of 2010 at 6:56 p.m. BP

21 Bates Number 891838.

Page 344:14 to 345:01

00344:14 Q. In addition, you had a plan to

15 collect one set of canned cuttings at

16 90-foot sections of the 13-5/8-inch casing

17 point, at 30-foot composite sections from

18 the 13-5/8 casing point to TD, and two

19 additional sets of can cuttings that shows

20 zone with oil staining and fluorescence.

21 That was the plan?

22 MR. FIELDS:

23 Objection, form.

24 A. Per that document, yes.

25 Q. And the plan was to ship those

00345:01 to Weatherford labs, right?

Page 346:16 to 346:20

00346:16 Q. Well, you just happened to take

17 all those samples on the way down, right?

18 A. We did.

19 Q. You have all the data with

20 Weatherford, right?

Page 347:02 to 347:03

00347:02 A. All the data was sent to

03 Weatherford.

90


Page 352:18 to 352:21

00352:18 BY MS. FLICKINGER:

19 Q. Hi, Mr. Bodek. My name is Nancy

20 Flickinger from the Department of Justice

21 on behalf of the United States.

Page 354:24 to 355:11

00354:24 Q. All right. I want to talk a

25 little bit about the partners.

00355:01 A. Okay.

02 Q. Anadarko and MOEX.

03 A. Yes, ma'am.

04 Q. The co-lessees.

05 Part of your responsibility

06 was to coordinate and communicate with

07 them, correct?

08 A. Yes, ma'am.

09 Q. And what information did they

10 have -- once they came onboard, what

11 information did they have access to?

Page 355:14 to 362:19

00355:14 A. It's very a comprehensive

15 question. I'll -- I'll try to step through

16 it methodically.

17 The first thing that we'll

18 do is we'll set up partners with access to

19 an online data storage site called the

20 WellSpace. I will contact the contact

21 people at -- partners and ask them for a

22 list of individuals that need to have

23 access to well data that is generated while

24 drilling Macondo. I'll set up a WellSpace,

25 which is basically an online SharePoint

00356:01 site, which has a folder structure that's

02 consistent with the types of data that's

03 coming off the rig. These -- this

04 wellsite -- these wellsite folders are

05 populated with the various types of data

06 when they're -- whenever they're available,

07 or twice daily when it comes, mud logs or

08 waterline logs -- I'm sorry. Mud logs or

09 LWD logs. They will also have access to

10 INSITE Anywhere.

11 INSITE Anywhere is a

12 real-time data transmission applet that is

13 maintained by -- by Halliburton. I should

14 say that WellSpace is also maintained by --

15 by Landmark, which is a Halliburton

91


16 corporation.

17 The real-time data -- the

18 INSITE streams real-time data from the rig.

19 So in a similar way, I will -- I e-mail

20 partners -- the partner contacts that I was

21 given from -- from the -- our negotiation

22 team. I e-mail our partner contacts with

23 an e-mail that will say something to the

24 extent of who are -- who are the

25 individuals that you consider operations

00357:01 critical, that you would need to have

02 real-time access to drilling data in a

03 real-time fashion as being generated by the

04 rig. And this INSITE Anywhere, once you're

05 granted access, you're granted access via

06 your e-mail and password. And it's a

07 standard Windows-based applet that -- that

08 displays on your computer screen. And you

09 can manipulate the different functions in

10 such a way that you can observe a myriad of

11 real-time data drilling parameters.

12 So those -- that the -- the

13 WellSpace and the INSITE, that's the -- the

14 core method of -- of communication. With

15 WellSpace, there's things in WellSpace.

16 This is the -- the data drop box. There's

17 such things in a WellSpace as daily

18 drilling reports.

19 Q. Uh-huh.

20 A. Geological reports, pore

21 pressure reports, wireline logs, mud logs,

22 electrical logs, and a couple other

23 miscellaneous folders that don't

24 necessarily come to mind right now. There

25 is a paleo folder, which may or may not

00358:01 have been populated. A BAT sonic folder

02 may not have been populated. I can't

03 remember -- I can't recall all the

04 specifics right now, what was entirely in

05 that -- in that directory. But that gives

06 you an idea of some of the -- some of

07 the -- some of the pieces of data that --

08 that partners would have had access to. If

09 they just simply had an Internet

10 connection, they could log onto a site.

11 The WellSpace didn't require a specific --

12 download a specific app in a computer. It

13 was simply an HTML web based SharePoint

14 site. So those are the two core pieces.

15 In addition to that, you

16 know, I would have telephone conversations

17 and e-mail transmittal back and forth

18 between partners and various individuals

19 that -- at the partner -- at the partners.

20 Q. And how frequently -- the

92


21 WellSpace folders, how frequently were

22 those updated?

23 A. It depends on the nature of the

24 data. For instance, a geological -- I'm

25 sorry. A detail report will be generated

00359:01 and posted every day. So regardless of

02 operations, there would be -- there will be

03 a -- a geo -- or I'm sorry, a drilling

04 operations -- a daily drilling report

05 posted.

06 Other pieces of data are

07 kind of contingent on whether we're

08 actually making -- we're actually making

09 progress, we're actually drilling and

10 uncovering new information, new -- making

11 new hole. There won't be a -- there won't

12 be a geological report if we're -- had --

13 if we hadn't uncovered any new geology.

14 There won't be a pore pressure report

15 unless we uncover -- you know, unless we

16 made progress. There won't be logs updated

17 unless we're --

18 Q. Unless there's some --

19 A. -- we're actually drilling. The

20 engineer log will be updated because

21 that -- engineering logs will -- just

22 monitored different -- different drilling

23 operations that aren't necessarily

24 associated with making hole. They're

25 updated twice daily.

00360:01 When -- when we are

02 drilling, the mud logs and the MWD logs

03 are -- are uploaded twice daily. There

04 will be a -- a friendly format like a PDF

05 or a .tif, something that you can view with

06 any generic data viewer. And we try to --

07 we try to up -- update those twice a day.

08 The real-time data, of

09 course, is -- it's in real-time. Anytime

10 you want to pull up that applet, you can --

11 you can observe different parameters

12 associated with whatever drilling

13 operations happens to be ongoing at that

14 time.

15 Q. So what would be some examples

16 of that?

17 A. Of what?

18 Q. Of the real-time data.

19 A. For instance, if we are -- if we

20 are drilling -- say, for instance, we're

21 drilling. And you can pull up a screen

22 that will have your -- your gamma ray, your

23 resistivity. You can look at, like I said,

24 countless -- you can look at any -- any of

25 the logs, associated logs. You can look at

93


00361:01 the pressure logs, the ECD log, the surface

02 mud weight log. It's basically a streaming

03 log that shows a -- the various tracks that

04 will show a value with a depth. And you

05 can manipulate -- you can manipulate the

06 software to show any -- any data that --

07 any piece of data that you would -- that

08 you consider relevant to whatever you

09 happen to be looking at.

10 For the most part, when

11 we're drilling, I'll be looking at

12 things -- I'll be looking at the mud log.

13 I'll be looking at the gamma -- gamma ray,

14 which is the indicator of lithology.

15 Resistivity, which is the indicator of --

16 of fluid type. And you can look at a host

17 of drilling parameters, weight on bed, rate

18 of penetration, rotational speed, torque.

19 You could look at background gas. And

20 typically, I'll be on -- I'll have

21 background gas up as well. You can look at

22 hook load, weight on bed -- wait, I've

23 already mentioned that.

24 Q. When you said ECD, what is that?

25 A. That's the equivalent

00362:01 circulating density. So when we're talking

02 about mud weight, we have three terms that

03 we'll use to reference the mud weight.

04 We'll use surface mud weight. That's the

05 mud that goes -- the weight of the drilling

06 fluid when it goes in the well.

07 Q. Uh-huh.

08 A. The static density, which is the

09 weight of the drilling fluid -- the

10 equivalent weight of the drilling fluid at

11 TD. And the circulating density, which is

12 when we're circulating, the hole is loading

13 up well cuttings and there's frictional

14 forces associated with pushing mud out

15 the -- the ports and the bit. And you'll

16 actually -- the rocks will actually be

17 subjected to a -- a -- even relatively

18 higher mud weight than just the -- the

19 static mud weight.

Page 363:07 to 365:17

00363:07 Q. Well, let's do this. Turn to

08 Tab 4, please, which is Bates Number

09 BP-HZN-MBI00175753.

10 (Exhibit Number 1213 marked.)

11 A. Yes, ma'am. I have that

12 right -- available in front of me.

13 Q. Okay. And is this the list of

14 people from Anadarko who had access to

94


15 Macondo WellSpace?

16 A. These are people from Anadarko

17 that had access to WellSpace. I cannot say

18 for sure that this is the final list, but

19 at the time that I sent this, these are the

20 people that I -- I requested to have access

21 to WellSpace.

22 Q. Right. And then some more may

23 have been added later on?

24 A. There was often -- I'll get --

25 I'll get one off e-mail saying such and

00364:01 such is a person new to the group, can you

02 please add them. And I will do so

03 accordingly. And I'm sure you've seen a

04 couple of e-mails like that.

05 Q. Right. And of this group of

06 people, were there some that you dealt with

07 fairly frequently?

08 A. There's a couple that I recall

09 having dealt with. John Kamm was my first

10 contact.

11 Q. Uh-huh.

12 A. He was the -- he was a

13 counterpart to myself. He was the

14 operations geologist. He was my -- the

15 first person I contacted to get the wheels

16 moving as far as getting partners setup

17 with -- with data transmission. Paul

18 Chandler is a geologist, so I spoke with

19 him about subsurface issues. And Josh

20 Nichols was the -- was the drilling

21 engineer.

22 So much like my role at BP,

23 I'm a liaison between the drillers and the

24 subsurface. It was that way with Anadarko,

25 that I dealt with Paul Chandler in the

00365:01 subsurface and Mr. Nichols and the -- on

02 the engineer standpoint. So I would field

03 questions from -- to both anyway.

04 Q. So they would call you up from

05 time to time with questions?

06 A. Yes, ma'am. Or send me an

07 e-mail.

08 Q. Uh-huh. Did you have any sense

09 how often they were looking at the

10 information up on WellSpace and INSITE?

11 A. My best -- I don't know for

12 sure. My best indicator would be when I

13 received an e-mail in reference to

14 something that I -- that I had recently

15 posted. I can't -- I cannot say for sure

16 how often each one of these individuals may

17 or may not have access to data.

Page 366:05 to 366:11

95


00366:05 Q. To the extent there were kicks

06 in the well or well control issues and

07 drilling stopped for a few days --

08 A. Uh-huh.

09 Q. -- would they call you up?

10 Did they know about those

11 incidents?

Page 366:14 to 367:03

00366:14 A. Yes. They seemingly did. There

15 was -- I remember getting -- getting

16 several e-mails where they would ask me,

17 hey, what's going on. There's times I

18 would -- I would volunteer data if -- if --

19 you know, in the -- in the daily drilling

20 report, you only really get one line that

21 gives you the 24-hour forecast. So if

22 there's something that -- that was going to

23 be a multi -- something that would -- an

24 operation that would -- they may not

25 intrinsically understand from just looking

00367:01 at the drilling report, I might give them a

02 call and let them know, hey, this is kind

03 of what we have going on.

Page 367:08 to 367:10

00367:08 Q. Do you know if these individuals

09 were from Anadarko Petroleum, or from some

10 other Anadarko corporation?

Page 367:13 to 369:13

00367:13 A. I -- since you ask it like that,

14 I don't know. I've always been operating

15 under the assumption it was Anadarko

16 Petroleum Corporation.

17 Q. Okay. Let's turn to -- turn to

18 Tab 15, please. This is

19 BP-HZN-MBI00074934.

20 (Exhibit Number 1214 marked.)

21 A. Yes, ma'am.

22 Q. So this is a note from Michael

23 Beirne to you and to other people, dated

24 October 27th.

25 A. And this is -- we're referring

00368:01 specifically to the -- the top one?

02 Q. Yes.

03 A. Okay.

04 Q. And in that he's requesting

05 materials that need to be sent to Mitsui

06 and Anadarko, correct?

96


07 A. Yes. That's what it -- what it

08 appears to be.

09 Q. Okay. The evaluation plan.

10 What's the evaluation program?

11 A. It's the data that -- the

12 evaluation plan is the data that we -- the

13 data that we plan to acquire from the well.

14 So while we're drilling, we'll be

15 collecting LWD data. We'll be collecting

16 gamma ray and resistivity logs while we're

17 drilling. We'll be collecting certain

18 geochemical samples, like head space gas or

19 flowline gas samples. Collecting cuttings.

20 And then probably more specifically with

21 the evaluation program, it refers to how

22 we're going to evaluate the reservoir. So

23 it outlines the evaluation program in -- in

24 the reservoir as far as how we're going to

25 evaluate it via wireline after we drill to

00369:01 objective depth.

02 Q. Okay. It also says, We'll put

03 together a detailed well plan to provide

04 Mitsui and Anadarko.

05 And Mitsui. Can you tell

06 me who Mitsui is?

07 A. I take them as the -- as a

08 partner. MOEX. I've heard them --

09 Q. Using it interchangeably with

10 MOEX?

11 A. I've always used Mitsui, and I

12 guess really late in the game, I was kind

13 of told it was MOEX.

Page 369:25 to 369:25

00369:25 Q. Okay. If you could go to Tab 6.

Page 370:03 to 370:19

00370:03 You can see there's a

04 number of individuals listed under Mitsui?

05 (Exhibit Number 1215 marked.)

06 A. Uh-huh.

07 Q. And these are individuals that

08 will have access to INSITE Anywhere.

09 With whom did you deal most

10 frequently on the -- on those list of

11 individuals?

12 A. For Mitsui?

13 Q. Yes.

14 A. I dealt with Naoki Ishii.

15 Q. Okay. Anybody else?

16 A. No.

17 Q. Okay. So all your

97


18 communications with MOEX/Mitsui came

19 through Naoki Ishii?

Page 370:22 to 370:25

00370:22 A. Yes.

23 Q. Okay. Can you turn to Tab 8,

24 please. And Bates Number is DWHMX00070342.

25 (Exhibit Number 1216 marked.)

Page 371:03 to 371:08

00371:03 Q. And here is a correspondence

04 with Mr. Ishii?

05 A. Yes.

06 Q. Is this representative of the

07 kinds of communications you might have with

08 him?

Page 371:11 to 372:02

00371:11 A. Yes.

12 Q. At the top, he says, Thank you

13 Bobby. Please let me know when you resume

14 drilling. Even in weekends, I need to

15 report to Tokyo. Thank you for your

16 understanding.

17 Did you have a sense, from

18 your communications with Mr. Ishii, as to

19 what extent he was reporting back to Tokyo?

20 A. I did not.

21 Q. You did not?

22 A. No, ma'am.

23 Q. Did you get any sense from your

24 communications with him as to -- to what

25 extent he had authority to make decisions

00372:01 independently without reporting back to

02 Tokyo?

Page 372:05 to 372:16

00372:05 A. I did not get that -- I did not

06 get a sense of that.

07 Q. Okay. One more person. If you

08 turn to Tab 11. And Anadarko is adding a

09 Mr. Bob Quitzau to the INSITE access list.

10 Is this another person that

11 you communicated with?

12 (Exhibit Number 1217 marked.)

13 A. Yes, ma'am.

14 Q. On behalf of Anadarko?

15 A. Yes, ma'am.

16 Q. And what was his background?

98


Page 372:19 to 372:22

00372:19 A. I believe he was a drilling

20 engineer consultant.

21 Q. Okay. Associated with Anadarko

22 Petroleum, to the best of your knowledge?

Page 372:25 to 373:07

00372:25 A. Yes, ma'am.

00373:01 Q. Okay. Okay. Let's look at

02 Tab 32.

03 Did you get the sense that

04 Anadarko was following progress at the well

05 with a certain level of technical

06 expertise?

07 (Exhibit Number 1218 marked.)

Page 373:10 to 373:15

00373:10 Q. Do you understand that question?

11 A. Could -- could you restate that

12 for me, please?

13 Q. Did they understand from a

14 technical perspective what was happening at

15 the well?

Page 373:18 to 373:18

00373:18 A. I believe they did.

Page 375:08 to 375:10

00375:08 Q. Okay. And Mr. Quitzau is asking

09 you what's going to happen with the rest of

10 the well, correct, 9-7/8-inch casing?

Page 375:13 to 375:25

00375:13 A. He is asking me a couple of

14 questions that pertain to what our planned

15 operations were -- are for subsequent

16 points in the well.

17 Q. And he's asking you what the

18 total -- what -- what the casing will be

19 when you reach total depth, correct?

20 A. Yes.

21 Q. Do you remember having

22 discussions with Mr. Quitzau concerning

23 progress at the well and the use of

24 contingency liners and --

99


25 A. Yes, I do.

Page 376:05 to 376:22

00376:05 (Exhibit Number 1219 marked.)

06 A. Could I -- could I read this?

07 I'm not --

08 Q. Yeah.

09 A. I'm not copied and I've never

10 seen this correspondence before.

11 Q. Okay.

12 A. Thank you. Okay. Ma'am, I'm

13 finished reviewing the document.

14 Q. Okay. So these e-mails reflect

15 the conversation that you had with

16 Anadarko's representative concerning events

17 at the well as of April -- April 5th,

18 correct?

19 A. That's how I interpret it.

20 Q. And at that point, you were

21 having some losses at the well and some

22 other difficulties?

Page 376:25 to 377:06

00376:25 A. We were having operational

00377:01 issues. I would say, yes, they were

02 difficulties.

03 Q. Okay. And you had a phone call

04 with him. So Anadarko through him was

05 appraised of what the situation was,

06 correct?

Page 377:09 to 377:21

00377:09 A. Yes. That's how I interpret it.

10 Q. Okay. He is suggesting here

11 that -- or bringing up the point of

12 reducing the mud weight to 14.3 ppg.

13 Do you see that on the --

14 A. On the previous --

15 Q. On the other page, yes.

16 A. Okay.

17 Q. In your conversations with

18 Anadarko's representatives, would you

19 sometimes have that kind of back and forth,

20 have you thought about doing this, have you

21 thought about doing that?

Page 377:24 to 378:11

00377:24 A. If it's something regarding

25 Mr. Quitzau, anything operational would be

100


00378:01 more pertinent to a driller, I will speak

02 with a member of our drilling contingent on

03 that. If it's subsurface related, I might

04 go to speak with -- with Chuck Bondurant.

05 It -- it depends on the nature of the

06 request. I'll -- which way I'll -- which

07 way I direct their question.

08 Q. So when you would get a request

09 for information from them, you would go to

10 the appropriate person to get it --

11 A. Information or --

Page 378:14 to 378:23

00378:14 A. -- or input, whether it be

15 subsurface or drilling. Like I said, I'm a

16 liaison between both, so I just take

17 whatever -- if it was Mr. Chandler, I go to

18 subsurface. If it was Mr. Quitzau, I would

19 go to the drilling.

20 Q. So sometimes they would give you

21 input, and then you would make sure that

22 that was --

23 A. That was communicated.

Page 379:01 to 379:05

00379:01 Q. -- communicated?

02 A. Yes, ma'am.

03 Q. And did -- did that sometimes

04 alter BP's decision as to how they were

05 going to proceed?

Page 380:05 to 381:01

00380:05 A. I don't know specifically. The

06 input was communicated. I don't know how

07 BP engineers implemented the input into

08 their practices.

09 Q. Okay. Go to Tab 44. Bates

10 Number BP-HZN-2179MDL00044347.

11 This is an e-mail dated

12 Monday, April 12th, from Michael Beirne to

13 you, among other people.

14 (Exhibit Number 1220 marked.)

15 A. Yes, ma'am.

16 Q. And it says, MOEX has requested

17 an explanation as to why we did not seek

18 approval to call objective depth this

19 weekend due to the fact none of the three

20 criteria were achieved. I need to provide

21 them a brief explanation that due to safety

22 and wellbore stability issues we had to

101


23 stop where we did.

24 Is it your understanding

25 that in order to call total depth, you had

00381:01 to obtain the partners' approval?

Page 381:04 to 381:04

00381:04 A. I don't know. It's a partner --

Page 381:11 to 382:12

00381:11 Q. Okay. And so what you're saying

12 is Michael Beirne would be the person who

13 would know that better than you do?

14 A. Yes, ma'am. And he was looking

15 for a bit of insight as to why BP made the

16 decision that BP did.

17 Q. Okay. Then you turn to your

18 response.

19 A. Yes, ma'am.

20 Q. Okay. And this is an e-mail

21 where you say there's no drilling margin.

22 Okay.

23 Drilling ahead any further

24 would unnecessarily jeopardize the

25 wellbore?

00382:01 A. Yes, ma'am.

02 Q. We had simply run out of

03 drilling margin. At this point, it became

04 a well integrity and safety issue.

05 So this is the situation as

06 of April 13th?

07 A. Yes, ma'am.

08 Q. Okay. So would this

09 information -- the partners were aware of

10 the losses and the difficulties and the

11 lack of drilling margin of the well,

12 correct?

Page 382:15 to 382:22

00382:15 A. I'm not sure. Per that -- per

16 the document we examined a few moments ago,

17 they -- they bring up issues that were

18 associated with the drilling problems that

19 we experienced in the reservoir section.

20 Q. Okay. Okay. And turning to

21 Tab 47, please. This is BP-HZN-MBI129063.

22 (Exhibit Number 1221 marked.)

Page 382:25 to 383:07

00382:25 Q. Okay. And again, this is

102


00383:01 Michael Beirne sending an e-mail to you.

02 Just talked with Anadarko

03 and they are onboard with proceeding to TA

04 the well.

05 Does this refresh your

06 memory at all as to whether they needed to

07 be onboard with the TA of the well?

Page 384:25 to 385:01

00384:25 Q. Bobby, I'm David Pote with the

00385:01 state of Louisiana. And Counsel Mikal,

Page 385:12 to 385:20

00385:12 How much time did you spend

13 preparing for today's deposition?

14 A. I spent two and a half -- two

15 and a half business days last week.

16 Q. Okay. So that would amount to

17 what, 20 hours? Is that -- two and a half

18 business days, am I right about that?

19 A. Approximately 20 hours, yes,

20 sir.

Page 413:24 to 414:01

00413:24 Q. Have you ever heard that -- that

25 that kick went undetected for more than 30

00414:01 minutes?

Page 414:06 to 414:10

00414:06 A. Yes, ma'am. I have heard that.

07 Q. You have. Who did you hear that

08 from?

09 A. I heard that from the drilling

10 engineer.

Page 414:13 to 414:17

00414:13 Q. From what drilling engineer?

14 A. Drilling engineer, I learned

15 that from -- Mark Hafle mentioned it to me.

16 Q. And did he also tell you why he

17 thought that was?

Page 414:20 to 414:24

00414:20 A. I don't remember specifically.

21 We had a short conversation. I can't

22 recall specifics.

103


23 Q. Did he mention to you that --

24 that Halliburton was stretched thin?

Page 415:02 to 415:04

00415:02 A. No, ma'am. He didn't mention --

03 I don't recall him mentioning that to me.

04 Q. Now, you testified earlier today

Page 415:25 to 417:10

00415:25 Q. So your purpose was to go and

00416:01 reestablish relationships?

02 A. Reengage the team. Talk -- talk

03 to my wellsite geologist, talk to my pore

04 pressure engineer, talk to the mudlogger.

05 Make sure there's no personality conflicts,

06 there's, you know, there's -- there's

07 nothing like, this person doesn't

08 communicate well with this person. Just

09 have a -- have conversation. Take a

10 look -- you know, a critical look at the

11 data with my colleagues. Always striving

12 for continuous improvement and operational

13 efficiency. Just trying to reengage the

14 team, reenergize the team, and give it, you

15 know, different perspective me being out

16 there. Give the data just a -- a more

17 scrutinized look. Just trying to ever --

18 ever improve the process.

19 Q. Did you accomplish everything

20 that you set out to do?

21 A. I thought that I did it. It's

22 very -- what I set out to do is not -- you

23 know, as to eliminate non-productive time.

24 So no loss events, no kick events. And the

25 next two hole-sections, there were not

00417:01 those aforementioned events. So what I set

02 out to do, it's hard to say. It's not

03 numerical. It's very qualitative to say

04 whether you accomplished something, but I

05 think I did reengage the team. I think we

06 started looking at things with a more

07 critical eye, and I think we started

08 communicating and having more

09 conversations. And I think that my visit

10 to the rig was a -- was a positive thing.

Page 430:06 to 432:09

00430:06 MR. WATTS:

07 Okay. This is Mikal Watts.

08 I've been asked to read in the tab numbers

104


09 versus the exhibit numbers so we'll have it

10 in the record.

11 Tab Number 1 is

12 Exhibit 1046. Yeah. I'm sorry. Tab 1 is

13 Exhibit 1046. Tab 2 is 1047. Tab 3 --

14 Tab 4 is Exhibit 1053. Tab 5 is

15 Exhibit 1048. Tab 6 is Exhibit 1050. Tab

16 7 is Exhibit 1051. Tab 8 is Exhibit 1054.

17 Tab 9 is Exhibit 1055. Tab 11 is

18 Exhibit 1052. Tab 14 is Exhibit 1056.

19 Tab 15 is Exhibit 1057. Tab 16 is

20 Exhibit 1082. Tab 17 is Exhibit 1059.

21 Tab 18 is Exhibit 1061. Tab 19 is

22 Exhibit 1060. Tab 20 is Exhibit 1062.

23 Tab 21 is Exhibit 1063. Tab 22 is

24 Exhibit 1064. Tab 23 is Exhibit 1065. Tab

25 24 is Exhibit 1066. Tab 25 is

00431:01 Exhibit 1067. Tab 26 is Exhibit 1058.

02 Tab 29 is Exhibit 1069. Tab 30 is

03 Exhibit 1071. Tab 31 is Exhibit 1072.

04 Tab 32 is Exhibit 1070. Tab 33 is

05 Exhibit 1073. Tab 34 is Exhibit 1074.

06 Tab 35 is Exhibit 1075. Tab 36 is

07 Exhibit 1076. Tab 37 is Exhibit 1078.

08 Tab 38 is Exhibit 1080. Tab 39 is

09 Exhibit 1081. Tab 40 is Exhibit 1079.

10 Tab 42 is Exhibit 1083. Tab 43 is

11 Exhibit 1084. Tab 44 is Exhibit 1086.

12 Tab 45 is Exhibit 1085. Tab 46 is

13 Exhibit 1087. Tab 47 is Exhibit 1090.

14 Tab 48 is Exhibit 1092. Tab 49 is

15 Exhibit 1089. Tab 50 is Exhibit 1088.

16 Tab 52 is Exhibit 1093. Tab 54 is

17 Exhibit 1094. Tab 55 is Exhibit 1091.

18 Tab 56 is Exhibit 1097. Tab 57 is

19 Exhibit 1095. Tab 58 is Exhibit 1096.

20 Tab 59 is Exhibit 1045. Tab 61 is

21 Exhibit 1098. Tab 62 is Exhibit 1200.

22 Tab 63 is Exhibit 1099. Tab 64 is

23 Exhibit 1201. Tab 66 is Exhibit 1202.

24 Tab 74 is Exhibit 1212. Tab 76 is

25 Exhibit 1205. Tab 84 is Exhibit 1206.

00432:01 Tab 85 is Exhibit 1207. Tab 89 is

02 Exhibit 1049. Tab 90 is Exhibit 1208.

03 Tab 91 is Exhibit 1068. Tab 92 is

04 Exhibit 1209. Tab 97 is Exhibit 1210.

05 Tab 100 is Exhibit 1203. Tab 101 is

06 Exhibit 1204. Tab 102 is Exhibit 1211.

07 And that's it.

08 (Exhibit Numbers 1045

09 through 1212 marked.)

Page 432:16 to 432:17

00432:16 Q. Mr. Bodek, my name is Richard

105


17 Hymel, and I represent Transocean. With me

Page 432:22 to 433:11

00432:22 Q. The first document I want to

23 turn to is the document that's -- the

24 Exhibit 1220. And it's in this -- it's in

25 this book.

00433:01 A. Okay.

02 Q. And it is Tab 44.

03 That is an e-mail from you

04 to Mr. B-e-i-r-n-e.

05 How do pronounce that?

06 A. It's pronounced Beirne.

07 Q. Beirne?

08 A. Yep.

09 Q. Okay. And it's an e-mail that's

10 been discussed already.

11 A. Yes, sir.

Page 433:13 to 433:14

00433:13 there. And I want you to refer to the Bly

14 report, which is Exhibit 1. And it's in

Page 433:17 to 433:20

00433:17 A. Okay.

18 Q. I want you to go to Page 54 of

19 the Bly report.

20 A. Okay. I'm at -- I'm at Page 54,

Page 434:06 to 434:14

00434:06 Q. Okay. The document that's on

07 Page 54 is a document that shows the

08 casing, some of the cement, but more

09 importantly for our discussion, some of the

10 zones, the pay zones. And then there's one

11 that's -- that's labeled a brine zone.

12 Do you see that?

13 A. In -- in Figure 1?

14 Q. Yes. In Figure 1.

Page 434:19 to 435:10

00434:19 where it says brine zone. Okay. Yeah.

20 Yep.

21 Q. All right. Now, I want to refer

22 you back to your e-mail to Mr. Beirne.

23 A. Yes, sir.

24 Q. And in that e-mail, five lines

106


25 down, you discuss a sand pressure at 17723

00435:01 MD. This sand pressure worked out to be

02 14.15 ppg.

03 Do you see that?

04 A. Yes, sir.

05 Q. Okay. Now, I want you to look

06 on exhibit -- on Figure 1 in the -- in the

07 Bly report and tell me if you -- if there's

08 any pressure, any interval shown on that

09 Figure 1 that is at 17723 and has a

10 pressure of 14.15.

Page 435:13 to 436:03

00435:13 A. I'm having a hard time

14 discerning the -- I don't know -- no,

15 there's no pressure at seven -- so the

16 17723, is it -- 723. The -- the numbers

17 don't -- don't match up. I could see kind

18 of intuitively it seems like it would be

19 the brine sand, but I can't -- I can't

20 confirm that.

21 Q. Okay. If you'll look at the

22 brine sand numbers, they run from 17 -- it

23 looks like 684 to 17693.

24 Does that look correct?

25 A. Yes, sir.

00436:01 Q. Okay. And -- and in the Bly

02 report it's 14.1 as opposed -- as opposed

03 to 14.15; is that correct?

Page 436:06 to 436:24

00436:06 A. If -- if we're -- if they're the

07 same -- if we're looking at the same -- if

08 what I was referring to in my e-mail to

09 Mike is, in fact, what we're looking at

10 here that's labeled 14.1, yes, there's a

11 discrepancy of five-hundredths between

12 those two numbers, providing that I was

13 talking about the same sand.

14 Q. Okay. And I guess just to refer

15 back to your e-mail. You're referring to

16 the sand with the highest pressure, is what

17 your discussion was about in your e-mail;

18 is that correct?

19 A. Yes, sir.

20 Q. Okay. And the point of that was

21 is that's where you needed to have your mud

22 weight and that caused problems with a

23 lower reservoir that had -- that had a

24 lower pressure; is that correct?

107


Page 437:03 to 437:20

00437:03 Q. Now, when you were evaluating

04 the Macondo well and you found this

05 pressure at -- at the depth that you found

06 it at, did you know -- would that -- that

07 zone consisted of?

08 A. Consisted of, meaning the fluid?

09 Q. Yes.

10 A. I don't -- I don't know that we

11 did at the time.

12 Q. And in fact, there's some

13 e-mails that went back and forth between

14 you and others where you talked about

15 trying to -- to do testing on these

16 different zones, but really y'all -- it was

17 something you gave up or you just couldn't

18 get them 'cause they -- they were not that

19 thick; is that correct? Does it refresh

20 your memory?

Page 437:23 to 438:11

00437:23 A. We did attempt to get pressure

24 measurements with -- with a formation

25 pressure while drilling tool. And don't

00438:01 remember the specifics, but at least one

02 occasion, I remember being unsuccessful

03 with the tool to obtain a pressure, yes,

04 sir.

05 Q. And really, the point of my

06 question is, is that Mr. Bly puts in his

07 report that the 14.1 zone is a brine zone.

08 And did you or anybody at BP determine that

09 the 14.1 zone or the one that had the

10 highest zone was a brine zone before the

11 casualty?

Page 438:14 to 439:07

00438:14 A. I don't remember, sir.

15 Q. Okay. Well, who was -- whose

16 job was it to determine what the zone

17 contained, whether it contained oil, gas,

18 or brine?

19 A. The petrophysicist would make

20 that determination.

21 Q. Okay. Who would we talk to if

22 we wanted to know the determination had

23 been made before the casualty whether this

24 zone with the highest pressure had gas,

25 oil, or brine?

00439:01 A. Talk to the -- the project

02 petrophysicist.

108


03 Q. And I'm asking you specifically

04 a name.

05 A. Galina Skripnikova.

06 Q. I want you to turn to Page 64 in

07 the Bly report.

Page 439:13 to 439:15

00439:13 MR. LEMOINE:

14 Richard, would you make that

15 an exhibit, please?

Page 439:24 to 439:24

00439:24 (Exhibit Number 1225 marked.)

Page 440:01 to 440:09

00440:01 Q. The third full paragraph down at

02 Page 64 talks about the 14.1 zone. And the

03 second sentence says, In fact, this zone

04 would not be expected to present a

05 possibility of gas flow or hydrocarbon

06 ingress, since the BP subsurface team for

07 the Macondo well assigned this interval a

08 value of zero net pay.

09 What does that mean?

Page 440:19 to 440:22

00440:19 I don't know what the -- I

20 don't know what parameters they put on to

21 consider what they would consider to be

22 quote, unquote, pay.

Page 441:02 to 447:10

00441:02 Q. Okay. I want to go back to

03 your -- the e-mail that we talked about.

04 And I want -- just want to ask you a few

05 questions.

06 A. Yes, sir.

07 Q. About half -- no. About one,

08 two, three -- about nine or ten lines down,

09 you have the statement, We surmised that

10 our under reamer had failed.

11 Do you see that statement?

12 A. Yes, sir.

13 Q. What did you mean by that?

14 A. While we were drilling the

15 reservoir sands, our ROPs diminished

16 significantly. And I was reiterating what

109


17 I heard from the drilling team. The --

18 suggested that the -- the under reamer had

19 failed to do its -- do its job. So it

20 wasn't drilling. ROPs had -- had

21 diminished.

22 Q. ROPs mean what?

23 A. Rate of penetration.

24 Q. Okay. And the decision was made

25 to pull out of the hole for a new bottom

00442:01 hole assembly?

02 A. Yes, sir.

03 Q. Okay. So that BP could go back

04 to drill as fast as they had been drilling

05 before?

06 MR. FIELDS:

07 Objection, form.

08 A. No, sir.

09 Q. Okay. About two-thirds of the

10 way down, there's a discussion about the --

11 once again, the GeoTap pressure was

12 measured at 14.15, the absolute minimum.

13 The minimum is -- is underlined.

14 Do you see that?

15 A. Yes, sir.

16 Q. And so you're talking about the

17 absolute minimum mud weight that you could

18 use was 14 pounds, and then you talk

19 about --

20 MR. FIELDS:

21 Surface mud weight.

22 MR. HYMEL:

23 Excuse me?

24 MR. FIELDS:

25 Surface mud weight.

00443:01 Q. Surface mud weight is 14 pounds.

02 And then at the end of that sentence, you

03 say -- actually, it's a separate sentence.

04 It appeared as if we had minimal, if any,

05 drilling margin.

06 Do you see that?

07 A. Yes, sir.

08 Q. What do you mean by that?

09 A. What I mean by that is when

10 we -- we drilled into our reservoir, we had

11 to drill on the reservoir a significant

12 amount before we can have -- we had a -- a

13 GeoTap, which is a formation pressure while

14 drilling tool. So the GeoTap was several

15 tens -- it was -- it was over a hundred

16 feet -- no. I'm not sure. It was behind a

17 bit. So we had to drill a significant way

18 into the reservoir in order to get the

19 GeoTap juxtaposed next to a reservoir sand

20 to get our sand pressure. When we took the

21 sand pressure, we determined the pressure

110


22 of our reservoir to be 12.6 pounds per

23 gallon, well below the 14.2 pre-drill

24 estimate of reservoir pressure.

25 So when we got into the

00444:01 reservoir -- when we drilled to the top --

02 when we're drilling on our way to the

03 reservoir, we were taking a couple of

04 GeoTaps on the way, and we had a 14 -- we

05 took a 14.15 GeoTap. So when we drilled

06 into our reservoir, our reservoir was

07 underpressured relative to projection. So

08 we were -- we were taking losses in the

09 reservoir with the same mud weight that we

10 needed to keep that 12 point -- I'm sorry,

11 14.15 sand covered. So when we can't

12 increase mud anywhere -- any -- any higher

13 to drill further without taking losses,

14 we're out of margin. So our downhole --

15 our bottom hole -- I'm sorry. Our highest

16 pore pressure in the well is approaching

17 the fracture gradient at the shoe.

18 Q. Going down to the last couple of

19 sentences. And it looks like you kind of

20 summarized down there what -- what we have

21 been talking about.

22 As you said, Drilling ahead

23 any further wouldn't have necessarily

24 jeopardized the wellbore.

25 And what does that mean?

00445:01 A. It means if -- if we wanted to

02 drill further deep in the well, we would

03 have had to have increased mud weight

04 commensurate with an expected pore pressure

05 increase as you go deeper. If we were to

06 increase pore pressure as we go deeper, we

07 would again incur losses. So either way --

08 you know, either way, drilling further was

09 not -- not a safe or prudent thing to do.

10 Q. And then there's a statement

11 that says, The 12.6 ppg reservoir in the

12 same hole-section had forced our hand.

13 And that's, in essence,

14 what you've been saying?

15 A. Yes, sir.

16 Q. Okay. 'Cause you had 12.6 and

17 you needed 14.5 to at least get through

18 that one zone?

19 A. Yep. We had that zone exposed.

20 We already cut it open.

21 Q. Right.

22 A. And our -- and our reservoir was

23 pressure regressed relative to some of

24 those isolated sands.

25 Q. On the last line you say, At

00446:01 this point, it became a well integrity and

111


02 safety issue.

03 What did you mean by that?

04 A. That drilling any further

05 could -- would subject us to -- to losses

06 if -- if we -- if we wanted to mud up to

07 drill further, we would have subjected the

08 well losses. If we wanted to maintain mud

09 weight and drill further with this -- with

10 this same mud weight that we knew we

11 would -- would take losses, we could -- we

12 could potentially drill into something that

13 was pressured. Intuitively, as you go

14 deeper, pressures increase.

15 Q. Okay. Now, that talks about the

16 well integrity issues. What safety issues

17 were you talking about there?

18 A. Safety issue is having -- having

19 losses is a safety issue, taking a kick is

20 a safety issue.

21 Q. Okay. Well, if you're having

22 losses, are you taking a kick?

23 A. No.

24 Q. Okay.

25 A. Both are -- both would be -- I

00447:01 would consider safety issues having losses

02 or taking a kick.

03 Q. How are having losses a safety

04 issue?

05 A. Potentially, if your losses are

06 great enough, you can unload the well. So

07 if your losses are so great and you can't

08 maintain a column of -- column of mud

09 weight, then eventually your well will

10 become underbalanced and can induce a kick.

Page 447:20 to 449:10

00447:20 Q. Now, just go back up a couple of

21 lines. And there's a statement, Having

22 drilled and evaluated the entire reservoir

23 interval would fulfill the two primary

24 objectives of the well.

25 What does that mean?

00448:01 A. The two primary objectives of

02 the well was to -- this is -- first and

03 foremost, this was an exploration well.

04 Q. Uh-huh.

05 A. Secondly, it was a keeper well.

06 First and foremost, the first primary

07 objective was to drill and evaluate the M56

08 reservoir. I think drilling it was an

09 objective and evaluating was the second

10 objective. I don't remember specifically

11 what the objectives are. I do remember

12 that drilling and evaluating the well were

112


13 the primary objectives of the well.

14

Q. So what you're saying in there

15 is, at this point, once you drill through

16 that reservoir and -- drill through it and

17 then evaluated it, you basically could have

18 stopped there. You could have plugged the

19 well, and you would have met the two

20 objectives of this well?

21 MR. FIELDS:

22 Object -- objection, form.

23 A. We could have done that and met

24 two objectives. Yes.

25 Q. The two primary objectives,

00449:01 correct?

02 A. Yes.

03 Q. Okay. And so attempting to

04 temporary and abandon -- temporarily

05 abandon this well so -- so you could come

06 back and produce it was trying to reach

07 another objective?

08 MR. FIELDS:

09 Objection, form.

10 A. Yes, sir.

Page 459:09 to 459:24

00459:09 Q. Before the casualty, were you

10 aware of two sands above that, that had

11 higher pressures?

12 A. Yes, sir.

13 Q. Okay. And one we've talked

14 about was the 14.15 --

15 A. Yes, sir.

16 Q. -- correct?

17 Were you also aware of

18 another sand above the primary reservoir

19 that had a higher pressure?

20 A. Yes, sir.

21 Q. And do you remember what that

22 pressure was?

23 A. That pressure was 13.01, if I

24 recall.

113

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