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well control by adjusting drilling mud properties and the use of well control
equipment such as diverters and BOP stacks.

The drilling engineer approved the APD on behalf of the District Manager
after he or she reviewed the items listed above and after plan approvals were
verified by the MMS Plans Unit. A MMS District Manager granted approvals of
APDs, with all applicable cautions and conditions as necessary from the MMS
Geological and Geophysical unit. If the APD did not satisfy all of the review
items listed above, the drilling engineer returned the APD to the operator with
comments documenting the deficiencies that need to be corrected prior to APD
approval.

Operators routinely gathered information and formulated drilling
programs that were much more detailed than the information required in the
APD submitted to MMS. For example, the drilling prognosis submitted with the
Macondo APD was condensed to a single page, while the full BP drilling
program was more than 100 pages long.

If an operator changed drilling plans after submission of an APD, it was
401
required to submit an “application for permit to modify” (“APM”). The APM
was required to include “a detailed statement of the proposed work that would
materially change from the approved APD.”
402

MMS’s Gulf of Mexico region was divided into five districts. The
Macondo well is located in the Mississippi Canyon Block 252, which is covered
by the New Orleans District. Frank Patton, an MMS drilling engineer in the New
Orleans District, approved the Macondo APD on behalf of David Trocquet, the
New Orleans District Manager.

The Panel found that Patton did not recognize that BP failed to submit
supporting documentation that the blind shear ram in the BOP stack had the
ability to shear the drill pipe in the hole under maximum anticipated surface
pressures per 30 CFR § 250.416(e). However, the Panel reviewed evidence that
Cameron and Transocean both determined, prior to the APD submittal, that the
Deepwater Horizon BOP stack had the ability to shear the drill pipe in use.

401 30 CFR § 250.465.
402 Id. When APMs are submitted through the e‐well system to revise the permit to drill, they are
submitted as a “revised permit to drill” (“RPD”). BP submitted its revised permit to drill through
the e‐well system.

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