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Patton also approved the APMs and RPDs that BP submitted to MMS for
the Macondo well, including the APMs related to BP’s temporary abandonment
of the well. BP submitted the last APM on April 16 and provided an overview of
BP’s planned temporary abandonment procedures. BP stated its intent to set a
cement plug at a depth of 8,367 feet to 8,067 feet, and explained that it needed to
set the plug deeper to minimize the chances of damaging the lock‐down sleeve.
Patton testified that he was not aware of evidence of any problems with the
Macondo well and that he believed that BP had met all applicable regulatory
403
requirements in submitting the APD the APMs, and the RPDs. The Panel
concluded that Patton’s review and approval of the APD was not a cause of the
Macondo blowout.

B. Well Activity Reports

After receiving MMS approval of an APD, pursuant to 30 CFR §
250.468(b), the designated operator had to submit a weekly Well Activity Report
(“WAR”) to the agency to report all of the specific operations at the well. The
operator had to submit the WAR into e‐Well weekly from the well’s spud (start)
date to the end of drilling operations at the well. The drilling engineer reviewed
the WAR for consistency with the reviewed permit and to identify any anomalies
that warrant possible revisions to the permit or issuance of incidents of
noncompliance with the regulations. The WAR did not provide real time
information, rather, it was a snapshot of the prior seven days’ activities. The
MMS drilling engineers who reviewed the WARs on the Macondo well, Patton
and Peter Botros, noted no deficiencies on the WARs during the drilling of the
Macondo well.

C. Macondo Departures and Alternative Procedures

In the APD process, operators could seek authorization from MMS to
404
depart from the drilling requirements set out in 30 CFR Part 250. MMS could
also allow operators to conduct alternative procedures if those procedures are
deemed to be safer or as safe as the requirements set forth in 30 CFR Part 250.
MMS granted multiple requests for departures and alternative procedures at the
Macondo well in the Macondo APD (see Appendix I). The Panel found that these

403 Testimony of Frank Patton, Joint Investigation Hearing, May 11, 2010, at 268‐69.
404 See 30 CFR § 250.142; 30 CFR § 250.409.

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