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departures from the regulations or alternate procedures were not a cause of the
Macondo blowout.

D. MMS Drilling Inspections

An MMS drilling inspection routinely involved a review of required
documents and records, a walk‐through visual inspection of the facility, and
testing of equipment. Records reviewed during a typical inspection included:
surveys; safety device information; records of BOP tests and inspections; records
of diverter tests; records of well control drills; documentation of maximum
pressures handled by the BOP stack; records reflecting the condition of the
drilling mud; formation integrity test results; records of leak‐off tests;
applications; permits; and any evidence of unreported pollution incidents.

Visual inspections typically included a visual assessment of: the diverter
system; classified drilling fluid handling areas; housekeeping and general safety
conditions; safety valves on the rig floor; conditions of man‐lift and air‐hoist wire
ropes; safe welding area and equipment in the area (to ensure the absence of
flammable material); grounding of electrical buildings and equipment;
emergency shutdown for diesel engines (air shut off); and operable BOP remote
control stations.

MMS inspectors tested the following equipment during a typical
inspection: crown block safety device; backup BOP accumulator charging
system; degasser function; mud pit level alarms; flow show alarm; gas detection
system; ventilation system and alarms; and mudlogger shack alarms. During the
inspections of drilling rigs, MMS inspectors were not required to function‐test
the emergency disconnect systems, lower marine riser packages, or BOP stack
secondary control systems.

E. Potential Incident of Noncompliance Guidelines

To ensure consistency in the agency’s inspection program, MMS
inspectors performed OCS inspections using a national checklist called the
Potential Incident of Noncompliance (“PINC”) list. This list is a compilation of
yes/no questions derived from safety, environmental and regulatory
requirements relating to oil and gas operations on the OCS.

Upon detecting a violation, the MMS inspector issued an Incident of
Noncompliance (“INC”) to the operator and used one of three main enforcement

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