Comment from DEAN SWANZY, PETROBRAS AMERICA

PLEASE SEE THE TWO QUESTIONS BELOW - CLARIFICATION NEEDS TO TAKE PLACE CONCERNING § 250.420 What well casing and cementing requirements must I meet? (b) * * * (3) For the final casing string (or liner if it is your final string), you must install dual mechanical barriers in addition to cement, to prevent flow in the event of a failure in the cement. These may include dual float valves, or one float valve and a mechanical barrier. You must submit documentation to BOEMRE 30 days after installation of the dual mechanical barriers. Question : Does the dual mechanical barrier requirement apply to just the inside of the casing or to both the inside and annulus flow paths ? We believe you are meaning the inside only. CONCERNINIG § 250.423 What are the requirements for pressure testing casing? (c) You must perform a negative pressure test on all wells to ensure proper casing installation. You must perform this test for the intermediate and production casing strings. Question : What is the definition of intermediate casing? The rule states a negative pressure test is required for intermediate and production casing. If drilling liners are set below intermediate casing is additional negative testing required ?