Require that all certifications needed by a Registered Professional Engineer be done by a
Registered Professional Petroleum Engineer. It makes no sense at all to utilize any PE. If
so, at least require a BS in Petroleum Engineering. There is no specification to determine
how any Registered Professional Engineer is "capable of reviewing and certifying that
the ... is appropriate for the purpose for which it is intended under expected wellbore
conditions."
Comment from John Burman, Self
This is comment on Rule
Oil and Gas and Sulphur Operations in the Outer Continental Shelf-Increased Safety Measures for Energy Development on the Outer Continental Shelf; Final Rule
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