# VENOCO, INC — Notice of Probable Violation

**Citation:** CPF 520047004  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2004-10-01

CLOSED notice of probable violation citing 195.452(e)(2), 195.452(f)(8), 195.452(h)(4), 195.452(i)(2), 195.452(j)(5), 195.452(k).

## Document text

Notice of Probable Violation involving VENOCO, INC. PHMSA's enforcement data identifies the cited regulations as 195.452(e)(2),  195.452(f)(8),  195.452(h)(4),  195.452(i)(2),  195.452(j)(5),  195.452(k). The case was opened on 2004-10-01 and is reported as closed as of 2006-07-10. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520047004_final order_07102006.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520047004/520047004_final%20order_07102006.pdf

CPF_NO_5-2004-7004.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520047004/CPF_NO_5-2004-7004.pdf

520047004_final order_07102006.pdf

400 Seventh Street, S.W.
U.S. Department Washington, D.C. 20590
of Transportation
Pipeline and
Hazardous Materials Safety
Administration JUL 1 0 ),, i r ;
Mr. William Schneider
President
Venoco, Inc.
6267 Carpinteria Ave., Suite 100
Carpinteria, CA 930 13
Re: CPF No. 5-2004-7004
Dear Mr. Schneider:
Enclosed is the Final Order issued by the Associate Administrator for Pipeline Safety in
the above-referenced case. It makes findings of violation and finds that you have completed
the actions specified in the Notice required to comply with the pipeline safety regulations.
The Final Order also finds that you have addressed the inadequacies in your procedures that
were cited in the Notice of Amendment. This case is now closed. Your receipt of the Final
Order constitutes service of that document under 49 C.F.R. 190.5.
Sincerely,
James Reynolds
Pipeline Compliance Registry
Office of Pipeline Safety
Enclosure
cc: Mr. Keith Wenal
Safety Manager
5464 Carpinteria Ave., Suite J
Carpinteria, CA 930 13-1 423
Mr. Chris Hoidal, P.E., Director Western Region, PHMSA
CERTIFIED MAIL -RETURN RECEIPT REQUESTED



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
In the Matter of
Venoco, Inc., CPF NO. 5-204-7004
Respondent
FINAL ORDER
Between April 12 and 13,2004, pursuant to 49 U.S.C. 5 60 1 17, representatives of the Pipeline
and Hazardous Materials Safety Administration's (PHMSA'S)' Office of Pipeline Safety and
California State Fire Marshall conducted an on-site pipeline safety inspectlion of Respondent's
Integrity Management Program (IMP) in Carpinteria, California. As a result of the inspection,
the Director, Western Region, PHMSA, issued to Respondent, by letter dated October 1, 2004, a
Notice of Probable Violation, Proposed Compliance Order, and Notice of Amendment (Notice).
In accordance with 49 C.F.R. 4 190.207, the Notice proposed finding that Respondent committed
violations of 49 C.F.R. Part 195, and proposed that Respondent take certain measures to correct
the alleged violations. The Notice also alleged inadequacies in the Respondent's IMP and
proposed to require amendment of Respondent's procedures to comply with the requirements of
195.452.
Respondent responded to the Notice by letter dated October 19,2004 (Response). Respondent
did not contest the allegations of violation but provided information concerning the corrective
actions it has taken. Respondent did not request a hearing, and therefore has waived its right to
one.
FINDINGS OF VIOLATION
In its Response, Respondent did not contest the alleged violations in the Notice. Accordingly, I
find that Respondent violated the following sections of 49 C.F.R. Part 194, as more fully
described in the Notice:
' Effective February 20,2005, the Pipeline and Hazardous Materials Safety Administration (PHMSA) succeeded
Research and Special Programs Administration as the agency responsible for regulating safety in pipeline
transportation and hazardous materials transportation. See, section 108 of the Norman Y. Mineta Research and
Special Programs Improvement Act (Public Law 108-426, 1 18 Stat. 2423-2429 (November 30,2004)). See also, 70
Fed. Reg. 8299 (February 18,2005)redelegating the pipeline safety authorities and functions to the PHMSA
Administrator.



Item 1 a- 49 C.F.R. 5 195.452(c)(l)(i)(A)-failing to conduct an acceptable geometry
tool run;
Item 1b- 49 C.F.R. tj 195.452(e)(l)(i-ix) and (2)-failing to conduct a risk analysis for
the lines needing to be hydrotested for baseline assessment and putting a prioritized
schedule in place for these lines;
Item 2 c - 4 9 C.F.R. 5 195.452(0(4) and (8)-failing to perform confirmation digs after
each pig run to compare predicted versus actual anomalies;
Item 4 a - 4 9 C.F.R. 5 195.452(h)(I)-failing to put in place a procless to provide an
adequate understanding of in-line inspection results; and
Item 6-9 C.F.R. 5 195.452(i)(l-2)-failing to conduct a risk analysis for its IMP.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items la, lb, 2c, 4a, and 6b in the
Notice. Under 49 U.S.C. 5 601 18(a), each person who engages in the transportation of
hazardous liquids or who owns or operates a pipeline facility is required to comply with the
applicable safety standards established under Chapter 601. Respondent stated in its Response
that, since the inspection, it has revised its "Liquid IMP Plan," and includqd copies of the
pertinent sections as well as summary sections of the risk assessments completed for the five
highest risk pipelines. The Regional Director has reviewed the revised seations as well as the
other attachments and has determined that they address the proposed compliance actions.
Accordingly, since compliance has been achieved with respect to these violations, it is not
necessary to include the compliance terms in this order.
AMENDMENT OF PROCEDURES
The Notice alleged inadequacies in Respondent's procedures and proposed to require
amendment of Respondent's procedures to comply with the requirements of
49 C.F.R. 5 195.452.
In its response, Respondent submitted copies of its amended procedures, which the Director,
Western Region, PHMSA reviewed. Accordingly, based on the results of this review, I find that
the Respondent's original procedures as described in the Notice were inadequate to ensure safe
operation of its pipeline system, but that Respondent has corrected the identified inadequacies.
No need exists to issue and order directing amendment.



The terms and conditions of this Final Order are effective on receipt.
Date Issued
Administrator
Pipeline Safety

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520047004>
- Source ID: `phmsa-enforcement`
- SHA-256: `d8c2ffb76e4a65187bca433e8bb4d53e920a57404d4b8f82609319fb03285d89`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T15:27:57.440Z
- Document slug: `phmsa-enforcement-520047004`

### Source metadata

```json
{
  "cpf": "520047004",
  "operator": "VENOCO, INC",
  "region": "Western",
  "pipelineType": "INTERSTATE LIQUID OFFSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.452(e)(2)",
    "195.452(f)(8)",
    "195.452(h)(4)",
    "195.452(i)(2)",
    "195.452(j)(5)",
    "195.452(k)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "520047004_final order_07102006.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520047004/520047004_final%20order_07102006.pdf",
      "bytes": 132876,
      "category": "agency_document"
    },
    {
      "name": "CPF_NO_5-2004-7004.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520047004/CPF_NO_5-2004-7004.pdf",
      "bytes": 132876,
      "category": "case_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "VENOCO, INC"
}
```
