VENOCO, INC — Notice of Probable Violation

case documentOfficial PDFCPF_NO_5-2004-7004.pdf#

520047004_final order_07102006.pdf, page 1Official PDF400 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#

520047004_final order_07102006.pdf, page 2DEPARTMENT 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.#

520047004_final order_07102006.pdf, page 3Item 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.#

520047004_final order_07102006.pdf, page 4The terms and conditions of this Final Order are effective on receipt. Date Issued Administrator Pipeline Safety#