{"operation":"document","citation":"CPF 520077003W","title":"VENOCO, INC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-06-05","effective_on":null,"summary":"CLOSED warning letter citing 195.452(j)(5), 195.452(k).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520077003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520077003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520077003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520077003W","body":"Warning Letter involving VENOCO, INC. PHMSA's enforcement data identifies the cited regulations as 195.452(j)(5),  195.452(k). The case was opened on 2007-06-05 and is reported as closed as of 2007-06-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520077003W_warning letter_06052007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520077003W/520077003W_warning%20letter_06052007.pdf\n\n520077003w_warning letter_06052007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520077003W/520077003w_warning%20letter_06052007_text.pdf\n\n520077003w_warning letter_06052007_text.pdf\n\nU. S Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W Dakota Ave, Suite tt0\nLakewood, CO 80228\nSENT TO COMPLIANt\"E REG/$'Jgg\nHardcopy Electromcal y\n¹ of Copies / Date\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nJune 5, 2007\nMr, Keith Wenal\nVenoco Inc.\n6267 Carpinteria Avenue\nCarpinteria, CA 93013\nCPF 5-2007-7003W\nDear Mr. Wenal:\nOn April 18, 2007, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\nprocedures and records for Venoco Inc. 's (Venoco) Integrity Management Program in\nCarpinteria, California.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violations are:\n1. $195. 452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(7) Methods to measure the program's effectiveness (see paragraph (k) of this\nsection);\n(k) What methods to measure program effectiveness must be used? An operator's\nprogram must include methods to measure whether the program is effective in\nassessing and evaluating the integrity of each pipeline segment and in protecting\n\n\n\n2.\nthe high consequence areas. See Appendix C of this part for guidance on methods\nthat can be used to evaluate a program's effectiveness.\nVenoco has not yet implemented their process for program evaluation.\n$195. 452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(5) A continual process of assessment and evaluation to maintain a pipeline's\nintegrity (see paragraph (j) of this section);\n(j) What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n(1) General. After completing the baseline integrity assessment, an operator must\ncontinue to assess the line pipe at specified intervals and periodically evaluate the\nintegrity of each pipeline segment that could affect a high consequence area.\n(2) Evaluation. An operator must conduct a periodic evaluation as frequently as\nneeded to assure pipeline integrity. An operator must base the frequency of\nevaluation on risk factors specific to its pipeline, including the factors specified in\nparagraph (e) of this section. The evaluation must consider the results of the\nbaseline and periodic integrity assessments, information analysis (paragraph (g)\nof this section), and decisions about remediation, and preventive and mitigative\nactions (paragraphs (h) and (i) of this section).\n(3) Assessment intervals. An operator must establish intervals not to exceed five\n(5) years for continually assessing the line pipe's integrity. An operator must base\nthe assessment intervals on the risk the line pipe poses to the high consequence\narea to determine the priority for assessing the pipeline segments. An operator\nmust establish the assessment intervals based on the factors specified in\nparagraph (e) of this section, the analysis of the results from the last integrity\nassessment, and the information analysis required by paragraph (g) of this\nsection.\nVenoco did not consider all of the risk factors listed in $195. 452(e) and (g) when\nestablishing re-assessment intervals.\nUnder 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed\n$100, 000 for each violation for each day the violation persists up to a maximum of $1, 000, 000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time, We advise you to correct the item(s)\n\n\n\nidentified in this letter. Failure to do so will result in Venoco Inc. being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2007-7003W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion\nof your responsive material qualifies for confidential treatment under 5 U. S. C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under\n5 U. S. C. 552(b).\nSincerely, W)\nC oi c\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 H. Monfared (¹118966)\n-3-","truncated":false,"body_characters":6305}