{"operation":"document","citation":"CPF 520081006W","title":"VENOCO, INC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-09-10","effective_on":null,"summary":"CLOSED warning letter citing 192.911, 192.935(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520081006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520081006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520081006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520081006W","body":"Warning Letter involving VENOCO, INC. PHMSA's enforcement data identifies the cited regulations as 192.911,  192.935(b). The case was opened on 2008-09-10 and is reported as closed as of 2008-09-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520081006W_warning letter_09102008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520081006W/520081006W_warning%20letter_09102008.pdf\n\n520081006w_warning letter_09102008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520081006W/520081006w_warning%20letter_09102008_text.pdf\n\n520081006w_warning letter_09102008_text.pdf\n\nU. S. Department\nof Transportation\nPlpellilne and\nHazardous Maferlialls Safety\nAdmilnilsfirafiion\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nWA~IXG KKTTKR\nSeptember 10, 2008\nMr Keith Wenal\nManager\nVenoco Incorporated\n6267 Carpinteria Ave.\n,\nCarpinteria, CA 93103\n4100\nCPF 5-2008-1006W\nDear Mr. Wenal\nOn July 23 to 27, 2007, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 Unites States Code, inspected Venoco\nIncorporated's (Venoco) Integrity Management Program (IMP) in Carpinteria, California\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipehne Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n$ 192. 911 What are the elements of an integrity management programs\nAn operator's initial integrity management program begins with a framework (see\n$192. 907) and evolves into a more detailed and comprehensive integrity\nmanagement, program, as information ils gained and inco~po~ated into the p~ogram.\nAn operator must make continual improvements to its program. The ilniltial\nprogram framework andi subsequent program must, at minimum, contain the\n\n\n\nVenoco's lMP plan failed to verify that data elements were brought together and\nanalyzed in their context such that integrated data can provide improved confidence\nwith respect to determining the relevance of specific threats and can support an improved\nanalysis of overall risk.\ng 192. 935 What additional preventive and mitigative measures must an operatoi\ntakeT\n(1) Third party damage. An operator must enhance its damage prevention\nprogram, as required ~nder )192. 614 of this part, with respect to a cove~ed segment\nto prevent and minimize the consequences of a release due to third party damage.\nEnhanced measures to an existing damage prevention program include, at a\n(iv) Monitoring of excavations conducted on covered pipehne segments by pipeHne\npersonneL If an operator finds physical evidence of encroachment invollving\nexcavation that the operator did not monitor near a covered segment, an operator\nmust eithei excavate the area near the encroachment or conduct an above ground\nsurvey using methods defined in NACK RP — 0502 — 2002 (incorporated by reference,\nsee $192. 7). An operator must excavate, and remediate, in accordance with\nANSI/ASMK 831. 8S and $192. 933 any indication of coating hohdays or\ndiscontinuity warranting direct examination.\nVenoco's lMP plan failed to address preventive and mitigative requirements regarding\nthreats due to third-party damage such as the implementation of enhancements to the\nrequired Damage Prevention Program with respect to covered segments to prevent and\nminimize the consequences of a release\n\n\n\nUnder 49 United States Code, ( 60122, you are subject to a civil penalty not to exceed $100, 00\nfor each violation for each day the violation persists up to a maximum of $1, 000, 000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item identified in this letter.\nFailure to do so will result Venoco Incorporated being subject to additional enforcement action\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-ZOO8-]I OO6W. Be advised that all material you submit in response to this enforcement\naction is subject to being made pubhcly available. If you beheve that any portion of your\nresponsive material qualifies for confidential treatment under 5 U. S. C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou beheve quahfy for confidential treatment redacted and an explanation of why you beheve\nthe redacted inforination quahfies for confidential treatment under 5 U. S C 552(b)\nSincerely,\n( Chris Hoidal\nDirector, Western Region\nPipelme and Hazardous Materials Safety Administration\ncc: PHP-60 Comphance Registry\nPHP-500 P Nguyen (0119231)","truncated":false,"body_characters":4824}