{"operation":"document","citation":"CPF 520081007M","title":"VENOCO, INC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-09-10","effective_on":null,"summary":"CLOSED notice of amendment citing 192.905(a), 192.911, 192.933, 192.935, 192.935(b), 192.935(i), 192.935(m), 192.937(b), 192.945, 192.947(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520081007m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520081007m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520081007m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520081007M","body":"Notice of Amendment involving VENOCO, INC. PHMSA's enforcement data identifies the cited regulations as 192.905(a),  192.911,  192.933,  192.935,  192.935(b),  192.935(i),  192.935(m),  192.937(b),  192.945,  192.947(d). The case was opened on 2008-09-10 and is reported as closed as of 2010-04-06. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520081007M_notice of amendment_09102008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520081007M/520081007M_notice%20of%20amendment_09102008.pdf\n\n520081007m_notice of amendment_09102008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520081007M/520081007m_notice%20of%20amendment_09102008_text.pdf\n\n520081007M_ooperator response_10032008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520081007M/520081007M_ooperator%20response_10032008.pdf\n\n520081007m_notice of amendment_09102008_text.pdf\n\nU S. DepGrtment\nof Tl GtlsPortGtloll\nPipelline and\nHazardous Materialls Safety\nAdministration\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nNOTICE OF AMKNBMKNT\nSeptember 10, 2008\nMr. Ikeith Wenal\nManager\nVenoco Incorporated\n6267 Carpinteria Ave.\n,\nCarpinteria, CA 93013\n0100\nCPF 5-2008-1007M\nDear Mr. Wenal'\nOn July 23 to 27, 2007, representatives of the Pipehne and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, mspected Venoco\nIncorporated's (Venoco) Integrity Management Program (IMP) in Carpinteria, Cahfornia\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nVenoco's IMP plan, as described below\ng 192. 905 (a) General.\nTo determine which segments of an operator's transmission pipehne system are\ncovered by this subpart, an operator must identify the high consequence areas. An\noperator must use method (1) or (2) from the definition in $192. 903 to identify a\nhigh consequence area. An operator may apply one method to its entire pipeline\nsystem, or an operator may apply one method to individual portions of the pipeline\nsystem. An operator must describe in its integrity management program which\nmethod it is applying to each portjlon of the oper'ator's pipeline system. The\ndescription must include the potential impact radius when utihzed to establish a\n\n\n\nItem 1A Venoco did not specify in its IMP plan which method it was applying to\nidentify HCAs.\nItem 18: Venoco needs to include system maps or other suitable detailed means for\ndocumenting the pipehne segment locations that are located in HCAs\nItem 1C. Venoco must ensure to apply the formula (r — 0. 69(p~d ) ) for the calculation\nof the potential impact radius accurately and consistently with $192 903 requirements.\nItem 10. Venoco must ensure to use pubhc officials as sources of information in its\nidentification process for identified sites.\nItem 1E. Venoco must include details how it included as a high consequence area, any\narea in Class 1 and Class 2 piping locations where the potential impact circle contains an\nidentified site.\nAn operator's initial integrity management program begins with a framework (see.\n$192. 907) and evollves into a more detailed and comprehensive integrity\nmanagement program, as information is gained and incorporated into the program.\nAn operator must make continual improvements to its program. The initial\nprogram framework and subsequent p~ogram must, at minimum, contain the\nfollowing elements. (When indicated, refe~ to ASMK/ANSI 831. 8S (incorporated\nby reference, see $192. 7) for more detailed information on the listed element. )\n(c) An identification of threats to each covered pipehne segment, which must\ninclude data integration and a risk assessment. An operator must use the threat\nidentification and risk assessment to prioritize covered segments for assessment\n($192. 917) andi to evajluate the merits of additional preventive and mitigative\nmeasures ($192. 935) for each covered segment.\nItem 2A: Venoco needs to mclude details in its justification for ehminating threats m its\nthreat analysis.\nItem 28: Venoco needs to include the use of a common spatial reference system and\nintegration of data on encroachments and foreign hne crossings.\nItem 2C. Venoco needs to include further clarification and additional details on how its\nrisk assessments are apphed to mitigative measures\n\n\n\nItem 2D: Venoco needs to include details how risk assessment was recalculated for each\nsegment to reflect the results from an mtegrity assessment or to account for completed\nprevention and mitigation actions.\nItem 2E Venoco must ensure adequate time and personnel have been allocated to permit\neffective implementation of its IMP plan and completion of the selected risk assessment\napproach\n(c) Schedule for evaluation and remediation . An oper ator must complete\nremediation of a condition according to a schedule prioritizing the conditions for\nevaluation and remediation. Unless a special requirement for remediating certain\nconditions appHes, as provided in paragraph (d) of this section, an operator must\nfollow the schedule in ASMK/~SI 831. 8S (incorporated by reference, see $192. 7),\nsection 7, Figure 4. If an operator cannot meet the schedule for any condition, the\noperator must explain the reasons why it cannot meet the schedule and how the\nchanged schedule will not jeopardize pubhc safety.\nItem 3A: Venoco needs to include a requirement to document the justification, when a\nremediation activity cannot be completed within estabhshed timeframe This\nrequirement must include reasons why the schedule cannot be met and the basis for why\nthe changed schedule will not jeopardize pubhc safety\nItem 38: Venoco needs to more fully describe how it records \"monitored conditions\" and\nmonitor these conditions during subsequent assessments.\n(f) A process for continual evaluation and assessment meeting the requirements of\n$192. 937.\n(b) Evaluation. An operator must conduct a periodic evaluation as frequently\nas needed to assure the integrity of each covered segment. The periodic\nevaluation must be based on a data integration and risk assessment of the\nentire pipeHne as specified in $192. 917. For plastic transmission pipeHnes, the\nperiodic evaluation is based on the threat analysis specified in 192. 917(d).\nFor al1l other transmission pipehnes, the evaluation must consider the past\n\n\n\nItem 3C: Venoco needs to specify the frequency of its periodic evaluations.\n(b) Third party damage and outside force damage-\n(l) Thii 6 party damage. An operator must enhance its damage prevention program,\nas required under gjL92. 6l4 of this part, with respect to a covered segment to\nprevent and mininuze 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 pipeline segments by pipeline\npersonnel. 1f an operator finds physical evidence of encroachment involving\nexcavation that the operator did not monitor near a covered segment, an operator\nmust either excavate the area near the encroachment or conduct an above ground\nsur vey using methods defined in RACK RP — 0502 — 2002 (incorporated by reference\nsee gl92. 7). An operator must excavate, and remediate, in accordance with\nANS1/ASMK 83l. 8S and g]I. 92. 933 any indication of'coating holidays or\ndiscontinuity warranting direct examination.\nItem 3D: Venoco needs to indicate in its IMP plan that for locations where there is\nphysical evidence of encroachment involving excavation, and Venoco did not monitor\nthis excavation near a covered segment, that Venoco will either: excavate the suspect\nencroached area, or use above ground indirect survey methods to identify if there is\ndamage to the pipehne and take appropriate remedial actions if necessary.\n(2) Outside force damage. 1f an operator determines that outside force ( e. g. ,\nearth\nmovement, floods, unstable suspension bridge) is a threat to the integrity of a\ncovered segment, the operator must take measures to minimize the consequences to\nthe covered segment from outside force damage. These measures include, but are\nnot hmited to, inc~easing the frequency of aerial, foot or other methods of patrols,\nadding external protection, reducing external stress, and relocating the Hne.\nItem 3E: Venoco needs to complete its work on the action item identified to\nevaluate preventive and mitigative measures to address the threats on its pipehnes\nfrom potential earthquakes.\n\n\n\nItem 3F Venoco needs to include a requirement to evaluate whether additional third\nparty preventive and mitigative measures need to be implemented\n(a) General. An operator must include in its integrity management program\nmethods to measure, on a semi-annual basis, whether the program is effective in\nassessing and evaluating the integrity of each covered pipehne segment and in\nprotecting the high consequence areas. These measures must include the four\noverall performance measures specified in ASMK/AXSL 831. 8S (incorporated by\nreference, see $192. 7), section 9. 4, and the specific measures for each identified\nthreat specified in ASMK/ANSI 831. 8S, Appendix A. An operator must submit the\nfour overall performance measures, by electronic or other means, on a semi-annual\nfrequency to OPS in accordance with $192. 951. An operator must submit its first\nreport on overall performance measures by August 31, 2004. Thereafter, the\nperformance measures must be complete through June 30 and Becember 31 of each\nyear and must be submitted within 2 months after those dates.\nItem 36: Venoco needs to specify that performance is measured semi-annually in\naccordance with the threat-specific metrics of ASME B31. 8S-2001, Table 9.\n(d) Bocuments to support any decision, analysis and process developed and used to\nimplement and evaluate each element of the basehne assessment plan and integrity\nmanagement program. Bocuments include those developed and used in support of\nany identification, calculation, amendment, modification, justification, deviation\nand determination made, and any action taken to implement and evaluate any of the\npr ogram elements;\nItem 3H: Venoco needs to expand the recordkeeping documentation requirements to\nsupport decisions, analyses, and calculations\n(k) A. management of change process as outlined in ASMK/ANSI 831. 8S, section 11.\nItem 3I: Venoco needs to include reasons for changes in MOC process documentation\nItem 3J. Venoco needs to ensure that for significant changes in its IMP plan, it provides\nnotification to PHMSA, i. e. the change from 1 '/z+ miles to 37+ miles of transmission\npip ehne.\n\n\n\nItem 314' Venoco needs to update the MOC process' Information Update List under DOT\nComphance Review, to include IMP plan impacts/revisions, and to ensure the MOC SOP\naddresses impact to the IMP plan in its processes.\nItem 3L. Venoco needs to ensure that meeting notes and corrective action to improve iis\nIMP plan and the quality assurance processes have been documented\nItem 3M: Venoco needs to mclude a process to ensure the quahty of work of its\ncontractors performing IMP related activities\nIem 3N: Venoco needs to mclude mternal communication plan to establish the\nunderstanding and support for the IMP.\nItem 30: Venoco needs to include details of how it will address safety concerns\nraised by State and OPS pipehne safety authorities in its Communications Plan.\nRes onse to this Notice\nThis Notice is provided pursuant to 49 U. S. C. ( 60108(a) and 49 C. F. R. ) 190. 237. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance ProceeCings Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade pubhcly available. If you beheve that any portion of your responsive material quahfies for\nconfidential treatment under 5 U. S. C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the potions you beheve quahfy for\nconfidential treatment redacted and an explanation of why you beheve the redacted information\nquahfies for confidential treatment under 5 U. S. C. 552(b). If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations m this\nNotice and authorizes the Associate Administrator for Pipehne Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C. F. R. ) 190. 237) If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within [number of days] days of receipt of this Notice. This\nperiod may be extended by written request for good cause. Once the inadequacies identified\nherein have been addressed in your amended procedures, this enforcement action will be closed\n\n\n\nIn correspondence concerning tins matter, please refer to CPF 5-2008-1007M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\n(\nChris Hoidal\nDirector, Western Region\nPipehne and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc PHP-60 Comphance Registry\nPHP-500 (P. Nguyen, ¹119231)","truncated":false,"body_characters":13471}