VENOCO, INC — Notice of Amendment

party submissionOfficial PDF520081007M_ooperator response_10032008.pdf#

520081007m_notice of amendment_09102008_text.pdf, page 1Official PDFU S. DepGrtment of Tl GtlsPortGtloll Pipelline and Hazardous Materialls Safety Administration 12300 W Dakota Ave, Suite 110 Lakewood, CO 80228 NOTICE OF AMKNBMKNT September 10, 2008 Mr. Ikeith Wenal Manager Venoco Incorporated 6267 Carpinteria Ave. , Carpinteria, CA 93013 0100 CPF 5-2008-1007M Dear Mr. Wenal' On July 23 to 27, 2007, representatives of the Pipehne and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, mspected Venoco Incorporated's (Venoco) Integrity Management Program (IMP) in Carpinteria, Cahfornia On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Venoco's IMP plan, as described below g 192. 905 (a) General. To determine which segments of an operator's transmission pipehne system are covered by this subpart, an operator must identify the high consequence areas. An operator must use method (1) or (2) from the definition in $192. 903 to identify a high consequence area. An operator may apply one method to its entire pipeline system, or an operator may apply one method to individual portions of the pipeline system. An operator must describe in its integrity management program which method it is applying to each portjlon of the oper'ator's pipeline system. The description must include the potential impact radius when utihzed to establish a#

520081007m_notice of amendment_09102008_text.pdf, page 2Item 1A Venoco did not specify in its IMP plan which method it was applying to identify HCAs. Item 18: Venoco needs to include system maps or other suitable detailed means for documenting the pipehne segment locations that are located in HCAs Item 1C. Venoco must ensure to apply the formula (r — 0. 69(p~d ) ) for the calculation of the potential impact radius accurately and consistently with $192 903 requirements. Item 10. Venoco must ensure to use pubhc officials as sources of information in its identification process for identified sites. Item 1E. Venoco must include details how it included as a high consequence area, any area in Class 1 and Class 2 piping locations where the potential impact circle contains an identified site. An operator's initial integrity management program begins with a framework (see. $192. 907) and evollves into a more detailed and comprehensive integrity management program, as information is gained and incorporated into the program. An operator must make continual improvements to its program. The initial program framework and subsequent p~ogram must, at minimum, contain the following elements. (When indicated, refe~ to ASMK/ANSI 831. 8S (incorporated by reference, see $192. 7) for more detailed information on the listed element. ) (c) An identification of threats to each covered pipehne segment, which must include data integration and a risk assessment. An operator must use the threat identification and risk assessment to prioritize covered segments for assessment ($192. 917) andi to evajluate the merits of additional preventive and mitigative measures ($192. 935) for each covered segment. Item 2A: Venoco needs to mclude details in its justification for ehminating threats m its threat analysis. Item 28: Venoco needs to include the use of a common spatial reference system and integration of data on encroachments and foreign hne crossings. Item 2C. Venoco needs to include further clarification and additional details on how its risk assessments are apphed to mitigative measures#

520081007m_notice of amendment_09102008_text.pdf, page 3Item 2D: Venoco needs to include details how risk assessment was recalculated for each segment to reflect the results from an mtegrity assessment or to account for completed prevention and mitigation actions. Item 2E Venoco must ensure adequate time and personnel have been allocated to permit effective implementation of its IMP plan and completion of the selected risk assessment approach (c) Schedule for evaluation and remediation . An oper ator must complete remediation of a condition according to a schedule prioritizing the conditions for evaluation and remediation. Unless a special requirement for remediating certain conditions appHes, as provided in paragraph (d) of this section, an operator must follow the schedule in ASMK/~SI 831. 8S (incorporated by reference, see $192. 7), section 7, Figure 4. If an operator cannot meet the schedule for any condition, the operator must explain the reasons why it cannot meet the schedule and how the changed schedule will not jeopardize pubhc safety. Item 3A: Venoco needs to include a requirement to document the justification, when a remediation activity cannot be completed within estabhshed timeframe This requirement must include reasons why the schedule cannot be met and the basis for why the changed schedule will not jeopardize pubhc safety Item 38: Venoco needs to more fully describe how it records "monitored conditions" and monitor these conditions during subsequent assessments. (f) A process for continual evaluation and assessment meeting the requirements of $192. 937. (b) Evaluation. An operator must conduct a periodic evaluation as frequently as needed to assure the integrity of each covered segment. The periodic evaluation must be based on a data integration and risk assessment of the entire pipeHne as specified in $192. 917. For plastic transmission pipeHnes, the periodic evaluation is based on the threat analysis specified in 192. 917(d). For al1l other transmission pipehnes, the evaluation must consider the past#

520081007m_notice of amendment_09102008_text.pdf, page 4Item 3C: Venoco needs to specify the frequency of its periodic evaluations. (b) Third party damage and outside force damage- (l) Thii 6 party damage. An operator must enhance its damage prevention program, as required under gjL92. 6l4 of this part, with respect to a covered segment to prevent and mininuze the consequences of a release due to third party damage. Enhanced measures to an existing damage prevention program include, at a (iv) Monitoring of excavations conducted on covered pipeline segments by pipeline personnel. 1f an operator finds physical evidence of encroachment involving excavation that the operator did not monitor near a covered segment, an operator must either excavate the area near the encroachment or conduct an above ground sur vey using methods defined in RACK RP — 0502 — 2002 (incorporated by reference see gl92. 7). An operator must excavate, and remediate, in accordance with ANS1/ASMK 83l. 8S and g]I. 92. 933 any indication of'coating holidays or discontinuity warranting direct examination. Item 3D: Venoco needs to indicate in its IMP plan that for locations where there is physical evidence of encroachment involving excavation, and Venoco did not monitor this excavation near a covered segment, that Venoco will either: excavate the suspect encroached area, or use above ground indirect survey methods to identify if there is damage to the pipehne and take appropriate remedial actions if necessary. (2) Outside force damage. 1f an operator determines that outside force ( e. g. , earth movement, floods, unstable suspension bridge) is a threat to the integrity of a covered segment, the operator must take measures to minimize the consequences to the covered segment from outside force damage. These measures include, but are not hmited to, inc~easing the frequency of aerial, foot or other methods of patrols, adding external protection, reducing external stress, and relocating the Hne. Item 3E: Venoco needs to complete its work on the action item identified to evaluate preventive and mitigative measures to address the threats on its pipehnes from potential earthquakes.#

520081007m_notice of amendment_09102008_text.pdf, page 5Item 3F Venoco needs to include a requirement to evaluate whether additional third party preventive and mitigative measures need to be implemented (a) General. An operator must include in its integrity management program methods to measure, on a semi-annual basis, whether the program is effective in assessing and evaluating the integrity of each covered pipehne segment and in protecting the high consequence areas. These measures must include the four overall performance measures specified in ASMK/AXSL 831. 8S (incorporated by reference, see $192. 7), section 9. 4, and the specific measures for each identified threat specified in ASMK/ANSI 831. 8S, Appendix A. An operator must submit the four overall performance measures, by electronic or other means, on a semi-annual frequency to OPS in accordance with $192. 951. An operator must submit its first report on overall performance measures by August 31, 2004. Thereafter, the performance measures must be complete through June 30 and Becember 31 of each year and must be submitted within 2 months after those dates. Item 36: Venoco needs to specify that performance is measured semi-annually in accordance with the threat-specific metrics of ASME B31. 8S-2001, Table 9. (d) Bocuments to support any decision, analysis and process developed and used to implement and evaluate each element of the basehne assessment plan and integrity management program. Bocuments include those developed and used in support of any identification, calculation, amendment, modification, justification, deviation and determination made, and any action taken to implement and evaluate any of the pr ogram elements; Item 3H: Venoco needs to expand the recordkeeping documentation requirements to support decisions, analyses, and calculations (k) A. management of change process as outlined in ASMK/ANSI 831. 8S, section 11. Item 3I: Venoco needs to include reasons for changes in MOC process documentation Item 3J. Venoco needs to ensure that for significant changes in its IMP plan, it provides notification to PHMSA, i. e. the change from 1 '/z+ miles to 37+ miles of transmission pip ehne.#

520081007m_notice of amendment_09102008_text.pdf, page 6Item 314' Venoco needs to update the MOC process' Information Update List under DOT Comphance Review, to include IMP plan impacts/revisions, and to ensure the MOC SOP addresses impact to the IMP plan in its processes. Item 3L. Venoco needs to ensure that meeting notes and corrective action to improve iis IMP plan and the quality assurance processes have been documented Item 3M: Venoco needs to mclude a process to ensure the quahty of work of its contractors performing IMP related activities Iem 3N: Venoco needs to mclude mternal communication plan to establish the understanding and support for the IMP. Item 30: Venoco needs to include details of how it will address safety concerns raised by State and OPS pipehne safety authorities in its Communications Plan. Res onse to this Notice This Notice is provided pursuant to 49 U. S. C. ( 60108(a) and 49 C. F. R. ) 190. 237. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance ProceeCings Please refer to this document and note the response options. Be advised that all material you submit in response to this enforcement action is subject to being made pubhcly available. If you beheve that any portion of your responsive material quahfies for confidential treatment under 5 U. S. C. 552(b), along with the complete original document you must provide a second copy of the document with the potions you beheve quahfy for confidential treatment redacted and an explanation of why you beheve the redacted information quahfies for confidential treatment under 5 U. S. C. 552(b). If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations m this Notice and authorizes the Associate Administrator for Pipehne Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C. F. R. ) 190. 237) If you are not contesting this Notice, we propose that you submit your amended procedures to my office within [number of days] days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed#

520081007m_notice of amendment_09102008_text.pdf, page 7In correspondence concerning tins matter, please refer to CPF 5-2008-1007M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, ( Chris Hoidal Director, Western Region Pipehne and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings cc PHP-60 Comphance Registry PHP-500 (P. Nguyen, ¹119231)#