# VENOCO, INC — Warning Letter

- **operation:** document
- **citation:** CPF 520120017W
- **title:** VENOCO, INC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2012-07-06
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.605(b)(8).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520120017w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520120017W
**body:**

Warning Letter involving VENOCO, INC. PHMSA's enforcement data identifies the cited regulation as 192.605(b)(8). The case was opened on 2012-07-06 and is reported as closed as of 2012-07-06. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520120017W_Warning letter_07062012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520120017W/520120017W_Warning%20letter_07062012.pdf

520120017W_Warning letter_07062012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520120017W/520120017W_Warning%20letter_07062012_text.pdf

520120017W_Warning letter_07062012_text.pdf

WARNING LETTER
CERTIFIED MAIL [7006 3450 0001 7095 3361] - RETURN RECEIPT REQUESTED
July 6, 2012
Mr. Keith Wenal
HES Manager
Venoco, Inc.
6267 Carpinteria Ave., Suite 100
Carpinteria, CA 93013-1423
CPF 5-2012-0017W
Dear Mr. Wenal:
On September 26-30, 2011, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
offshore natural gas pipeline that extends from Platform Grace to the Venoco Oil & Gas
Processing Plant near the city of Carpinteria, California.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and
the probable violation is:
1. §192.605 Procedural manual for operations, maintenance, and emergencies.
(b) Maintenance and normal operations. The manual required by paragraph (a)
of this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(8) Periodically reviewing the work done by operator personnel to determine the
effectiveness, and adequacy of the procedures used in normal operation and
maintenance and modifying the procedures when deficiencies are found.
At the time of the inspection, records were not available to show compliance with the
requirement to periodically review personnel work to confirm the effectiveness of normal
O&M procedures since 2008.



Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000
for any related series of violations. We have reviewed the circumstances and supporting
documents involved in this case, and have decided not to conduct additional enforcement
action or penalty assessment proceedings at this time. We advise you to correct the item(s)
identified in this letter. Failure to do so will result in Venoco, Inc. being subject to additional
enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 5-2012-0017W. Be advised that all material you submit in response to this
enforcement action is subject to being made publicly available. If you believe that any portion
of your responsive material qualifies 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 portions you believe qualify for confidential treatment redacted and an explanation of why
you believe the redacted information qualifies for confidential treatment under 5 U.S.C.
552(b).
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Kenerson (#132927)
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