# VENOCO, INC — Warning Letter

- **operation:** document
- **citation:** CPF 520170018W
- **title:** VENOCO, INC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2017-09-15
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.491(c), 192.605(a), 192.615(b)(2), 192.947(d).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520170018w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520170018w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520170018w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520170018W
**body:**

Warning Letter involving VENOCO, INC. PHMSA's enforcement data identifies the cited regulations as 192.491(c),  192.605(a),  192.615(b)(2),  192.947(d). The case was opened on 2017-09-15 and is reported as closed as of 2017-09-15. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520170018W_Warning Letter_09152017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170018W/520170018W_Warning%20Letter_09152017.pdf

520170018W_Warning Letter_09152017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170018W/520170018W_Warning%20Letter_09152017_text.pdf

520170018W_Warning Letter_09152017_text.pdf

WARNING LETTER
CERTIFIED MAIL – RETURN RECEIPT REQUESTED
September 15, 2017
Mr. Michael Wracher
Chief Operating Officer
Venoco, Inc.
6267 Carpinteria Ave., Suite 100
Carpinteria, CA 93013
CPF 5-2017-0018W
Dear Mr. Wracher:
On May 30, 2017 to June 1, 2017, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),
inspected Venoco Inc.’s (Venoco) Ellwood Gas Sales Line connected to its Ellwood Onshore
Facility in Carpinteria, California.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items
inspected and the probable violation(s) are:
1. §192.605 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include



procedures for handling abnormal operations. This manual must be reviewed
and updated by the operator at intervals not exceeding 15 months, but at least
once each calendar year. This manual must be prepared before operations of a
pipeline system commence. Appropriate parts of the manual must be kept at
locations where operations and maintenance activities are conducted.
Venoco did not review and update its manual of written procedures for emergency response at
intervals not exceeding 15 months, but at least once each calendar year. Venoco’s South
Ellwood Field and Line 96 Emergency Action Plan’s (Revision 6 dated 12/2016) Record of
Revision did not show an annual review for each calendar year in the past 5 years. Calendar
years 2012, 2013, and 2015 review and update were not documented on the Record of
Revision.
2. §192.615 Emergency plans.
(b) Each operator shall:
(2) Train the appropriate operating personnel to assure that they are
knowledgeable of the emergency procedures and verify that the training is
effective.
Venoco did not demonstrate that it trained the appropriate operating personnel to assure that
they are knowledgeable of the emergency procedures and verify that the training is effective.
Specifically, Venoco did not provide written records of emergency response training covering
the appropriate operating personnel for its Ellwood Onshore Facility.
3. §192.947 What records must an operator keep?
An operator must maintain, for the useful life of the pipeline, records that
demonstrate compliance with the requirements of this subpart. At minimum, an
operator must maintain the following records for review during an inspection.
(d) Documents to support any decision, analysis and process developed and used
to implement and evaluate each element of the baseline assessment plan and
integrity management program. Documents 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 program elements.
Venoco did not maintain, for the useful life of the pipeline, records that demonstrate
compliance with §192.935(a). Venoco did not provide records that demonstrated that
additional measures have been identified and implemented (or scheduled) beyond those
already required by Part 192 to prevent a pipeline failure and to mitigate the consequences of
a pipeline failure in a high consequence area. Specifically, Venoco did not provide “Gas
Integrity Management Plan (IMP) Element #8, Preventive and Mitigative Measures Agenda
and Action Items” for the last 3 calendar years. This document was intended to be used for
review and implementation of Element #8 in accordance with Venoco’s IMP Element #8
Preventive and Mitigative Measures written procedure.
2



4. §192.491 Corrosion control records.
(c) Each operator shall maintain a record of each test, survey, or inspection
required by this subpart in sufficient detail to demonstrate the adequacy of
corrosion control measures or that a corrosive condition does not exist. These
records must be retained for at least 5 years, except that records related to
§§192.465 (a) and (e) and 192.475(b) must be retained for as long as the pipeline
remains in service.
Venoco did not maintain a record of each test, survey or inspection required by Subpart I in
sufficient detail to demonstrate the adequacy of corrosion control measures or that a corrosive
condition does not exist. Specifically, Venoco did not provide records that demonstrated it
conducted inspections of its Ellwood Gas Sales Line aboveground pipe for atmospheric
corrosion in accordance with §192.481.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to
exceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022
for a 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 items
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 5-2017-0018W. 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,
Kim West
Acting Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 C. Ishikawa (#155478)
Venoco, Inc. 370 17th Street, Suite 3900, Denver, CO 80202-1370
3
- **truncated:** false
- **body characters:** 6903