{"operation":"document","citation":"CPF 520172001W","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":null,"summary":"CLOSED warning letter citing 192.465(a), 192.605(a), 192.947(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520172001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520172001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520172001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520172001W","body":"Warning Letter involving VENOCO, INC. PHMSA's enforcement data identifies the cited regulations as 192.465(a),  192.605(a),  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.\n\nOfficial case documents:\n\n520172001W_Warning Letter_09152017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520172001W/520172001W_Warning%20Letter_09152017.pdf\n\n520172001W_Warning Letter_09152017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520172001W/520172001W_Warning%20Letter_09152017_text.pdf\n\n520172001W_Warning Letter_09152017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED\nSeptember 15, 2017\nMr. Michael Wracher\nChief Operating Officer\nVenoco, Inc.\n6267 Carpinteria Ave., Suite 100\nCarpinteria, CA 93013\nCPF 5-2017-2001W\nDear Mr. Wracher:\nOn May 30, 2017 to June 1, 2017, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected Venoco Inc.’s (Venoco) Offshore Gas Pipeline system connected to its Platform\nGrace and Carpinteria Onshore Oil and Gas Facility in Carpinteria, California.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items\ninspected and the probable violation(s) are:\n\n\n\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual\nof written procedures for conducting operations and maintenance activities and\nfor emergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed\nand updated by the operator at intervals not exceeding 15 months, but at least\nonce each calendar year. This manual must be prepared before operations of a\npipeline system commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\nVenoco did not review and update its manual of written procedures for emergency response at\nintervals not exceeding 15 months, but at least once each calendar year. Venoco’s Santa\nClara Unit Oil Spill and Gas Contingency Plan’s (dated 12/2016) Record of Revision did not\nshow an annual review for each calendar year in the past 5 years. Calendar years 2013 and\n2015 review and update were not documented on the Record of Revision.\n2. §192.947 What records must an operator keep?\nAn operator must maintain, for the useful life of the pipeline, records that\ndemonstrate compliance with the requirements of this subpart. At minimum, an\noperator must maintain the following records for review during an inspection.\n(d) Documents to support any decision, analysis and process developed and used\nto implement and evaluate each element of the baseline assessment plan and\nintegrity management program. Documents include those developed and used in\nsupport of any identification, calculation, amendment, modification, justification,\ndeviation and determination made, and any action taken to implement and\nevaluate any of the program elements.\nVenoco did not maintain, for the useful life of the pipeline, records that demonstrate\ncompliance with §192.935(a). Venoco did not provide records that demonstrated that\nadditional measures have been identified and implemented (or scheduled) beyond those\nalready required by Part 192 to prevent a pipeline failure and to mitigate the consequences of\na pipeline failure in a high consequence area. Specifically, Venoco did not provide “Gas\nIntegrity Management Plan (IMP) Element #8, Preventive and Mitigative Measures Agenda\nand Action Items” for the last 3 calendar years. This document was intended to be used for\nreview and implementation of Element #8 in accordance with Venoco’s IMP Element #8\nPreventive and Mitigative Measures written procedure.\n3. §192.465 External corrosion control: Monitoring.\n(a) Each pipeline that is under cathodic protection must be tested at least once\neach calendar year, but with intervals not exceeding 15 months, to determine\nwhether the cathodic protection meets the requirements of §192.463. However, if\ntests at those intervals are impractical for separately protected short sections of\nmains or transmission lines, not in excess of 100 feet (30 meters), or separately\nprotected service lines, these pipelines may be surveyed on a sampling basis. At\nleast 10 percent of these protected structures, distributed over the entire system2\n\n\n\nmust be surveyed each calendar year, with a different 10 percent checked each\nsubsequent year, so that the entire system is tested in each 10-year period.\nVenoco did not test its Offshore Gas Pipeline system that is under cathodic protection (CP) at\nleast once each calendar year, but with intervals not exceeding 15 months, to determine\nwhether the CP meets the requirements of §192.463. In 2015, the CP test on Platform Grace\nwas conducted on March 28, 2015. Then in 2016, the CP test on Platform Grace was\nconducted on September 24, 2016. Therefore, the 2016 CP test was late and exceeded the 15-\nmonth interval required by §192.465(a).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022\nfor a related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time. We advise you to correct the items\nidentified in this letter. Failure to do so will result in Venoco, Inc. being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2017-2001W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b),\nalong with the complete original document you must provide a second copy of the document\nwith the portions you believe qualify for confidential treatment redacted and an explanation of\nwhy you believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 C. Ishikawa (#155480)\nVenoco, Inc. 370 17th Street, Suite 3900, Denver, CO 80202-1370\n3","truncated":false,"body_characters":6749}