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2002 Civil Penalties

2002 Civil Penalties

 2002 Civil Penalties

The goal of the OCS Civil Penalties Program is to assure safe and clean operations on the OCS. Through the pursuit, assessment, and collection of civil penalties and referrals for the consideration of criminal penalties, the program is designed to encourage compliance with OCS statutes and regulations.

2002 Civil Penalties Summary
All Penalties Paid in Calendar 2002

(1/1/2002 – 12/31/2002)

Operator Name
and Case No.

Violation and Date(s)

Penalty Paid and
Date Paid

Regulation(s) Violated
(30 CFR)

The Louisiana Land and Exploration Company

G-2000-047

The master shutdown devices for bad oil pump number 1, bad oil pump number 2 and for 7 wells were bypassed; as well as the pressure safety low on the fuel gas scrubber.

06/14/00 – 06/14/00

$85,000

01/11/02

250.803(c)(1)
Fairways Specialty Sales & Service, Inc.

G-2001-004

Operator did not conduct an annual crane inspection and the Low Pressure Oil Separator was operating above the MAWP.

06/03/00 – 10/26/00
09/23/00 – 10/30/00

$83,000

04/12/02

250.107(a)
250.108
El Paso Production Oil & Gas Company

G-2001-005

The level safety high on the sump tank was bypassed.

10/13/00 – 10/13/00

$13,000

02/13/02

250.803(c)(1)
Matrix Oil & Gas, Inc.

G-2001-006

INC issued for a hole was in piping caused by corrosion approximately one foot down stream of the PSV on the test separator.

09/14/00 – 09/29/00

$17,000

11/19/02

250.107
Fairways Specialty Sales & Service, Inc.

G-2001-009

Facility was not identified as required and the operator did not correct the violation until 209 days after being cited. Civil Penalty is being pursued as a failure to correct. Facility had corrosion problems including rusty handrails, nuts, bolts, nipples, and valves and the operator did not correct the violation until 213 days after being cited. Civil Penalty is being pursued as a failure to correct.

07/11/00 – 02/04/01
07/11/00 – 02/08/01

$84,800

04/12/02

250.154
250.107
Fairways Specialty Sales & Service, Inc.

G-2001-010

Facility was not identified as required and the operator did not correct the violation until 90 days after being cited. Civil Penalty is being pursued as a failure to correct. Facility had corrosion problems including rusty piping,  handrails, nuts, bolts, nipples, and valves and the operator did not correct.

11/06/00 – 02/01/01
11/06/00 – 02/05/01

$26,200

04/12/02

250.107
250.154
EEX Corporation

G-2001-013

Pressure safety low on condensate pump bypassed.

12/01/00 – 12/01/00

$7,500

03/19/02

250.803(c)(1)
El Paso Production Oil & Gas Company

G-2001-015

There were 5 wells where the downhole tubing plug was not tested within the required timeframe.

06/04/00 – 02/20/01

$7,000

02/01/02

250.804(a)(1)(iii)
Texaco Exploration and Production Inc.

G-2001-017

Inoperable Gas Detection system in the drilling mud returns.

04/17/01 – 04/17/01

$12,500

01/29/02

250.410(c)(2)(iv)
Amerada Hess Corporation

G-2001-018

ESD (emergency shut-down) station on boat landing was bypassed; the PSHL (pressure safety high/low) on the departing oil pipeline was found bypassed; and the PSV (pressure safety valve) on the bulk oil dual separator was bypassed.

04/11/01 – 04/11/01
03/31/01 – 03/31/01
03/31/01 – 03/31/01

$36,000

04/18/02

250.803(c)(1)
250.803(c)(1)
250.1004(b)(3)
The Louisiana Land and Exploration Company

G-2001-020

The SCSSV for Wells Nos. B-1 and B-3 was bypassed.

03/07/01 – 03/07/01

$20,000

01/11/02

250.803(c)(1)
Texaco Exploration and Production Inc.

G-2001-021

Bypassed manual reset relay for the test separator.

05/21/00 – 05/21/00

$10,000

01/23/02

250.803(c)(1)
Chevron U.S.A. Inc.

G-2001-024

The surface safety value (SSV) for Well C-7 was bypassed.

06/15/01 – 06/16/01

$20,000

01/23/02

250.803(c)(1)
BP Corporation North America Inc.

G-2001-025

Level safety low (LSL) for glycol/hydrocarbon separator was found bypassed.

06/12/01 – 06/13/01

$20,000

01/10/02

250.803(c)(1)
El Paso Production GOM Inc.

G-2001-026

Burner safety low on glycol reboiler was found bypassed. It was not flagged or being monitored at the time.

05/24/01 – 05/24/01

$12,000

06/05/02

250.803(c)(1)
El Paso Production Oil & Gas Company

G-2001-027

ESD station blocked out of service by a closed manual isolation block valve located on the sub-cellar deck exit stairway to the boat landing.

06/19/01 – 06/19/01

$17,000

04/15/02

250.803(c)(1)
Chevron U.S.A. Inc.

G-2001-028

Pollution occurred when both the wet oil tank and sump tank carried over. The level safety high (LSH) on the wet oil tank did not shut-in the platform as indicated on SAFE chart.

05/25/01 – 05/25/01
05/25/01 – 05/25/01

$36,000

01/29/02

250.300(a)
250.802(e)
Denbury Resources Inc.

G-2001-029

A major component of the approved dry chemical firefighting system was inoperable.

05/08/01 – 05/08/01

$15,000

03/07/02

250.803(b)(8)
PANACO, INC.

G-2001-030

The ultraviolet (UV) fire detection system for turbine generators were bypassed plus no record of testing the fire detection system from 5/2/99 to 5/2/01.

05/02/99 – 05/02/01
05/02/01 – 05/02/01

$151,000

02/12/02

250.804(a)(8)
250.803(c)(1)
NCX Company, Inc.

G-2001-031

The 2' ball valve for the by-pass line, near the fuel gas scrubber shut down valve (SDV) was in the half-open position rendering the SDV inoperative.

07/11/01 – 07/11/01

$12,000

04/24/02

250.803(c)(1)
Stone Energy Corporation

G-2001-034

Five barrels of oil polluted the Gulf of Mexico. The pressure safety high/low and independent pressure safety high were bypassed.

07/05/01 – 07/05/01
07/05/01 – 07/05/01

$35,000

05/03/02

250.803(c)(1)
250.300(a)
Energy Partners, Ltd.

G-2001-035

The surface safety valve on Well C-1A was bypassed.

07/22/01 – 07/22/01

$10,000

06/10/02

250.803(c)(1)
Devon Energy Production Company, L. P.

G-2001-036

Operating with an inoperable inlet SDV on the compressor suction scrubber while the compressor remained in service and on production for 76 days.

04/25/01  –  07/09/01

$15,200

08/12/02

250.803(b)(7)(iii)
Amoco Production Company

G-2001-037

Fuel Gas Scrubber SDV bypassed and PSH nonfunctional.

07/17/01 – 07/17/01

$15,000

04/02/02

250.803(c)(1)
Energy Resource Technology, Inc.

G-2001-038

The high-pressure freewater knockout separator panel was pinned out of service.

11/30/00 – 11/30/00

$15,000

06/11/02

250.803(c)(1)
NCX Company, Inc.

G-2001-039

The manual emergency shut down (ESD) station located on the east production deck stairway exit to the cellar deck was found disconnected from the facility ESD system and the platform's monitoring gas detection system (ASH) was found bypassed.

07/17/01 – 07/17/01
07/17/01 – 07/17/01

$24,500

03/22/02

250.803(c)(1)
250.803(b)(4)
BP Exploration & Oil Inc.

G-2001-040

Rig floor hand injured after receiving a shock from an improperly grounded skid mounted electrical pressure washer.

03/15/01 – 03/15/01

$23,000

05/09/02

250.114(c)
Apache Corporation

G-2001-041

Surface safety valve (SSV) on Well No. A-5 was found pinned out of service.

07/16/01 – 07/16/01

$13,000

05/10/02

250.803(c)(1)
GOM Shelf LLC

G-2001-042

The emergency shutdown stations (ESD's) at the S/E and N/W stairways at the +10 deck were discovered inoperable. The ESD's at the S/W and N/E boat landings were also discovered inoperable.

07/24/01 –  07/24/01

$60,000

09/24/02

250.803(b)(4)
Devon Energy Production Company, L.P.

G-2001-044

The 'total system bypass' was found in the bypass position on a slave panel. This bypassed the pressure safety high/low and level safety high on the fuel gas scrubber.

06/27/01 – 06/27/01

$3,000

06/20/02

250.803(c)(1)
Union Oil Company of California

G-2001-045

The level safety high on the sump tank was bypassed.

07/23/01 – 07/23/01

$10,000

04/16/02

250.803(c)(1)
Union Oil Company of California

G-2001-047

The emergency shut down (ESD) station at the boat landing was found blocked out of service

08/12/01 –  08/12/01

$5,000

09/11/02

250.803(c)(1)
Union Oil Company of California

G-2002-001

The emergency shut down (ESD) stations on the northwest, southwest, east, and west boat landings were all bypassed.

09/18/01 –  09/18/01

$20,000

09/11/02

250.803(c)(1)
Nuevo Energy Company

P-2002-001

Failure to test fire and gas detection systems on required basis (every 3 months); 1 testing period missed. Failure to conduct required monthly testing for flow safety valves on water injection wells for 2 months; 2 testing periods missed.

06/22/01 –  07/23/01        06/23/01 –  07/13/01

$6,000

08/08/02

250.804(a)(8)
250.804(a)(8)
Union Oil Company of California

G-2002-003

Pressure safety high/low and level safety high on fuel gas scrubber were found bypassed.

09/25/01 – 09/25/01                09/25/01 –  09/25/01

$17,500

09/11/02

250.803(c)(1)
250.803(c)(1)
Fairways Specialty Sales & Service, Inc.

G-2002-004

Oil was observed entering the Gulf of Mexico from two different sources associated with the water clarifier:  from the open end of an unapproved 4” PVC line installed on the water overboard discharge line and extending approximately 20' into the air, and directly from the water overboard discharge line due to a malfunctioning dump valve.

09/28/01 –  09/28/01            09/28/01 –  09/28/01

$42,500

08/20/02

250.802(e)
250.300(a)
J. M. Huber Corporation

G-2002-005

The sump pump was not operational resulting in pollution of crude oil into Gulf waters.

10/30/01 –  10/30/01            10/30/0110/30/01

$35,000

08/16/02

250.300(b)(4)
250.300(a)
Fairways Specialty Sales & Service, Inc.

G-2002-006

Emergency shut down stations at two boat landings and the shut down valve to the test separator were bypassed.

11/07/01 – 11/07/01          11/08/01 – 11/08/01

$28,000

08/20/02

250.803(c)(1)
250.803(c)(1)
Linder Oil Company, A Partnership

G-2002-008

The walkway to the sump tank, handrails on a stairway and +12 walkway, and grating at the wellbay area on the +12 level were not maintained in a safe condition. The walkway and handrails had corroded to the point of separation and the grating had missing sections.

08/28/01 – 09/20/01

$25,000

09/10/02

250.107
Union Oil Company of California

G-2002-010

Three emergency shut down stations were bypassed at the +10 deck level.

10/29/0111/06/01

$15,000

09/11/02

250.803(c)(1)
Kerr-McGee Corporation

G-2002-011

The surface-controlled subsurface safety valves in Wells A-6 & A-6D were bypassed for 11 days.

09/14/01 – 09/24/01

$66,000

10/22/02

250.803(c)(1)
Vastar Resources, Inc.

G-2002-012

Two emergency shut down stations were inoperable; one at the boat landing on the F structure and one at the boat landing on the I structure.

12/03/01 – 12/03/01

$37,000

08/13/02

250.803(b)(4)
Kerr-McGee Oil & Gas Corporation

G-2002-013

Rusty vessel, walkways, stairways, and grating preventing safe operations.

12/21/0112/21/01

$20,000

10/22/02

250.107
Shell Offshore Inc.

G-2002-014

Flowline pressure-activated relay had a pin inserted in it thereby bypassing the pressure safety high/low for flowline segment FA-2.

10/01/01 – 10/01/01

$12,000

12/09/02

250.803(c)(1)
Exxon Mobil Corporation

G-2002-015

Secondary sump pump, approved in lieu of level safety high on sump tank, found out of service

01/10/02 – 01/11/02

$15,000

09/09/02

250.802(e)
Seneca Resources Corporation

G-2002-016

Surface-controlled subsurface safety valve (SCSSV) for Well No. 15 was bypassed and out of service.

12/11/0112/14/01

$32,000

08/28/02

250.803(c)(1)
J. M. Huber Corporation

G-2002-017

Relay for Well Number 81 Surface Safety Valve pinned out of service

01/08/02 – 01/08/02

$7,000

08/27/02

250.803(c)(1)
BP Exploration & Production Inc.

G-2002-018

The oil low level sensor on the heater treater was not tested within the required timeframe (missed 13 monthly tests).

12/13/0012/03/01

$39,000

09/16/02

250.804(a)(3)
Chevron U.S. A. Inc.

G-2002-019

The gas sales pipeline (KAH 827) did not have secondary over-pressure protection.

11/13/0111/13/01

$23,000

09/30/02

250.1002(d)
Burlington Resources Offshore Inc.

G-2002-020

The firewater pump was in the manual mode instead of the automatic mode, as required by the approved SAFE chart. The float cell oil pump's shutdown valve was bypassed.

04/20/01 – 04/20/01        04/20/01 – 04/20/01

$47,500

12/05/02

250.802(e)
250.803(c)(1)
Remington Oil and Gas Corporation

G-2002-024

Remote BOP control station was found inoperable.

04/18/02 – 04/18/02

$12,500

12/04/02

250.406(d)(3)
Vastar Resources, Inc.

G-2002-030

Leaking valves causing gas blow by and incorrectly operated Flotation Cell causing gas accumulation resulting in a fire which required an emergency evacuation of personnel and a shut in of the facility.

02/12/02 – 02/12/02

$20,000

12/10/02

250.107
LLOG Exploration Offshore, Inc.

G-2002-031

Two violations involving a ventilation alarm failure in the mud pit room when the ventilation fan was turned off and an audible alarm failure when testing the mud return indicator.

03/25/0203/25/02

$25,000

12/20/02

250.410(c)(2)(iii)
250-410(e)(1)
Conoco Inc.

G-2002-032

Surface-controlled subsurface safety valve for Well A-6 was blocked out of service.

05/08/02 – 05/08/02

$10,000

11/27/02

250.803(c)(1)
Conoco Inc.

G-2002-035

Surface-controlled subsurface safety valve for Well A-5 was blocked out of service

05/09/02 – 05/09/02

$5,000

11/27/02

250.803(c)(1)
Chevron U.S.A. Inc

G-2002-029

The automatic backup accumulator charging system was rendered inoperable by closed air supply valves.

4/23/024/24/02

$30,000

12/20/02

250.515(c)(2)

Total Penalties Paid: 1/1/02 – 12/31/02

56 Cases: $1,503,700

The following acronyms are used in this table:

ESD

Emergency Shutdown Device

INC

Incident of Non-Compliance

LACT

Liquid Automatic Custody Transfer

LSH

Level Safety High

LSL

Level Safety Low

MAWP

Maximum Allowable Working Pressure

NON

Notice of Non-Compliance

PSHL

Pressure Safety High/Low

PSL

Pressure Safety Low

PSV

Pressure Safety Valve

SCSSV

Surface Controlled Subsurface Safety Valve

SDV

Shut Down Valve

SSV

Subsurface Valve

The purpose of publishing the penalties summary is to provide information to the public on violations of special concern in OCS operations and to provide an additional incentive for safe and environmentally sound operations.

The Oil Pollution Act (OPA 90) strengthened section 24 of the OCS Lands Act Amendments of 11038. Subtitle B of OPA 90, entitled 'Penalties,' increased the amount of the civil penalty from a maximum of $10,000 to a maximum of $20,000 per violation for each day of noncompliance. More importantly, in cases where a failure to comply with applicable regulations constitutes or constituted a threat of serious, irreparable, or immediate harm or damage to life (including fish and other aquatic life); property; any mineral deposit; or the marine, coastal, or human environment; OPA 90 provided the Secretary of the Interior with the authority to assess a civil penalty without regard to the requirement of expiration of a period of time allowed for corrective action.
 
On August 8, 1997, the MMS published new regulations(22 KB PDF) implementing the civil penalty provisions of the OCS Lands Act. Written in 'plain English,' the new question-and-answer format provides a better understanding of the OCS civil penalty process. In addition, the provisions of OPA 90 require the Secretary of the Interior to adjust the maximum civil penalty to reflect any increases in the Consumer Price Index. The new rule increased the maximum civil penalty to $25,000 per day per violation.