2003 Civil Penalties
The goal of the OCS Civil/Criminal 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.
2003 Civil Penalties Summary
All Penalties Paid Calendar 2003
(1/1/2003 - 12/31/2003)
|
Operator Name |
Violation and Date(s) |
Penalty Paid and |
Regulation(s) Violated |
|
Tri-Union Development Corporation G-1999-033 |
The PSH, PSL, LSH, LSL (water), and LSL (oil) for the remote well separator were bypassed at the master panel. 05/17/99 – 05/18/99 |
$30,000 06/18/03 |
30 CFR 250.803(c) |
|
Tri-Union Development Corporation (Offshore Consulting Services) G-1999-036 |
The SCSSV for Well A-1 was bypassed. 05/25/99 – 05/25/99 |
$15,000 06/18/03 |
30 CFR 250.803(c) |
|
Tri-Union Development Corporation G-2000-003 |
The PSV on the glycol separator was bypassed and not flagged properly or monitored. 11/04/99 – 11/08/99 |
$10,000 06/18/03 |
30 CFR 250.803(c) |
|
Tri-Union Development Corporation (Offshore Consulting Services) G-2000-012 |
This case involves 23 INC's. Two were failure to correct violations regarding hole in grating and broken handrails. The other 21 concerned improperly maintained and tested safety equipment including the ESD stations and the PSH's, PSL's, and PSV's on many production vessels. 11/01/98 – 03/23/99 |
$338,800 06/18/03 |
30 CFR 250.20(c) |
|
Tri-Union Development Corporation G-2000-013 |
The PSH on Well A-3 was not tested as required. 05/15/99- 05/25/99 |
$7,500 06/18/03 |
30 CFR 250.804(a)(3) |
|
Tri-Union Development Corporation (Target Operators and Consulting, Inc.) G-2000-015 |
The LSL on the Glycol Reboiler Surge Tank and the PSL on the Natural Draft Unit of the Reboiler were not tested for one month. 10/23/99 - 10/23/99 |
$24,000 06/18/03 |
30 CFR 250.804(a)(3) |
|
Tri-Union Development Corporation (Target Operators and Consulting, Inc.) G-2000-016 |
The LSH on the sump tank was bypassed.
10/14/99 - 10/14/99 |
$15,000 06/18/03 |
30 CFR 250.803(c) |
|
Tri-Union Development Corporation (Target Operators and Consulting, Inc.) G-2000-017 |
Tri-Union produced on 5/25/99 while under a shut-in order pending corrective action. 05/25/99 – 05/25/99 |
$8,000 06/18/03 |
30CFR 250.110(b)(1) |
|
Tri-Union Development Corporation (Target Operators and Consulting, Inc.) G-2000-018 |
Failure to correct violations issued during 5/7/99 inspection concerning sustained casing pressure on Well No. 1.
05/07/99 – 08/25/99 |
$22,200 06/18/03 |
30 CFR 250.517(c) |
|
Tri-Union Development Corporation G-2000-019 |
No record of testing PSH and PSL on MAJ-1902 (Compressor Fuel Filter) since component was installed on 8/14/99. 09/14/99 – 12/07/99 |
$36,000 06/18/03 |
30 CFR 250.804(a)(3) |
|
Tri-Union Development Corporation (Nabors Drilling Inc.) G-2002-009 |
During a workover operation on Well A-2, the blowout preventer system was not equipped with an operable kill line. Also, there was not a remotely controlled valve on the choke line. These violations existed for 16 days. 07/11/01 – 07/11/01 |
$160,000 06/30/03 |
30 CFR 250.615(c) |
|
Transworld Exploration and Production, Inc. (Island Operators Co. Inc.) G-2002-021 |
The firewater pump was bypassed for 2 days.
08/22/01 – 08/23/01 |
$30,000 05/02/03 |
30 CFR 250.803(c) |
|
Amerada Hess Corporation G-2002-022 |
Operating upstream a vessel with the Pressure Safety Valve and Pressure Safety High set above the maximum allowable operating pressure of the departing oil pipeline with the pressure safety valve was taken out of service (SAC'd out) on the departing oil pipeline. 02/07/02 - 02/07/02 |
$10,000 01/29/03 |
30 CFR 250.1002 |
|
Seneca Resources Corporation G-2002-023 |
Operations were not performed in a safe and workmanlike manner, in that, the choke line was below the bottommost rams. This was due to the incorrect size rams that were originally placed below the choke line during a workover operation. 02/25/02 – 03/13/02 |
$85,000 01/30/03 |
30 CFR 250.107(a) |
|
Union Oil company of California G-2002-025 |
Subsurface safety devices in Wells A-2, A-3, A-5, A-6, A-7, A-8, A-10, A-11, A-21, A-22, A-23, A-25, A-26, A-27, A-29, A-31, A-33, and subsea well #1 not tested for proper operations and leakage from September 25, 2000 to May 2001. Must be tested every 6 months. Missed one test per well. 04/01/01 – 05/02/01 |
$54,000 04/01/03 |
30 CFR 250.804(a)(1) |
|
Kerr-McGee Oil & Gas Corporation G-2002-026 |
The subsurface safety valves in two completions were found leaking and left in service without repairing/replacing the valves. One downhole valve was known to be leaking for 186 days; the other, 365 days. 01/01/01 – 01/07/02 |
$467,950 04/09/03 |
30 CFR 250.804(a)(1) |
|
Union Oil Company of California G-2002-028 |
Subsurface safety devices in Wells A-1, A-2, A-3, A-4, and A-5 not tested for proper operation and leakage from September 25, 2001 to May 19, 2002. Must be tested every 6 months. Missed one test per well. 03/31/02 – 05/19/02 |
$15,000 04/01/03 |
30 CFR 250.804(a)(1) |
|
BP Exploration & Production Inc. (Charlie & Demples Production (C&D Production)) G-2002-033 |
The fire water system was operating below the minimum required 75 psi. 06/19/02 - 06/19/02 |
$70,000 01/09/03 |
30 CFR 250.803(b)(8) |
|
PetroQuest Energy, L.L.C. (Baker Energy, Inc.) G-2002-034 |
Lessee failed to prevent pollution to the offshore water (sheen measured approximately 1/4 mile long). The pressure safety high was bypassed on the Well No. 26 flow line for 4 days. 05/21/02 – 05/24/02 |
$61,500 05/05/03 |
30 CFR 250.803(c) |
|
Samedan Oil Corporation (Offshore Production Corporation) G-2002-036 |
The C-5, C-9 and C-14D wells were bypassed on the master control panel by tie-wrapping the relays in an open position. 05/31/02 – 05/31/02 |
$45,000 04/25/03 |
30 CFR 250.803(c) |
|
Chevron U.S.A. Inc. (Danos & Curole Marine Contractors, Inc.) G-2002-037 |
The pressure safety lows on the two oil charge pumps and the pressure safety highs/lows on the on the two pipeline pumps were bypassed for 7 days. 05/09/02 - 05/15/02 |
$210,000 01/24/03 |
30 CFR 250.803(c) |
|
BP Exploration & Production Inc. G-2002-038 |
Bypassed Relays for the Pressure Safety High/Low for four producing wells. 05/07/02-05/10/02 |
$80,000 01/09/03 |
30 CFR 250.803(c) |
|
Transworld Exploration and Production, Inc. (Production Management Incorporated) G-2002-039 |
The subsurface controlled subsurface safety valve (SSCSV) in Well C-1 was removed on 3/27/00; well was left with open wellbore until new valve installed on 7/13/00. Master surface safety valve (SSV) and manual master in Well C-1 leaking since 3/27/00; not repaired as of 7/10/00 inspection. The surface controlled subsurface safety valve in Well C-5 was tested for leakage on 6/11/00; the leakage rate was calculated as exceeding the allowable leakage rate. The well was not shut-in and the valve was not repaired; instead, the well continued to produce. It has since been determined that the calculation included an error and the rate actually did not exceed the allowable rate. 03/27/00 – 07/11/00 |
$82,500 12/09/03 |
30 CFR 250.804(a)(4) |
|
Vastar Offshore, Inc. G-2002-043 |
The portable High Pressure Electrical Steam Cleaner and portable vacuum machine did not use an external ground for safe operations. 06/27/02 – 06/27/02 |
$20,000 04/14/03 |
30 CFR 250.107(a) |
|
Devon Louisiana Corporation G-2002-044 |
Surface-controlled subsurface safety valve for Well No. 10 was blocked out of service. 07/23/02 - 07/26/02 |
$40,000 01/23/03 |
30 CFR 250.803(c) |
|
J. M. Huber Corporation (Grasso Production Management) G-2002-045 |
Surface safety valve in Well A-6 was pinned out of service; was not flagged or being monitored. Glycol system was found bypassed; relays not flagged or monitored. Crane inspections of 4/2000 and 12/2000 show critical components need to be repaired or replaced; not done as of 6/16/2001 inspection. Subsurface controlled subsurface safety valve on Well A-6 last inspected 8/17/99; missed 3 six-month inspections. 04/11/00 – 06/16/01 |
$203,750 12/15/03 |
30 CFR 250.108 |
|
Devon Louisiana Corporation G-2002-046 |
Relays for two wells placed in the bypass mode. 10/21/01 – 10/24/01 |
$80,000 04/22/03 |
30 CFR 250.803(c) |
|
El Paso Production Oil & Gas Company G-2002-047 |
Accident occurred involving a crane on the platform due to unworkmanlike act and there was no annual inspection performed on the crane. 08/11/02 – 08/11/02 |
$50,000 07/07/03 |
30 CFR 250.107(a) |
|
GOM Shelf LLC G-2002-048 |
The audible alarm for the ventilation system in the classified mud pit room was found in by-pass. 08/09/02 – 08/09/02 |
$17,500 11/25/03 |
30 CFR 250.410(e)(5) |
|
Tri-Union Development Corporation G-2002-052 |
Oil entered the Gulf of Mexico from the overboard water line from the flotation cell. The following safety devices were bypassed: level safety high on the flotation cell, pressure safety high and pressure safety low on the water skimmer, level safety low on the oil treater. Additional incidents constituted unsafe and unworkmanlike operations: uncontrolled discharge of oil onto top deck through the opened lower valve on the skimmer oil bucket sight glass; liquid contained in platform's pneumatic supply system; hazardous accumulation of oil on top deck; deck drain line from top deck leaking oil onto the LACT skid; hatch covers on flotation cell found open. 08/26/02 – 08/26/02 |
$85,000 07/31/03 |
30 CFR 250.803(c) |
|
J. M. Huber Corporation (Bottomline Operating Enterprises, Inc.) G-2002-053 |
Several well SCSSV and Plug Test not performed along with Gas Lift Lines not tested and electrical safety issues. 02/01/01 – 03/05/01 |
$159,000 12/01/03 |
30 CFR 250.804(a)(1) |
|
Devon SFS Operating, Inc. G-2003-001 |
Improperly secured crane, no annual inspection performed, and no load test performed resulting in a fatality and damage to the platform. 05/05/02 – 05/05/02 |
$45,000 10/27/03 |
30 CFR 250.108 |
|
BP America Production Company G-2003-002 |
The Operator failed to conduct crane dismantling and removal operations in a safe and workmanlike manner, resulting in the crane falling into the Gulf of Mexico. Accident occurred due to failure to follow the procedures established in the Job Safety Analysis (JSA). 11/02/02 – 11/02/02 |
$25,000 11/24/03 |
30 CFR 250.107(a) |
|
BP America Production Company G-2003-006 |
Surface-controlled subsurface safety valve for Well No. E-18 was blocked out of service. 01/03/03 – 01/03/03 |
$20,000 07/23/03 |
30 CFR 250.803(c) |
|
Union Oil Company of California G-2003-008 |
The block and bleed relays for the shut down valve on the 6' incoming high pressure pipeline were found tie-wrapped out of service. 02/02/03 – 02/03/03 |
$40,000 08/06/03 |
30 CFR 250.1004 |
|
Nuevo Energy Company P-2002-002 |
On 7/7/02, 9 barrels of crude leaked from Platform Edith to Elly 6' pipeline riser at Platform Elly into the ocean. 01/01/02 – 07/07/02 |
$80,000 03/24/03 |
30 CFR 250.200 |
|
Total Penalties Paid:01/01/2003 - 12/31/2003 36 Cases:($2,742,700) |
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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.