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2005 Civil Penalties

2005 Civil Penalties


2005 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.

2005 Civil Penalties Summary
 All Penalties Paid in Calendar 2005
(01/01/2005 - 12/31/2005)

Operator Name
and Case No.

Violation and Date(s)

Penalty Paid and
Date Paid

Regulation(s) Violated
(30 CFR)

W & T Offshore, Inc.


A burning operation was conducted without the issuance of a written authorization for the work and the site was not being monitored with a portable gas detector.

12/07/96 – 12/07/96
12/07/96 – 12/07/96



30 CFR 250.52(b)
30 CFR 250.52(d)(2)

Seneca Resources Corporation


The subsurface-controlled safety valve (SSCSV – in a landing nipple) was not tested for one testing period (tested on 11/4/94 and then on 1/23/96). Also, the pipeline shut down valve from West Delta 32 C to West Delta 32 A was found defective and left in service for 17 days.

05/23/96 – 05/23/96
05/23/96 – 05/23/96



30 CFR 250.124(a)(1)(ii)
30 CFR 250.154(b)(2)

Blue Dolphin Exploration Company

(Petroleum Offshore Professional Services)


Tubing plugs on 8 wells not inspected for leakage within required timeframe. Electrical installations not maintained in accordance with API RP 500 & RP 14F. Crane inspection of 6/00 indicated that emergency shut down cable and boom angle indicator needed to be replaced; crane not taken out of service.

04/02/99 – 10/03/00
10/02/99 – 10/03/00
10/04/00 – 10/04/00
06/14/00 – 10/04/00



30 CFR 250.804 (a)(1)
30 CFR 250.804 (a)(1)
30 CFR 250.114 (c)
30 CFR 250.108

Maritech Resources, Inc.

(Petroleum Offshore Professional Services)


Approval was granted to install an SSCSV in lieu of an SCSSV in satellite Well No. 1 with the condition that at the first sign of sand production the well would be shut-in immediately and the approval rescinded. Numerous occurrences of produced sand were not reported to the district and the well remained on production. The SSCSV was removed from the well and found to be damaged. It was reinstalled in the well which was not plugged or attended overnight.

02/03/03 – 02/04/03
11/05/02 – 02/04/03



30 CFR 250.804 (a)(1)(ii)
30 CFR 250.801(h)(3)

Murphy Exploration & Production Company – USA


The Pressure Safety Low (PSL) for the intermediate pressure (IP) Separator was found in bypass.

04/05/04 – 04/06/04



30 CFR 250.803

Devon Louisiana Corporation


The isolation valves for two Emergency Shut Down (ESD) Stations were found in the bypassed position, rendering the two ESD stations inoperable.

04/16/04 – 04/16/04



30 CFR 250.803 (c)(1)

Shell Offshore Inc.


The surface controlled subsurface safety valve (SCSSV) was found blocked out service by the hydraulic control line closed at the isolation valve on the tree.

06/16/04 – 06/24/04



30 CFR 250.803

Forest Oil Corporation


Level Safety High (LSH) on sump tank was found bypassed at the safety system panel. The blocked out safety device was not flagged nor being monitored by personnel. Safety Device bypassed for 1 day.

06/03/04 – 06/03/04



30 CFR 250.803 (c)

Exxon Mobil Corporation


A 4' x 8' section of top deck grating had been removed in order to facilitate a wireline unit removal operation. The area was not flagged or barricaded to warn personnel of the open area; and personnel working in the direct vicinity of the open hole were not wearing fall protection gear.

04/26/04 – 04/26/04



33 CFR 142.42

Anadarko E&P Company LP

(Island Operators Co. Inc.)


The main group device selector switches for both the high pressure separator (MBD 1050) and the intermediate pressure separator (MBD 1100) were bypassed. The end devices were not flagged, nor were they being monitored.

05/04/04 – 05/04/04
05/04/04 – 05/04/04



30 CFR 250.803
30 CFR 250.803

Forest Oil Corporation

(Ensco Offshore Co.)


An accident involving an injury occurred on 04/19/04 while the crew was changing the annular rubber. The operation was not performed in a safe manner, and an employee lowered through the rotary was injured when the Blow Out Preventer (BOP) stack shifted.

04/19/04 – 04/19/04



30 CFR 250.107(a)

Energy Partners, Ltd.


Surface Controlled Subsurface Safety Valve (SCSSV) for Well

F-3 was blocked out of service; not flagged nor being monitored. Safety Device blocked out of service for 9 days.

12/07/03 – 12/15/03



30 CFR 250.803 (c)

Forest Oil Corporation


Required safety equipment (smoke and/or thermal rate of rise detectors) for both the Company Man's Office/Bunkhouse and the Galley were inoperable.

05/29/04 – 06/01/04



30 CFR 250.803 (b)(9)

Apache Corporation

(Island Operators Co. Inc.)


Pipeline Pump pressure safety low (PSL) bypassed and a failure to report casing pressure caused by a hole in the tubing.

03/09/04 – 03/09/04
09/23/03 – 02/13/04



30 CFR 250.803
30 CFR 250.517(c)

Kerr-McGee Oil & Gas Corporation


The manual relay for the Surface Safety Valve was pinned and tie-wrapped out of service.

07/16/03 – 07/16/03



30 CFR 250.803

Stone Energy Corporation

(Rowen Drilling)


Failure to initiate prompt well control measures to control the influx of well formation fluids which entered the wellbore.

08/08/04 – 08/08/04



30 CFR 250.107

Century Exploration New Orleans, Inc.

(Island Operators Co., Inc.)


The Aqueous Film Forming Foam (AFFF) had not been replaced after failing an analysis test.

09/28/04 – 09/28/04



33 CFR 146.15

Forest Oil Corporation

(Baker Energy, Inc.)


The 150 gal Aqueous Film Forming Foam (AFFF) Fire Boss Unit was not being maintained in an operable condition since the effectiveness of the foam was not being monitored.

10/13/04 – 10/13/04



30 CFR 250.803 (b)(8)

Bois d'Arc Offshore Ltd.

(Eagle Consultants)


The Platform was producing without an operable firewater system for 2 days.

07/20/04 – 07/21/04



30 CFR 250.803 (b)(8)

Newfield Exploration Company


The Pressure Safety Valves (PSC) on Compressor Nos. 1 & 2 were isolated, rendering them inoperable; and there were no fusible loop material (TSE) over the engine for Compressor No. 1.

08/18/04 – 08/21/04
08/18/04 – 08/21/04
08/21/04 – 08/21/04



30 CFR 250.803 (c)
30 CFR 250.802 (b)
30 CFR 250.803 (c)

Apache Corporation


Open holes in cellar deck and +10 levels without appropriate barricade to prevent personnel from falling into the holes.

11/09/04 – 11/09/04



33 CFR 142.87

Pogo Producing Company


Bypassed LSL on the test separator with the upper and lower isolation valves in the closed position.

08/05/04 – 08/05/04



30 CFR 250.803

Newfield Exploration Company

(Rowan Drilling)


Personnel were observed working without fall protection gear while engaged in an activity where there was a hazard of falling 10 or more feet.

11/23/04 – 11/23/04



30 CFR 250.107

Apache Corporation

(Dolphin Service Inc.)


An employee fell 45 feet into the Gulf when he stepped through the open hole created by the removal of wooden boards which had been placed over the open hole to protect it.

12/20/04 – 12/20/04



30 CFR 250.107 (a)

The Houston Exploration Company

(Grasso Production Management)


The Gas Detector Head (ASH-10) for gas compressor 802 was found inoperable due to the sensor being disconnected from the main circuit board panel. The blocked out safety device was not flagged nor being monitored by personnel. Safety Device bypassed for 1 day.

01/03/05 – 01/03/05



30 CFR 250.803 (c)

Bois d'Arc Offshore Ltd.

(Eagle Consultants)


The Burner Safety Low (BSP) for the fuel to the Glycol Reboiler, EAW-921, and the Temperature safety High (TSH) for the media and the stack were in by-pass. The blocked out safety devices were not flagged nor being monitored by personnel. Safety Devices bypassed for 1 day.

03/02/05 – 03/02/05



30 CFR 250.803 (c)

Total Penalties Paid: 01/01/2005 12/31/2005

26 Cases: ($796,600)

The following acronyms are used in this table:


Emergency Shutdown Device


Hydrogen Sulfide


Incident of Non-Compliance


Liquid Automatic Custody Transfer


Level Safety High


Level Safety Low


Maximum Allowable Working Pressure


Notice of Non-Compliance


Pressure Safety High/Low


Pressure Safety Low


Pressure Safety Valve


Surface Controlled Subsurface Safety Valve


Shut Down Valve


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.