What We Do / 2006 Civil Penalties

2006 Civil Penalties

2006 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.

2006 Civil Penalties Summary
 All Penalties Paid in Calendar Year 2006
 
(01/01/2006 - 12/31/2006)

Operator Name
and Case No.

Violation and Date(s)

Penalty
Paid and

Date Paid

Regulation(s) Violated
(30 CFR)

The Houston Exploration Company

(Grasso Production Management)

G-2003-004

Failed to conduct one annual crane inspection.

 

 

01-Jul-2002-30-Sep-2002

$10,000

08/25/06

250.108

PetroQuest Energy, L.L.C.

(Wood Group Production Services)

G-2004 - 026

Missing grating & handrails, corroded unsafe steps, and severe corrosion around the fuel scrubber created an unsafe situation for personnel. Also, the flowline and departing pipeline did not have secondary over-pressure protection.

29-Jun-2004 - 29-Jun-2004
29-Jun-2004 - 29-Jun-2004

$60,000

1/3/06

250.802(b)
250.107

El Paso Production Oil and Gas Company

G-2005 - 007

Explosion and fire occurred on platform from welding and cutting operations near hydrocarbons.

23-Dec-2004 - 23-Dec-2004

$25,000

2/7/06

250.107

Exxon Mobil Corporation

G-2005 - 012

The Pressure Safety Low (PSL) for Well G-24 , had the incorrect spring and piston installed; the spring tension was backed off to a point where it would not  function. This violation occurred for 11days.

29-Dec-2004 - 29-Dec-2004

$25,000

06/8/06

250.803 (b)(2)(i)

Apache Corporation

(Wood Group Production Services)

G-2005 - 014

During an annual inspection, the inspector discovered that the Emergency Shut Down (ESD) stations for both the North and South boat landings were out-of-service.

15-Oct-2004 -18-Oct-2004

$28,000

3/10/06

250.803

Noble Energy, Inc.

(Hercules Offshore Drilling)

G-2005 - 015

The gas detector panel that monitors the mud pit room and shale shaker area was found to be in bypass during a monthly rig inspection. The operator forgot to put it back in service after calibrating the sensors. When the panel was taken out of bypass and tested, the audible alarm failed to activate.

23-Feb-2005 - 02-Mar-2005

$160,000

2/15/06

 250.459(b)

Energy Partners Ltd.

G2005 - 016

The level safety high (LSH) shut-in sensor for the Deck drain sump tank was bypassed at the main panel. Neither the LSH nor the operating condition of the sump tank were being monitored by platform personnel.

02-Mar-2005 - 02-Mar-2005

$8,000

1/10/06

 250.803(c)

El Paso Production Oil and Gas Company

(Baker Energy, Inc.)

G-2005 - 020

Shut down valve connected in such a way that it would not operate as designed; pressure would not bleed off if an upset had occurred.

10-Mar-2005 -10-Mar-2005

$10,000

08/07/06

250.802(b)

Apache Corporation

(Wood Group Production Services)

G-2005 - 021

Grating missing on the plus 10 Deck level in two areas and area not barricaded to prevent personnel from entering.

10-Apr-2005 - 20-Apr-2005

$66,000

2/9/06

250.107

Apache Corporation

(Wood Group Production Services

G-2005 - 022

During a production follow-up inspection on February 20, 2005, wells A002 and A003 Surface Safety Valve (SSV's) were pinned out of service in the open position, and the wells were not flagged or monitored.

20-Feb-2005 - 20-Feb-2005

$24,000

3/13/06

250.803(c)

ATP Oil & Gas Corporation

(Wood Group Production Services)

G-2005 - 023

The vertical run Surface Safety Valve (SSV) for Well C-2 was bypassed and locked out of service with a locking cap.
 

05-May-2005 -19-May-2005

$21,000

6/22/06

30 CFR 250.803 (c)

Millennium Offshore Group, Inc.

(TODCO)

G-2005 - 024

Unsafe and unworkmanlike operations were conducted in that the policies and procedures for Confined Space Entry were not being adhered to as per Operator's Health, Safety and Environment manual.

30-Mar-2005 - 30-Mar-2005

$10,000

07/27/06

250.107

Noble Energy

G-2005 - 025

During an inspection on May 2, 2005 the top and bottom isolation valves on the Level Safety Low (LSL) for the Bad Oil Tank (ABJ-5020) were found blocked out of service and not flagged or being  monitored.

1-May-2005 - 02-May-2005

$8,000

3/24/06

250.803(c)

Apache Corporation

G-2005 - 026

Apache failed to comply with the safe and workmanlike manner and well control requirements addressed in the regulations. A remote blowout preventer (BOP) station on the rig floor would not operate nor function the bottom pipe ram and the hydraulic (HCR) choke valve. An accumulation of hydraulic oil on derrick beams and board rack, oily and slippery hand rail, and no grating over mud pits demonstrated Apache's failure to maintain all equipment in a safe condition.

7/25/2005 - 7/25/2005
7/25/2005 - 7/25/2005

$28,000

05/11/06

250.107
250.615 (c)

Pioneer Natural Resources USA, Inc.

G-2005 - 027

Operations were not performed in a safe manner as Personnel attempted to replace a 2' ball valve on the water dump bypass line on the Chem-Electric Treater without draining the vessel. This created an uncontrolled oil release from the vessel over the structure's open grating, and into the containment skid which was damaged and unable to contain the oil. As a result, approximately 1 barrel of oil polluted the Gulf.

6/10/2005 - 6/10/2005
6/10/2005 - 6/10/2005
6/10/2005 - 6/10/2005

$45,000

5/10/06

250.300 (b)
250.300 (a)
250.107 (a)

SPN Resources, LLC

G-2005 - 028

The sump system could not automatically maintain the oil at a level sufficient to prevent discharge of oil into offshore waters.

05/06/2005 - 05/06/2005

$10,000

6/13/06

250.300 (b)

ATP Oil & Gas Corporation

G-2006 - 001

The Level Safety Low (LSL) on the water section of the Heater Treater was bypassed and blocked out of service. Startup, maintenance or testing procedures were not being performed; personnel were not monitoring the bypassed and blocked out functions; and the LSL was not flagged.

10/31/2005 - 10/31/2005

$5,000

06/27/06

250.803 (c)

Petroquest Energy, L.L.C

(Grasso Production Management)

G-2006 - 002

The Gas Detector Head (ASH) in the operator's tool room was found covered with plastic wrap which rendered it inoperable. Paint fumes were activating the ASH and plastic bags were placed over it to prevent nuisance shut-ins and to keep the fumes from contaminating the sensor.

6/19/2005 - 06/20/2005

$20,000

06/08/06

250.803 (c)

Apache Corporation

G-2006 - 003

An employee was injured since work had been performed in an unsafe and un-workmanlike manner. On 10-3-05, in order to access a well slot, 33' openings were cut in the grating on the well Deck and on the lower production Deck. The two holes cut in the Decking were never barricaded, covered, guarded, or made inaccessible until 10-5-05, after the employee fell 8' through the unguarded hole cut in the well Deck and into the opening cut on the lower production Deck. He was able to catch himself before falling completely through the second opening into the cross members and well slot guide 40' below.

10/03/2005 - 10/05/2005

$70,000

05/16/06

250.107

Noble Energy, Inc.

G-2006 - 004

While in route to another destination, the Minerals Management Service (MMS) Inspectors noticed a multi-colored sheen on the water coming from the ST 196 Platform B. They landed on the platform and found oil flowing out of the vent hatch on the Sump Tank ABH-4760. The MMS Inspectors also found the Sump System did not automatically maintain the oil level sufficiently enough to prevent discharge of oil into offshore waters.

18-Oct-2005 - 18-Oct-2005
18-Oct-2005 - 18-Oct-2005

$50,000

07/13/06

250.300(a)
250.300(b)

Kerr-McGee Oil & Gas Corporation

G-2006 - 005

Three safety devices were found bypassed at the panel. The level safety low for the wet/dry oil tank, the shut down valve for the dry oil pump, and the shut  down valve for the incoming pipeline. Proposed amount mitigated from information supplied in letter.

12-Nov-2004 - 12-Nov-2004
12-Nov-2004 - 12-Nov-2004

$15,000

07/19/06

250.1004
250.803

ATP Oil & Gas Corporation

G-2006 - 006

An injury occurred as a result of unsafe and unworkmanlike operations. A contract worker fell 30ft. through a unsecured access hatch. Additionally large openings in the Deck were found and sections of heliport skirting was missing 

10/29/2004 - 11/6/2004

$110,000 

12/29/06

250.107

Union Oil Company of California

G-2006 - 007

A pollution incident occurred as a result of improperly isolating the turbine compressor from the production train.

10-Sep-2004 - 10-Sep-2004

$25,000

07/25/06

250.300(a)

Tana Exploration Company LLC

G-2006 - 008

The primary and secondary surface safety valves (SSV), in addition to the fuel gas were bypassed on Caisson Well No. 28. The relays were placed in bypass by BP Exploration and Production employees (acting as contractors for Tana) on February 14, 2005. When an upset occurred on February 19, 2005, on the upstream processing platform, the Well No. 28 did not shut in due to these safety devices being bypassed. The pipeline experienced overpressure and the flange gasket ruptured allowing gas/condensate to escape. The Well was shut in using the boat landing emergency shut down pull loop.

14-Feb-2005 - 19-Feb-2005
14-Feb-2005 - 19-Feb-2005

$165,000

08/31/06

250.803(c)
250.803(c)

Energy Partners, Ltd

G-2006 - 009

The pressure safety low (PSL) on the departing high-pressure transfer gas pipeline (KAH-103) was by-passed at the master panel, leaving the pipeline unprotected from a leak or rupture. The relay was not flagged and conditions were not being monitored.

07/06/2005 - 07/07/2005

$10,000

06/22/06

250.1004

Arena Offshore, LLC

(Island Operators Co., Inc)

G-2006 - 010

Pollution occurred in offshore waters from overflow of vessel to Deck  caused from a pipeline being tested which was using FSVs instead of block valves. This overflow went to the Deck containment system and the Deck drain sump system tank was inoperable.

26-Aug-2005 - 26-Aug-2005
26-Aug-2005 - 26-Aug-2005

$27,000

08/25/06

250.300(b)
250.300(a)

Callon Petroleum Operating Company

G-2006 - 011

The fuel gas supply for the sump pump was manually closed, placing the sump pump in an out of service mode. Neither the sump pump nor the sump tank were being monitored by platform personnel.

12/12/2005 - 12/12/2005

$5,000

05/11/06

250.300 (b)

Forest Oil Corporation

(Production Management Industries, LLC)

G-2006 - 012

Operations were not performed in a safe and workmanlike manner, and equipment had not been maintained in a safe condition. Pollution occurred since a fuel tank was filled beyond capacity and the sump system had not been properly maintained.

17-Jun-2005 - 17-Jun-2005
17-Jun-2005 - 17-Jun-2005
17-Jun-2005 - 17-Jun-2005

$45,000

09/06/06

250.107
250.107
250.300(a)

Palace Operating Company

(Island Operators Co.)

G-2006 - 013

During an annual inspection the MMS inspector detected that the Surface Safety Valve (SSV) on well # 2 was locked open using a fusible SSV stem cap rendering the valve inoperable or by-passed. This valve would not close had an undesirable event occurred (under pressure or overpressure of the flowline).

11/28/2005 - 11/28/2005

$5,000

10/27/06

250.803(c)

Total E&P USA, Inc.

G-2006 - 014

Both Emergency Shut Down Valves were bypassed by isolation valve on two boat landings and the two PSVs on the Intermediate Production Separator were found closed thus taking them out of service (bypassed) by two isolation valves.

08/15/2005 - 08/21/2005
08/16/2005 - 08/21/2005

$130,000

06/16/06

250.803
250.803

Northstar Gulfsands, LLC

(Offshore Contract Services LLC)

G-2006 - 015

The level safety low (LSL) on the atmospheric bad oil tank was manually closed placing it in bypass
 

4-Jan-2006 - 5-Jan-2006

$15,000

09/06/06

250.803

Nippon Oil Exploration U.S.A.

G-2006 - 017

The Platform's two Primary means of escape had not been adequately maintained. Personnel on the platform had no safe means of egress due to missing grating and handrails.

9/4/2005 -1/3/2006

$30,000

9/28/06

250.107

Chevron U.S.A. Inc

G-2006 - 018

Platform's emergency equipment had not been adequately maintained. The winch and lower flange kit on the south capsule was severely corroded and unsafe for use.

8/3/2004 - 8/9/2004

$30,000

10/30/06

250.107(a)(2)

ATP Oil & Gas Corporation

G-2006 - 019

The level controller which starts the sump pump was improperly set therefore rendering the sump pump incapable of maintaining the oil in the sump tank at a safe level to prevent discharge into the gulf waters.

19-Sep-2004 - 19-Sep-2004

$12,000

09/22/06

250.300(b)

ATP Oil & Gas Corporation

(Wood Group Production Services)

G-2006 - 020

The Emergency Shut Down (ESD) Stations on the condensate accumulator Deck, sump Deck, well bay area and boat landing were all rendered out of service since the ESD supply line was disconnected.

09-Nov-2004 - 09-Nov-2004

$20,000

09/22/06

250.803(c)(1)

Marathon Oil Company

G-2006 - 022

The Temperature Sensing Element for the +10 Deck drain Sump Pump was bypassed.

9/23/2004 - 9/23/2004

$40,000

11/9/06

250.803

BP America Production Company

G-2006 - 023

Operations were not performed in a safe and workmanlike manner. While making an assessment of the unsafe conditions on the platform that needed repairing, the construction crew did not barricade a 3'4' x 3'4' opening in the stairway landing. Later, one of the crew members was injured when he fell through the open hole approximately 20' and into the Gulf of Mexico.

2/10/2006 - 2/10/2006

$25,000

10/25/06

250.107(a)(1)

GOM Shelf LLC

(Crown Oilfield Services, Inc.)

G-2006 - 026

While attempting to secure and barricade hurricane related damages on the sub-cellar Deck, a contract employee was seriously injured since the work was not performed in a safe and workmanlike manner. He was not wearing fall protection while he was in the direct vicinity of open holes in the Deck grating, and he fell approximately 25-30 feet through a 3'x 3' opening onto the +10 Deck.

2/10/2006 - 2/10/2006

$30,000

10/6/06

250.107(a)

Pioneer Natural Resources USA, Inc.

G-2006 - 034

The main safety panel was bypassed during testing. In order to test any safety device on this panel they all had to be placed in bypass. When the panel was in total bypass the supply to the indicators was removed not allowing them to trip when an abnormal condition became present, thus there was no way for personnel to monitor the bypassed devices.

7/17/2006 - 7/17/2006

$20,000

12/13/06

250.803(c)

Venoco, Inc.

P-2005 - 001

During well recompletion operations, an accident occurred which resulted in a loss of well control (blowout), and a 3 gallon oil spill. An investigation revealed removal of a lockdown pin from the well head during the alignment of the split tube hanger had circumvented the blowout preventer system.

11/19/2004 - 11/19/2004

$30,000

4/27/06

250.300(a)
250.107(a)

Nuevo Energy Company

P-2004 - 002

On February 16, 2004, a transformer on a variable speed drive (VSD) unit over-heated and caught fire. A Minerals Management Service (MMS) investigation of the incident determined the fire, which was confined to the motor control center room was due to the following causes:  The electrical overload protection on the VSD had been placed in a non-functional mode. High amperage from a downhole electric submersible pump caused transformer to overload on the VSD, which subsequently overheated. Melting metal from the transformer dripped into a pan of threading oil below the transformer. A cotton glove that was laying in the pan of threading oil ignited. The resultant fire was extinguished by platform personnel investigating the source of smoke from the motor control center.

16-Feb-2004 - 16-Feb-2004
31-Mar-2004 - 31-Mar-2004

$8,000

2/8/06

250.107

250.803(c)(1)

Total Penalties Paid: 01/01/2006 - 12/31/2006

41 Cases:($1,480,000)

The following acronyms are used in this table:

ESD Emergency Shutdown Device
H2S Hydrogen Sulfide
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.