What We Do / 2008 Civil Penalties

2008 Civil Penalties

2008 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.

2008 Civil Penalties Summary
Penalties Paid in Calendar Year 2008

(1/1/2008 - 12/31/2008)
 

Operator Name
and Case No.

Violation and Date(s)

Penalty Paid and
Date Paid

Regulation(s) Violated
30 CFR)

Pogo Producing Co.

G-2007-009

During the investigation of a ¾ mile by 16 mile oil slick on November 29, 2006 the MMS Inspector discovered that operators had bypassed basically the entire platform safety system including the ESD to keep production online.Further investigation revealed a second pollution incident on November 21, 2006 in which oil was blown out of the flare boom leaving the platform covered with oil and causing pollution.

29-Nov-2006 – 29-Nov-2006
29-Nov-2006 – 29-Nov-2006
29-Nov-2006 – 29-Nov-2006
29-Nov-2006 – 29-Nov-2006
29-Nov-2006 – 29-Nov-2006
21-Nov-2006 – 21-Nov-2006
21-Nov-2006 – 21-Nov-2006
29-Nov-2006 – 29-Nov-2006
29-Nov-2006 – 29-Nov-2006
29-Nov-2006 – 29-Nov-2006
21-Nov-2006 – 29-Nov-2006

$505,000

2/8/2008

CFR 250.803(c)
CFR 250.803(c)
CFR 250.803(c)
CFR 250.803(c)

CFR 250.803(c)
CFR 250.300(a)
CFR 250.300(a)
CFR 250.1004
CFR 250.1004
CFR 250.1004
CFR 250.107

SPN Resources, LLC

G-2007-012

MMS Inspectors found the accumulator with no air supply connected to it.The remote BOP control station was also found with no operating pressure on it. The Inspection also revealed that there was not a full opening work-string safety valve or TIW wrench located on the rig floor. Personnel were witnessed working greater than 6 feet above the Deck with no fall protection.The Inspector also found stairs to the BOP and pipe rack to be in an unsafe location which required personnel to climb over the handrails.

01-Sep-2006 – 01-Sep-2006
01-Sep-2006 – 01-Sep-2006
01-Sep-2006 – 01-Sep-2006
01-Sep-2006 – 01-Sep-2006
01-Sep-2006 – 01-Sep-2006
01-Sep-2006 – 01-Sep-2006

$100,000

1/18/08

CFR 250.107(a)
CFR 250.515(d)
CFR 250.515(d)
CFR 250.515(c)
CFR 250.515(c)
CFR 250.401

W&T Offshore, Inc.

G-2007-016

Operator failed to properly barricade the 4' X 4' opening and a 7'10' X 16' opening during workover operations.

04-Apr-2007 – 16-Apr-2007

$130,000

3/12/2008

CFR 250.107

Helis Oil & Gas Company, LLC

(Hercules Offshore Drilling)

G-2007-021

The operator failed to supply sufficient accumulator fluid capacity required to close and hold closed the 30 inch Shaffer NL annular installed on the diverter system.

06-May-2007 – 07-May-2007

$40,000

1/17/2008

CFR 250.430

W&T Offshore

G-2007-022

Firewater Pump low discharge pressure with two hoses opened and Aqueous Film Forming Foam Concentrate (AFFF) light water unit had lost the required pressure for the system.

31-MAR-2007 – 28-APR-2007

$145,000

10/2/08

 

CFR 250.803(b)(8)
Remington Oil and Gas Corp.

G-2007-025

Failure to properly secure grating led to an accident with injury.

26-Apr-2007 – 27-Apr-2007

 $45,000

1/09/2008

CFR 250.107

Exxon Mobile Corp.

G-2007-027

Well bypassed at the panel
 

12-Apr-2007 – 17 Apr-2007

$30,000

2/29/08

CFR 250.803

Pogo Producing Co.

G-2007-029

There was an excessive  number of safety devices bypassed while bringing the platform online.With only one person watching the computer it was impossible to safely monitor all of the bypassed devices. During these start-up operations Operators overflowed the float cell pouring a hydrocarbon/water mixture onto the Deck. Once the platform was shut in the operators received an alarm on the PSH for the fuel gas scrubber and there was no action taken in response to the alarm. The AFFF unit which was protecting the wet/dry oil tanks was found to be empty.

03-Apr-2007 – 03-Apr-2007
03-Apr-2007 – 03-Apr-2007
29-Mar-2007 – 08-May-2007

$80,000

2/08/2008

CFR 250.107(a)
CFR 250.803(c)
CFR 250.107

Exxon Mobil Corp.

G-2007-030

The actuator for the compressor suction shut down valve (SDV) had been removed.

13-May-2007 – 21-May-2007

$35,000

1/14/2008

CFR 250.803

Pogo Producing Co.

G-2007-031

The Inspectors noticed that the block valve for the pressure safety valve (PSV) located on the test Separator had been left in the closed position. The Inspectors witnessed personnel working with no fall protection at a height greater than 6 feet above the Deck. The Inspectors found that the AFFF unit which was protecting the wet/dry oil tanks contained an empty bottle; and additionally, that the valve handles had been removed from the fire monitors, which were the secondary form of protection for the wet/dry oil tanks.

It was also discovered that the operator had 'failed to correct' the location of the LSH for the sump.

29-Mar-2007 – 30-Mar-2007
30-Mar-2007 – 30-Mar-2007
30-Mar-2007 – 30-Mar-2007

30-Mar-2007 – 30-Mar-2007
30-Mar-2007 – 30-Mar-2007

$150,250

2/08/2008

CFR 250.803(c)
CFR 250.107(a)
CFR 250.107
CFR 250.107
CFR 250.107

Pogo Producing Co.

G-2007-033

TSE on the rental generator was found with the block valve closed on the supply line, rendering the TSE inoperable.

17-May-2007 – 17-May-2007

$25,000

2/11/2008

CFR 250.803

Pogo Producing Co.

G-2007-034

Gas-lift line was open ended with 1000 psi on the down stream side of the check valve and the gas-lift header was found with 700 psi on it and all flanges associated with the header had missing bolts.

17-May-2007 – 17-May-2007
17-May-2007 – 17-May-2007

$40,000

2/11/2008

CFR 250.107
CFR 250.107

Forest Oil Corp.

G-2007-035

During welding/cutting operations to remove a cantilever Deck a fire/explosion occurred when hot slag fell between 10 and 15 feet into an open ended connection on top of the out of service oil storage tank.

26-Jun-2007 – 26-Jun-2007

$35,000

3/31/08

CFR 250.401

Palm Energy Offshore, LLC

G-2007-037

The top block valve on the LSH fluid chamber was found closed.

10-Jul-2007 – 10-Jul-2007

$15,000

2/11/2008

CFR 250.803

Energy XXI GOM, LLC

G-2007-039

There was a closed block valve upstream of the PSV on the First Stage Suction Scrubber which rendered the PSV inoperable.Also, the SCSSV was found with pressure trapped on the control line which locked open the SCSSV.

11-Jul-2007 – 11-Jul-2007
11-Jul-2007 – 11-Jul-2007

$15,000

1/17/2008

CFR 250.803(c)
CFR 250.803(c)

Energy Resource Technology, Inc.

G-2007-041

A pollution event of less than 200 bbls, seventeen safety devices not tested prior to initiating production, Leaking gas from 2' line, and four safety devices bypassed.

14-May-2007 – 17 May 2007
15-May-2007 – 17 May 2007
17-May-2007 – 17 May 2007

$135,000

9/26/08

CFR 250.101
CFR 250.107
CFR 250.300(a)

Apache Corp.

(Island Operators, Inc.)

G-2007-043

A flash fire, that resulted in an injury, occurred since a flowline had not been properly isolated or blind flanged from the process header. The welder was injured when his torch came in contact with hydrocarbons that were released through the open ended flowline.

05-Sep-2007 – 07-Sep-2007

$85,000

4/29/08

CFR 250.803(c)

W&T Offshore, Inc.

G-2007-044

Lead sump pump inoperable
 

21-Jun-2007 – 21-Jun-2007

$35,000

4/11/08

CFR 250.300(b)

Nexen Petroleum U.S.A., Inc.

G-2008-001

The pneumatic fire detection system installed over the gas generator was found inoperable since the temperature safety element (TSE) was not connected to the supply line.

02-Nov-2007 – 02-Nov-2007

$15,000

5/9/08

CFR 250.803(c)

Linder Oil Company, A Partnership

G-2008-003

MMS Inspectors found the SSV and Wing SDV on Well #4 bypassed with fusible caps.There was also a 1 inch open ended line on the fuel gas header where a PSV had been removed.

03-Dec-2007 - 07-Dec-2007
03-Dec-2007 - 10-Dec-2007

$180,000

8/7/08

CFR 250.803(c)
CFR 250.803(c)

Forest Oil Corporation

G-2008-004

The SCSSV for the B-1 well was bypassed at the panel for a total of 6 days.

 01-DEC-2007 – 06-DEC-2007

$60,000

 12/30/08

 

CFR 250.803(c)(1)
Dauphin Island Gathering Partners

G-2008-005

The handrails on the north end of the well bay had not been maintained in a safe condition.The handrails were corroded and deteriorated to a point that they were no longer a suitable guard and they could not adequately hold a persons weight.

08-Nov-2007 – 08-Nov-2007

$25,000

8/5/08

CFR 250.107

Apache Corporation

G-2008-006

Repairs were made to the damaged crane boom that were not in accordance with API RP 2D, Section 4.3.3(e) and the crane was placed back in service without conducting a load test.

14-Jan-2008 – 15-Jan-2008

$50,000

7/25/08

CFR 250.108

Dominion Exploration & Production, Inc.

G-2008-008

The Pressure Safety Valve (PSV) for the Glycol Contactor was bypassed with a closed manual block valve.

28-Nov-2006 – 28-Nov-2006

$5,000

8/29/08

CFR 250.803(c)

Marathon Oil Co.

G-2008-009

The MMS Inspector found that the Surface Controlled Subsurface Safety Valve (SCSSV) and the verticle run Surface Safety Valve (SSV) had been rendered inoperable.The SCSSV was blocked at the supply line; and the SSV was locked in the open position with a nonfusible cap.

18-Dec-2007 – 18-Dec-2007

$30,000

7/14/08

CFR 250.803(c)

McMoRan Oil &Gas LLC

G-2008-011

The cantilever Deck was not properly guard railed or barricaded.

14-Apr-2008 – 14-Apr-2008

$15,000

9/25/08

CFR 250.107

Medco Energi US LLC

G-2008-012

Unsafe situations were discovered by the MMS Inspector on four Caissons.

Equipment had not been maintained in a safe manner and precautions had not been

made to provide for the safety of personnel.

06-MAY-2008 – 06-MAY-2008     06-MAY-2008 – 06-MAY-2008     06-MAY-2008 – 06-MAY-2008     06-MAY-2008 – 06-MAY-2008     06-MAY-2008 – 06-MAY-2008     06-MAY-2008 – 06-MAY-2008     29-APR-2008 – 29-APR-2008

$75,000

 

11/21/08

 

CFR 250.107(a)(2)
CFR 250.107(a)(2)
CFR 250.107(a)(2)
CFR 250.107(a)(2)
CFR 250.107(b) 
CFR 250.107(b)
 
CFR 250.107(b)

SPN Resources, LLC

G-2008-017

A section of grating on the boat landing was severely corroded and damaged,creating a large opening that was unsafe for personnel. There was no barricade or guard to restrict the area and alert personnel of the hazard 

10-JUL-2008 – 10-JUL-2008

$15,000

 

12/30/08

 

CFR 250.107
Plains Exploration & Production Company

P-2006-002

A flash fire involving a flare scrubber vessel resulted in minor burns to an employee.Work involving a glycol skid did not follow operator's safety manual.

18-Jul-2006 – 18-Jul-2006
18-Jul-2006 – 18-Jul-2006

$40,000

4/8/08

CFR 250.803(b)(1)
CFR 250.803(b)(1)

DCOR  LLC

P-2006-003

Five INCs were issued following a 7/27/06 incident that resulted in significant damage to the unit crane during an operation to remove stuck progressive cavity pump rods.

27-Jul-2006 – 27-Jul-2006
27-Jul-2006 – 27-Jul-2006
27-Jul-2006 – 27-Jul-2006
27-Jul-2006 – 27-Jul-2006
27-Jul-2006 – 27-Jul-2006

$35,000

1/30/2008

CFR 250.107(a)CFR 250.108
CFR 250.108
CFR 250.108
CFR 250.606

Arguello Inc.

P-2006-004

During rerouting of gas flow (in connection with drilling rig demobilization and work on the condensate stabilizer vessel) a valve was erroneously opened resulting in H2S exposure.

12-Aug-2006 – 12-Aug-2006

$20,000

4/8/08

CFR 250.107(a)

Total Penalties Paid: 1/1/08 - 12/31/08

31 Cases: $2,210,250

The following acronyms are used in this table:

AFFF Aqueous Film Forming Foam
ESD Emergency Shutdown Device
INC Incident of Non-Compliance
LSH Level Safety High
BOP Blow out Preventer
MBD Thousands of Barrels per day
PSH Pressure Safety High
SDV Shut down valve
PSV Pressure Safety valve
SCSSV Subsurface Safety valve
TSE Temperature Safety Element
SSV Surface Safety 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.