U.S. 
Deparlment 
400 Seventh Street, S.W. of Transportation Washington, D.C.20590 
Pipeline and Hazardous 
Materials Safety Administration 
Robert P. Carone 
President 
Pacific Operators Offshore, LLC 
6307 Carpinteria Ave 
Carpinteria, CA 93013-3013 
Re: CPF No. 5-2004-2002 
Dear Mr. Carone: 
Enclosed is the Final Order issued by the Acting Associate Administrator for Pipeline Safety 
in the above-referenced case. It makes findings of violation and assesses a civil penalty of 
$1 0,000. The Order also finds that you have addressed the inadequacies in your procedures that 
were cited in the Notice of Amendment. When the civil penalty is paid, this enforcement action 
will be closed. The penalty payment terms are set forth in,the Final Order. Your receipt of the 
Final Order constitutes service under 49 C.F.R. 9 190.5. 
Sincerely, 
u 
James Reynolds 
Pipeline Compliance Registry 
PHMSA-Office of Pipeline Safety 
Enclosure 
cc: 
Mr. Chris Hoidal, P.E., Director Western Region, PHMSA 
Mr. Clement M. Alberts, Pacific Operators Offshore LLC, Environmental Coordinator 
CERTIFIED MAIL -RETURN RECEIPT REQUESTED 

DEPARTMENT OF TRANSPORTATION 
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 
OFFICE OF PIPELINE SAFETY 
WASHINGTON, DC 20590 
1 
In the Matter of ) 
Pacific Operators Offshore, LLC, 
)
1 CPF NO. 5-2004-2002 
Respondent 
)
1 
FINAL ORDER 
Between August 13 and August 14,2002, pursuant to 49 U.S.C. 5 601 17, representatives of the 
Pipeline and Hazardous Materials Safety Administration's (PHMSA'S)' Office of Pipeline Safety 
conducted an on-site pipeline safety inspection of Respondent's pipeline facilities, manuals, and 
records in La Conchita, California. As a result of the inspection, the Director, Western Region, 
PHMSA, issued to Respondent, by letter dated March 12,2004, a Notice of Probable Violation, 
Proposed Civil Penalty, and Notice of Amendment (N~tice).~ 
In accordance with 49 C.F.R. 
5 190.207, the Notice proposed finding that Respondent committed violations of 49 C.F.R. Parts 
191 and 192 and proposed assessing a civil penalty of $22,500 for the alleged violations. The 
Notice also proposed, in accordance with 49 C.F.R. 5 190.237, that Respondent amend its 
procedures for Operations, Maintenance, and Emergencies. 
After requesting and receiving an extension of time to respond, Respondent responded to the 
Notice by letter dated June 1 1,2004 that was later supplemented per PHMSA's request for 
further information (Response). Respondent did contest two of the allegations and offered 
information for review for many of the allegations and citations of inadequacy. In the June 1 1, 
2004 Response, Respondent did not request a hearing, and therefore has waived its right to one. 
1 Effective February 20, 2005, the Pipeline and Hazardous Materials Safety Administration (PHMSA) succeeded 
Research and Special Programs Administration as the agency responsible for regulating safety in pipeline 
transportation and hazardous materials transportation. See, section 108 of the Norman Y. Mineta Research and 
Special Programs Improvement Act (Public Law 108-426, 118 Stat. 2423-2429 (November 30,2004)). See also, 70 
Fed. Reg. 8299 (February 18,2005) redelegating the pipeline safety authorities and functions to the PHMSA 
Administrator. 
On March 22,2004, Respondent was notified that the Notice's CPF Number changed from CPF No. 5-2004-7002 
to CPF 5-2004-2002. 

FINDINGS OF VIOLATION 
(Uncontested) 
In its Response, Respondent did not contest many of the alleged violations in the Notice. 
Accordingly, I find that Respondent violated the following sections of 49 C.F.R. Parts 191 and 
192, as more fully described in the Notice: 
Item 1 - 49 C.F.R. 5 19 1.17 - failing to submit annual report for three years; 
Item 4 - 49 C.F.R. 5 192.477 -failing to inspect for internal corrosion within prescribed 
intervals; 
Item 5 - 49 C.F.R. 5 192.48 1 -failing to inspect for atmospheric corrosion within 
prescribed intervals; 
Item 6 - 49 C.F.R. 5 192.605(a)- failing to review and update O&M manuals for five 
years; 
Item 10 - 49 C.F.R. 5 192.61 5(c) -failing to substantiate that it maintained liaison 
activities with public officials; and 
Item 11 - 49 C.F.R. 5 192.705(b)-failing to conduct right-of-way inspections two times 
per year for three years. 
(Contested) 
Item 2 in the Notice alleged Respondent violated 49 C.F.R. 5 192.465(b) for failing to inspect 
rectifiers within the prescribed intervals, as more fully described in the Notice. In its Response, 
Respondent requested that this allegation be withdrawn and indicates that it provided 
documentation. However, with respect to Notice Item 2, the documentation did not provide any 
information regarding the inspection dates in question (November 26, 1999 to March 10,2000). 
Accordingly, I find that Respondent violated 49 C.F.R. 5 192.465(b) by failing to inspect 
rectifiers within the prescribed intervals. 
Item 3 in the Notice alleged Respondent violated 49 C.F.R. 5 192.467(c) for failing to act on a 
suspected pipeline casing electrical short, as more fully described in the Notice. In its Response, 
Respondent states that the charge significantly overstated the facts. Here, supporting evidence 
that would indicate such was not provided. In its Response, Respondent indicates that since the 
receipt of the Notice, it has fully repaired the problem. In this case, the repair was made after the 
inspection. Accordingly, I find that Respondent violated 49 C.F.R. 5 192.467(c) by failing to act 
on a suspected pipeline casing electrical short. 
These findings of violation will be considered prior offenses in any subsequent enforcement 
action taken against Respondent. 

ASSESSMENT OF PENALTY 
Under 49 U.S.C. 5 60122, Respondent is subject to a civil penalty not to exceed $25,000 per 
violation for each day of the violation up to a maximum of $500,000 for any related series of 
violation^.^ 
49 U.S.C. Ħħ 60122 and 49 C.F.R. Ħħ 190.225 require that, in determining the amount of the civil 
penalty, I consider the following criteria: nature, circumstances, and gravity of the violation, 
degree of Respondent's culpability,.history of Respondent's prior offenses, Respondent's ability 
to pay the penalty, good faith by Respondent in attempting to achieve compliance, the effect on 
Respondent's ability to continue in business, and such other matters as justice may require. The 
Notice proposed a total civil penalty of $22,500 for the violations. 
Item 1 of the Notice proposed a civil penalty of $6,000 for violation of 49 C.F.R. 9 191.17(a) in 
that, at the time of inspection, Respondent failed to file FORM RSPA 7 100.2-1 for years 2000, 
2001, and 2002. Respondent conceded this allegation and indicates it is submitting the subject 
report for all years per the Notice. Respondent requests that the information submitted in its 
response be taken into consideration in determining the amount of civil penalty. In accordance 
with 49 C.F.R. Ħħ 19 1.17(a), an operator of a transmission or a gathering pipeline system shall 
submit an annual report for that system on Department of Transportation Form RSPA 71 00.2-1. 
This report must be submitted each year, not later than March 15, for the preceding calendar 
year. 
Item 2 of the Notice proposed a civil penalty of $1,000 for violation of 49 C.F.R. 5 192.465(b) in 
that, at the time of inspection, Respondent's rectifier records indicated that the rectifier on 
platform Hogan was not read within 2.5 months as required by the regulation. Respondent 
requests that this allegation be withdrawn. However, the documentation provided by Respondent 
did not provide any information regarding the inspection dates in question. 
Item 3 of the Notice proposed a civil penalty of $2,000 for violation of 49 C.F.R. Ħħ 192.467(c), 
as more fully described in the Notice, in that Respondent failed to act on a suspected pipeline 
casing electrical short. In its Response, Respondent stated that it has since fully repaired the 
problem and does not anticipate a recurrence of this particular issue and requested that the 
proposed penalty for this allegation be significantly mitigated or withdrawn. 
Item 4 of the Notice proposed a civil penalty of $3,000 for violation of 49 C.F.R. Ħħ 192.477 in 
that Respondent failed to inspect for internal corrosion within prescribed intervals, as more l l l y 
described in the Notice. The regulation requires that if corrosive gas is being transported, 
coupons or other suitable means must be used to determine the effectiveness of the steps taken to 
minimize internal corrosion. Each coupon or other means of monitoring internal corrosion must 
be checked two times each calendar year, but with intervals not exceeding 7 % months. Here, 
the gas transported from Platform Hogan to La Conchita Plant contains water. Respondent was 
using coupons to monitor the internal corrosion of its pipeline. A coupon was installed on 
The Pipeline Safety Improvement Act of 2002, Pub.L.No. 107-355, 5 8(b)(l), 116 Stat. 2992, increased the civil 
penalty liability for violating a pipeline safety standard to $100,000 per violation for each day of the violation up to 
a maximum of $1,000,000 for any related series of violations. 

January 27,2000 and removed for inspection on October 24,2000; the maximum interval of 7 ?4 
months was exceed by 43 days. And again, a coupon was installed on October 24,2000 and 
removed for inspection on July 13,2001; the maximum interval of 7 ?4months was exceeded by 
33 days. During the inspection, no evidence of internal corrosion was observed. In its Response, 
Respondent indicates that it has adjusted its internal inspection procedures and does not 
anticipate a recurrence of this particular issue. Respondent requested reconsideration of the 
amount of penalty proposed for this violation. 
Item 5 of the Notice proposed a civil penalty of $3,000 for violation of 49 C.F.R. $192.481, as 
more fully described in the Notice, in that Respondent failed to inspect for atmospheric corrosion 
within prescribed intervals. In accordance with the regulation, operators shall, at intervals not 
exceeding three years for onshore pipeline and at least once each calendar year, but with 
intervals not exceeding 15 months, for offshore pipelines, reevaluate each pipeline that is 
exposed to the atmosphere and take remedial action whenever necessary to maintain protection 
against atmospheric corrosion. Here, Respondent has pipelines that are exposed to the 
atmosphere aboard Platform Hogan and at its La Conchita Gas Plant. At the time of inspection, 
Respondent did not provide documentation that it performed three atmospheric corrosion 
inspections on the exposed portion of its pipeline at Platform Hogan and one inspection at La 
Conchita Gas Plant for the period of April 1999 to August 2002. During this inspection, 
atmospheric corrosion was not observed. In its Response, Respondent indicated that it has 
adjusted its internal inspection documentation procedures and does not anticipate a recurrence of 
this particular issue. Respondent requested reconsideration of the amount of penalty proposed 
for this violation. 
Item 6 of the Notice proposed a civil penalty of $5,000 for violation of 49 C.F.R. Ħħ192.605(a) in 
that Respondent failed to review and update O&M manuals for five years. In its Response, 
Respondent states that it has performed the required review and adjusted its internal procedures 
so that it does not anticipate a recurrence of this particular issue. 
Item 10 of the Notice proposed a civil penalty of $1,000 for violation of 49 C.F.R. 5 192.61 5(c) 
in that Respondent failed to substantiate that it maintained liaison activities with public officials. 
Respondent stated that it has adjusted its internal documentation procedures and does not 
anticipate a recurrence of this particular issue. 
Item 11 of the Notice proposed a civil penalty of $1,500 for violation of 49 C.F.R. 5 192.705(b) 
in that Respondent failed to conduct right-of-way inspections two times per year for three years. 
Respondent states that it has adjusted its internal procedures so that it does not anticipate a 
recurrence of this particular issue. 
In the Notice, a total civil penalty of $22,500 was proposed for the alleged violations with 
respect to the pipeline, which is located in a class 1 area and passes through navigable waters. 
Respondent submitted information and responses for Western Region staff to review. Staff 
evaluating information at hand, informs me that the facilities are only marginally viable from an 
economic standpoint. Furthermore, the Regional Director recommends reduction of the civil 
penalty due to reflect the cooperation and perceived intent shown by Respondent. 

Accordingly, having reviewed the record and considered the assessment criteria, I assess 
Respondent a total civil penalty of $10,000 as follows: 
Notice Item # Original CP Revised CP 
Total $22,500.00 $10,000.00 
Payment of the civil penalty must be made within 20 days of service. Payment may be 
made by sending a certified check or money order (containing the CPF Number for this 
case) payable to "U.S. Department of Transportation" to the Federal Aviation 
Administration, Mike Monroney Aeronautical Center, Financial Operations Division 
(AMZ-300), P.O. Box 25082, Oklahoma City, OK 73 125. 
Federal regulations (49 C.F.R. 8 89.21(b)(3)) also permit this payment to be made by wire 
transfer through the Federal Reserve Communications System (Fedwire), to the account 
of the U.S. Treasury. Detailed instructions are contained in the enclosure. Questions 
concerning wire transfers should be directed to: Financial Operations Division (AMZ- 
300), Federal Aviation Administration, Mike Monroney Aeronautical Center, P.O. Box 
25082, Oklahoma City, OK 73 125; (405) 954-8893. 
AMENDMENT OF PROCEDURES 
Notice Items 7(a-0, 8, and 9 alleged inadequacies in Respondent's procedures/plans and 
proposed to require amendment of Respondent's procedures to comply with the requirements of 
49 C.F.R. 8 192.605(a)(b)(2) (Notice Item 7), 49 C.F.R. 4 192.614 (a) and (c)(6)(ii) (Notice Item 
8), 49 C.F.R. 8 192.615(a)(3)(iv) (Notice Item 9), as fully described in the Notice. 
In a subsequent site visit, PHMSA reviewed Respondent's plans/procedures for completeness 
and it appeared that Respondent had satisfied Notice Items 7(a-0, 8, and 9. Accordingly, based 
on the results of this review, I find that Respondent's original procedures as described in the 
Notice were inadequate to ensure safe operation of its pipeline system, but that Respondent has 
corrected the identified inadequacies. No need exists to issue an Order Directing Amendment. 

WARNING ITEMS 
The Notice did not propose a civil penalty or corrective action for Notice Item 12 for Respondent 
failing to have a line marker on its pipeline south of Highway 101 in compliance with 49 C.F.R. 
tj 192.707(a)(l-2) and Notice Item 13 for Respondent failing to produce records to evidence 
repair in compliance with 49 C.F.R. 5 192.709(a) but warned Respondent that it should take 
appropriate corrective action to correct the items. In its Response, Respondent stated that it has 
taken action towards addressing the cited items. Respondent is again warned that if PHMSA 
finds a violation for any of these items in a subsequent inspection, enforcement action will be 
taken. 
Under 49 C.F.R. tj 190.2 15, Respondent has a right to submit a Petition for Reconsideration of 
this Final Order. The petition must be received within 20 days of Respondent's receipt of this 
Final Order and must contain a brief statement of the issue(s). The filing of the petition 
automatically stays the payment of any civil penalty assessed. However, if Respondent submits 
payment for the civil penalty, the Final Order becomes the final administrative decision and the 
right to petition for reconsideration is waived. The terms and conditions of this Final Order are 
effective on receipt. 
&- Date Issued 
A&& Associate Administrator 
for Pipeline Safety