# HAWAII ELECTRIC LIGHT — Warning Letter

**Citation:** CPF 520095024W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2009-05-27

CLOSED warning letter citing 195.304, 195.404(a)(4).

## Document text

Warning Letter involving HAWAII ELECTRIC LIGHT. PHMSA's enforcement data identifies the cited regulations as 195.304,  195.404(a)(4). The case was opened on 2009-05-27 and is reported as closed as of 2009-05-27. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520095024W_warning letter_05272009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095024W/520095024W_warning%20letter_05272009.pdf

520095024W_warning letter_05272009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095024W/520095024W_warning%20letter_05272009_text.pdf

520095024W_warning letter_05272009_text.pdf

WARNING LETTER
CERTIFIED – RETURN RECEIPT REQUESTED
May 27, 2009
Mr. Jay Ignacio
President
Hawaiian Electric Light Company
54 Halekauila Street
PO Box 1027
Hilo, Hawaii 96721-1027
CPF 5-2009-5024W
Dear Mr. Ignacio:
On March 17-22, 2009, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected
Hawaiian Electric Light Company’s (HELCO) delivery line, facilities, and records in Hilo,
Hawaii.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violations are:
1. §195.404 Maps and Records.
(a) Each operator shall maintain current maps and records of its pipeline systems
that include at least the following information;
(4) The diameter, grade, type and nominal wall thickness of all pipe.



The operator could not provide records indicating the grade of pipe that was used to replace a
portion of the pipeline that had mechanical damage and leaked causing an oil spill that occurred
on January 13, 2004.
The operator could not provide records indicating the grade of pipe used during 2003, 2004, and
2006 for installation of launchers and receiver, the new Y to facilitate smart pigging and relief
valve.
The Specific evidence upon which the probable violation is based is spool drawings on pipe and
fitting installed at Kalanianaole & Banyan Way.
2. §195.304 Test pressure.
The test pressure for each pressure test conducted under this subpart must be
maintained throughout the part of the system being tested for at least 4 continuous
hours at a pressure equal to 125 percent, or more, of the maximum operating
pressure and, in the case of a pipeline that is not visually inspected for leakage
during test, for at least an additional 4 continuous hours at a pressure equal to 110
percent, or more, of the maximum operating pressure.
The operator provided hydro-test records for the pipe and fittings installed for a new pig
launcher at Chevron Terminal. The January 14, 2004, hydro-test record of this piping indicated
that the pipe was hydro-tested for only one hour.
No hydro-test records were presented for the pipe that was used to replace a portion of the
pipeline that had mechanical damage and leaked causing an oil spill that occurred on January
13, 2004.
The Specific evidence upon which the probable violation is based includes the spool drawing on
hydro-tested pipe and the pipe testing log.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000
for each violation for each day the violation persists up to a maximum of $1,000,000 for any
related series of violations. We have reviewed the circumstances and supporting documents
involved in this case, and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to correct the items identified in this letter.
Failure to do so will result in Hawaiian Electric Light Company being subject to additional
enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 5-2009-5024W and send all responses to my attention at 222 W. 7th Ave. #200, PO Box
2



37, Anchorage, Alaska 99513. Be advised that all material you submit in response to this
enforcement action is subject to being made publicly available. If you believe that any portion
of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along
with the complete original document you must provide a second copy of the document with the
portions you believe qualify for confidential treatment redacted and an explanation of why you
believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).
Sincerely,
Dennis Hinnah
Deputy Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 B. Flanders (#123950)
3

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520095024W>
- Source ID: `phmsa-enforcement`
- SHA-256: `be2dc772ff52dd662bc1caa994b87c318a20fac4e596179297fd68c5bacad406`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-23T05:06:28.952Z
- Document slug: `phmsa-enforcement-520095024w`

### Source metadata

```json
{
  "cpf": "520095024W",
  "operator": "HAWAII ELECTRIC LIGHT",
  "region": "Western",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.304",
    "195.404(a)(4)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "520095024W_warning letter_05272009.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520095024W/520095024W_warning%20letter_05272009.pdf",
      "bytes": 175656,
      "category": "agency_document"
    },
    {
      "name": "520095024W_warning letter_05272009_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520095024W/520095024W_warning%20letter_05272009_text.pdf",
      "bytes": 15706,
      "category": "agency_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "HAWAII ELECTRIC LIGHT"
}
```
