# ISLAND ENERGY — Warning Letter

**Citation:** CPF 520170013W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2017-08-18

CLOSED warning letter citing 192.491(c), 192.743(a).

## Document text

Warning Letter involving ISLAND ENERGY. PHMSA's enforcement data identifies the cited regulations as 192.491(c),  192.743(a). The case was opened on 2017-08-18 and is reported as closed as of 2017-08-18. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520170013W_Operator Response To Notice_09082017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170013W/520170013W_Operator%20Response%20To%20Notice_09082017.pdf

520170013W_Warning Letter_08182017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170013W/520170013W_Warning%20Letter_08182017.pdf

520170013W_Warning Letter_08182017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170013W/520170013W_Warning%20Letter_08182017_text.pdf

520170013W_Warning Letter_08182017_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
August 18, 2017
Mr. Peter Guadagni
General Manager
Island Energy
440 Walnut Ave
Vallejo, CA 94592
CPF 5-2017-0013W
Dear Mr. Guadagni:
On January 24 through 27, 2017, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected
the Island Energy procedures for gas distribution system in Vallejo, California.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violations are:
1. §192.491 Corrosion control records.
(c) Each operator shall maintain a record of each test, survey, or inspection required by
this subpart in sufficient detail to demonstrate the adequacy of corrosion control measures
or that a corrosive condition does not exist. These records must be retained for at least 5
years, except that records related to §§192.465(a) and (e) and 192.475(b) must be retained
for as long as the pipeline remains in service.
Island Energy failed to document the inspection of the aboveground meter sets for atmospheric
corrosion. A review of the corrosion records revealed that Island Energy did not have a location
to record the atmospheric corrosion inspection. Island Energy conducts the inspection at least



every three years, not to exceed 39 months. This inspection is evidenced by the fact that Island
Energy manually reads each meter set at least monthly for billing purposes.
2. §192.743 Pressure limiting and regulating stations: Capacity of relief devices
(a) Pressure relief devices at pressure limiting stations and pressure regulating stations
must have sufficient capacity to protect the facilities to which they are connected. Except
as provided in §192.739(b), the capacity must be consistent with the pressure limits of
§192.201(a). This capacity must be determined at intervals not exceeding 15 months, but
at least once each calendar year, by testing the devices in place or by review and
calculations.
Island Energy failed to verify and document the capacity of the system emergency relief valve in
2015 and 2016. A review of maintenance records revealed the failure to verify the capacity of the
relief valve.
As of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil
penalty not to exceed $209,002 per violation per day the violation persists up to a maximum of
$2,090,022 for a 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 item(s) identified in
this letter. Failure to do so will result in Island Energy 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 5-2017-0013W. 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,
Kim West
Acting Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Dunphy (#148456)

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520170013W>
- Source ID: `phmsa-enforcement`
- SHA-256: `1553985ca157f23f03ee432f333dc89dad1e75567190f535465a9de5dfeb8c4b`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-23T17:55:01.233Z
- Document slug: `phmsa-enforcement-520170013w`

### Source metadata

```json
{
  "cpf": "520170013W",
  "operator": "ISLAND ENERGY",
  "region": "Western",
  "pipelineType": "GAS INTRASTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.491(c)",
    "192.743(a)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 3,
  "attachments": [
    {
      "name": "520170013W_Operator Response To Notice_09082017.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520170013W/520170013W_Operator%20Response%20To%20Notice_09082017.pdf",
      "bytes": 39231,
      "category": "party_submission"
    },
    {
      "name": "520170013W_Warning Letter_08182017.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520170013W/520170013W_Warning%20Letter_08182017.pdf",
      "bytes": 85052,
      "category": "agency_document"
    },
    {
      "name": "520170013W_Warning Letter_08182017_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520170013W/520170013W_Warning%20Letter_08182017_text.pdf",
      "bytes": 81345,
      "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": "ISLAND ENERGY"
}
```
