{"operation":"document","citation":"CPF 520095012M","title":"HAWAII ELECTRIC LIGHT — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-02-19","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(f)(3), 195.452(f)(8).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095012m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095012m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095012m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520095012M","body":"Notice of Amendment involving HAWAII ELECTRIC LIGHT. PHMSA's enforcement data identifies the cited regulations as 195.452(f)(3),  195.452(f)(8). The case was opened on 2009-02-19 and is reported as closed as of 2009-09-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520095012M_notice of amendment_02192009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095012M/520095012M_notice%20of%20amendment_02192009.pdf\n\n520095012M_notice of amendment_02192009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095012M/520095012M_notice%20of%20amendment_02192009_text.pdf\n\n520095012M_operator response_03062009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095012M/520095012M_operator%20response_03062009.pdf\n\n520095012M_notice of amendment_02192009_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 19, 2009\nMr. Norman Verbanic, Jr.\nProduction Manager\nHawaiian Electric Light Company, Inc.\n54 Halekauila Street\nHilo, HI 96721-1027\nCPF 5-2009-5012M\nDear Mr. Verbanic:\nBetween August 1 and 4, 2008, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nthe Hawaiian Electric Light Company’s (HELCO) procedures for their Integrity Management\nProgram (IMP) in Hilo, Hawaii.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nHELCO’s plans or procedures, as described below:\n1. §195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\n\n\n\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(8) A process for review of integrity assessment results and information analysis\nby a person qualified to evaluate the results and information (see paragraph (h)\n(2) of this section).\nThe HELCO procedures do not ensure the IMP reviewers and evaluators are qualified.\nThe procedures currently require the documentation of their IMP team members;\nhowever, the procedures do not specify the level of qualifications the IMP reviewers\nmust have to adequately review and analyze the assessment results.\n2. §195.452 Pipeline integrity management in high consequence areas.\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, each of the following\nelements in its written integrity management program:\n(3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this\nsection);\n(g) What is an information analysis? In periodically evaluating the integrity of\neach pipeline segment (paragraph (j) of this section), an operator must analyze all\navailable information about the integrity of the entire pipeline and the\nconsequences of a failure. This information includes:\n(1) Information critical to determining the potential for, and preventing, damage\ndue to excavation, including current and planned damage prevention activities,\nand development or planned development along the pipeline segment;\n(2) Data gathered through the integrity assessment required under this section;\n(3) Data gathered in conjunction with other inspections, tests, surveillance and\npatrols required by this Part, including, corrosion control monitoring and\ncathodic protection surveys; and\n(4) Information about how a failure would affect the high consequence area, such\nas location of the water intake.\nThe HELCO procedures are inadequate for considering the risks associated with their\npipeline facility beyond just line pipe. The facility risk needs to define how equipment\nsuch as pumps, valves, and gaskets is addressed via the risk analysis and P&MM\nprocesses.\n2\n\n\n\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to\nfind facts as alleged in this Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 30 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIn correspondence concerning this matter, please refer to CPF 5-2009-5012M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 H. Nguyen (#121975)\nEnclosure: Response Options for Pi peline Operators in Compliance Proceedings\n3","truncated":false,"body_characters":6614}