{"operation":"document","citation":"CPF 520095024W","title":"HAWAII ELECTRIC LIGHT — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-05-27","effective_on":null,"summary":"CLOSED warning letter citing 195.304, 195.404(a)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095024w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095024w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520095024w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520095024W","body":"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.\n\nOfficial case documents:\n\n520095024W_warning letter_05272009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095024W/520095024W_warning%20letter_05272009.pdf\n\n520095024W_warning letter_05272009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095024W/520095024W_warning%20letter_05272009_text.pdf\n\n520095024W_warning letter_05272009_text.pdf\n\nWARNING LETTER\nCERTIFIED – RETURN RECEIPT REQUESTED\nMay 27, 2009\nMr. Jay Ignacio\nPresident\nHawaiian Electric Light Company\n54 Halekauila Street\nPO Box 1027\nHilo, Hawaii 96721-1027\nCPF 5-2009-5024W\nDear Mr. Ignacio:\nOn March 17-22, 2009, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nHawaiian Electric Light Company’s (HELCO) delivery line, facilities, and records in Hilo,\nHawaii.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1. §195.404 Maps and Records.\n(a) Each operator shall maintain current maps and records of its pipeline systems\nthat include at least the following information;\n(4) The diameter, grade, type and nominal wall thickness of all pipe.\n\n\n\nThe operator could not provide records indicating the grade of pipe that was used to replace a\nportion of the pipeline that had mechanical damage and leaked causing an oil spill that occurred\non January 13, 2004.\nThe operator could not provide records indicating the grade of pipe used during 2003, 2004, and\n2006 for installation of launchers and receiver, the new Y to facilitate smart pigging and relief\nvalve.\nThe Specific evidence upon which the probable violation is based is spool drawings on pipe and\nfitting installed at Kalanianaole & Banyan Way.\n2. §195.304 Test pressure.\nThe test pressure for each pressure test conducted under this subpart must be\nmaintained throughout the part of the system being tested for at least 4 continuous\nhours at a pressure equal to 125 percent, or more, of the maximum operating\npressure and, in the case of a pipeline that is not visually inspected for leakage\nduring test, for at least an additional 4 continuous hours at a pressure equal to 110\npercent, or more, of the maximum operating pressure.\nThe operator provided hydro-test records for the pipe and fittings installed for a new pig\nlauncher at Chevron Terminal. The January 14, 2004, hydro-test record of this piping indicated\nthat the pipe was hydro-tested for only one hour.\nNo hydro-test records were presented for the pipe that was used to replace a portion of the\npipeline that had mechanical damage and leaked causing an oil spill that occurred on January\n13, 2004.\nThe Specific evidence upon which the probable violation is based includes the spool drawing on\nhydro-tested pipe and the pipe testing log.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\nFailure to do so will result in Hawaiian Electric Light Company being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2009-5024W and send all responses to my attention at 222 W. 7th Ave. #200, PO Box\n2\n\n\n\n37, Anchorage, Alaska 99513. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with the\nportions you believe qualify for confidential treatment redacted and an explanation of why you\nbelieve the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nDennis Hinnah\nDeputy Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 B. Flanders (#123950)\n3","truncated":false,"body_characters":4724}