{"operation":"document","citation":"CPF 520100008W","title":"ISLAND ENERGY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-02-12","effective_on":null,"summary":"CLOSED warning letter citing 192.16(d), 192.465(a), 192.465(b), 192.605(b)(8), 192.615(c), 192.739(a), 192.747(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100008w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100008w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100008w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520100008W","body":"Warning Letter involving ISLAND ENERGY. PHMSA's enforcement data identifies the cited regulations as 192.16(d),  192.465(a),  192.465(b),  192.605(b)(8),  192.615(c),  192.739(a),  192.747(a). The case was opened on 2010-02-12 and is reported as closed as of 2010-02-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520100008W_warning letter_02122010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100008W/520100008W_warning%20letter_02122010.pdf\n\n520100008W_warning letter_02122010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100008W/520100008W_warning%20letter_02122010_text.pdf\n\n520100008W_warning letter_02122010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 12, 2010\nMr. David Elder\nGeneral Manager\nIsland Energy\n440 Walnut Avenue\nMare Island, CA 94592-0001\nCPF 5-2010-0008W\nDear Mr. Elder:\nOn December 15 - 16, 2009, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\ngas distribution system at Mare Island, California.\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. §192.605 Procedural Manual for operations, maintenance, and emergencies.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(8) Periodically reviewing the work done by operator personnel to determine the\neffectiveness and adequacy of the procedures used in normal operation and\nmaintenance and modifying the procedures when deficiencies are found.\n\n\n\nThere were no records available at the time of the inspection to document periodic review of the\nwork done by operator’s personnel to determine the effectiveness and adequacy of procedures.\n2. §192.615 Emergency plans.\n(c) Each operator shall establish and maintain liaison with appropriate fire, police,\nand other public officials to:\n(1) Learn the responsibility and resources of each government organization that\nmay respond to a gas pipeline emergency;\n(2) Acquaint the officials with the operator’s ability in responding to a gas pipeline\nemergency;\n(3) Identify the types of gas pipeline emergencies of which the operator notifies the\nofficial; and\n(4) Plan how the operator and officials can engage in mutual assistance to\nminimize hazards to life or property.\nThere were no records available at the time of the inspection to document required liaison\nactivities had been performed.\n3. §192.465 External corrosion control: Monitoring.\n(a) Each pipeline that is under cathodic protection must be tested at least once each\ncalendar year, but with intervals not exceeding 15 months, to determine whether\nthe cathodic protection meets the requirements of §192.463. However, if tests at\nthose intervals are impractical for separately protected short sections of mains or\ntransmission line, not in excess of 100 feet (30 meters), or separately protected\nservice line, these pipelines may be surveyed on a sampling basis. At least 10\npercent of these protected structures, distributed over the entire system must be\nsurveyed each calendar year, with a different 10 percent checked each subsequent\nyear, so that the entire system is tested in each 10-year period.\nRecords were unavailable at the time of the inspection to document compliance with the\ninspection and testing requirements for corrosion control. Only a few recorded readings could\nbe found.\n4. §192.465 External corrosion control: Monitoring.\n(b) Each cathodic protection rectifier or other impressed current power source\nmust be inspected six times each calendar year, but with intervals not exceeding 2\n½ months.\n2\n\n\n\nRecords were unavailable at the time of the inspection to document compliance with the\ninspection and testing requirements for corrosion control. Only a few recorded readings could\nbe found.\n5. §192.16 Customer Notification.\n(d) Each operator must make the following records available for inspection by the\nAdministrator or a State agency participating under 49 U.S.C. 60105 or 60106:\n(1) A copy of the notice currently in use; and\n(2) Evidence that notices have been sent to customers within the previous 3 years.\nNo records pertaining to customer notification were available during the inspection.\n6. §192.739 Pressure Limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting stations, relief device (except rupture discs), and\npressure regulating station and its equipment must be subjected at intervals not\nexceeding 15 months, but at least once each calendar year, to inspections and tests\nto determine that it is-\n(1) In good mechanical condition;\n(2) Adequate from the standpoint of capacity and reliability of operation for the\nservice in which it is employed.\n(3)Except as provided in paragraph (b) of this section, set to control or relieve at\nthe correct pressure consistent with the pressure limits of §192.201(a);\nNo documentation of required pressure regulator and monitor testing for calendar years 2006\nand 2007 was available during the inspection.\n7. §192.747 Valve maintenance: Distribution systems.\n(a) Each valve, the use of which may be necessary for the safe operation of a\ndistribution system, must be checked and serviced at intervals not exceeding 15\nmonths, but at least once each calendar year.\nNo documentation of required valve maintenance for calendar years 2006 and 2007 was\navailable during the inspection.\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\n3\n\n\n\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\nFailure to do so will result in Island Energy being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2010-0008W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Stahoviak (#123931)\n4","truncated":false,"body_characters":7115}