{"operation":"document","citation":"CPF 520126012W","title":"HECO - HAWAIIAN ELECTRIC COMPANY, INC. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-04-19","effective_on":null,"summary":"CLOSED warning letter citing 195.222(a), 195.404, 195.404(a)(1), 195.430(a), 195.583(a), 195.589(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520126012w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520126012w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520126012w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520126012W","body":"Warning Letter involving HECO - HAWAIIAN ELECTRIC COMPANY, INC.. PHMSA's enforcement data identifies the cited regulations as 195.222(a),  195.404,  195.404(a)(1),  195.430(a),  195.583(a),  195.589(c). The case was opened on 2012-04-19 and is reported as closed as of 2012-04-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520126012W_warning letter-04192012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520126012W/520126012W_warning%20letter-04192012_text.pdf\n\n520126012W_warning letter_04192012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520126012W/520126012W_warning%20letter_04192012.pdf\n\n520126012W_warning letter-04192012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nApril 19, 2012\nMr. Floyd Shiroma\nDirector\nHawaiian Electric Company Inc.\n475 Kamehameha Highway\nPearl City, HI 96782\nCPF 5-2012-6012W\nDear Mr. Shiroma:\nOn March 24 through March 25, 2011, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected Hawaiian Electric Company’s (HECO’s) pipeline facilities in Honolulu, Hawaii. As\npart of the inspection, we reviewed your Operation and Maintenance Manual procedures, and\nimplementation records or documentation of those procedures.\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\nthe probable violations are:\n1. §195.222 Welders: Qualification of welders.\n(a) Each welder must be qualified in accordance with section 6 of API 1104\n(incorporated by reference, see §195.3) or section IX of the ASME Boiler and\nPressure Vessel Code, (incorporated by reference, see §195.3) except that a welder\nqualified under an earlier edition than listed in §195.3 may weld but may not re-\nqualify under that earlier edition.\n\n\n\nHECO did not document in sufficient detail the results of the welder qualifying tests in\naccordance with Section 6 of API 1104. During the time of inspection, neither the number of\ntensile strength test results nor the number of root bead test results were annotated on the\nqualification record for Mr. Eti Niaulituatoo. Following the inspections, HECO submitted to\nmy inspectors a letter, dated April 15, 2011, indicating that an amended qualification record for\nMr. Eti Niaulituatoo had been made. The new qualification record detailed acceptable tensile\nstrength and root/face bend test results for Mr. Niaulituatoo. An operator must ensure the\nwelder qualification records, including test results, are always documented and detailed enough\nto show compliance with §195.222, and referenced standards within that regulation.\n2. §195.404 Maps and Records.\n(a) Each operator shall maintain current maps and records of its pipeline\nsystems that include at least the following information;\n(1) Location and identification of the following pipeline facilities;\n(i) Breakout tanks;\n(ii) Pump stations;\n(iii) Scraper and sphere facilities;\n(iv) Pipeline valves;\n(v) Facilities to which §195.402(c) (9) applies;\n(vi) Rights-of-way; and\n(vii) Safety devices to which §195.428 applies.\nAt the time of inspection, HECO did not have current maps of its pipeline system. HECO’s\nalignment sheets for the Iwilei pipeline have not been updated since the original construction.\nInterviews with HECO personnel revealed that HECO had hired Coffman Engineering to\ndevelop new alignment sheets, and that the new alignment sheets will include all modifications,\npipeline crossings, and repairs. The previously mentioned April 15th letter from HECO stated\nthat HECO is in the process of updating their alignment sheets.\n3. §195.404 Maps and Records.\nA record of each inspection and test required by this subpart shall be maintained\nfor at least 2 years or until the next inspection or test is performed, whichever is\nlonger.\nHECO failed to correctly maintain records that show the proper date of the inspection and\ntesting for the relief valves per 195.428 at the Iwilei pump station. During the time of\ninspection, HECO’s 2009 record for the testing and inspection of the Taylor relief valve at the\nIwilei pump station indicated an inspection date of February 1, 2010. Interviews with HECO\npersonnel revealed that the Taylor relief valve was removed and it was sent to a contractor for\ntesting. In the interim, HECO installed a newly inspected and tested pressure relief valve, but\nthe 2009 inspection and test record of the previous pressure relief valve had been misplaced.\nSubsequently, HECO requested a copy of the inspection and test record from the contractor. A\ncopy of inspection and test record provided by the contractor was dated February 1, 2010 but\n\n\n\nthis appears to be the date the maintenance records was queried. Fortunately, HECO provided\nmy staff a calibration seal with a date of August 2009 for the original Taylor relief valve. An\noperator is required to maintain inspection records of all inspections being done under Subpart\nF – Operation and Maintenance for at least two (2) years or until the next inspection or test is\nperformed.\n4. §195.430 Firefighting equipment.\nEach operator shall maintain adequate firefighting equipment at each pump\nstation and breakout tank area. The equipment must be-\n(a) In proper operating condition at all times;\nHECO did not maintain their firefighting equipment at the Iwilei Fuel Storage Facility (IFSF)\nduring the period preceding our inspection. During the time of inspection, HECO’s records\nshow that their fire foam system was inspected in April 2009, and the inspection report had\nfour (4) recommendations for the Iwilei Fuel Storage Facility. It appears that none of the\nrecommendations had been implemented and addressed. Meanwhile, HECO’s letter dated\nApril 15, 2012 to my staff indicated HECO plans to change their firefighting equipment\nprocedure on how HECO will document the inspection and testing report, and follow-up the\nrecommendations.\n5. §195.589 What corrosion control information do I have to maintain?\n(c) You must maintain a record of each analysis, check, demonstration,\nexamination, inspection, investigation, review, survey, and test required by this\nsubpart in sufficient detail to demonstrate the adequacy of corrosion control\nmeasures or that corrosion requiring control measures does not exist. You must\nretain these records for at least 5 years, except that records related to Secs.\n195.569, 195.573(a) and (b), and 195.579(b) (3) and (c) must be retained for as long\nas the pipeline remains in service.\nHECO failed to maintain atmospheric corrosion monitoring records for their Iwilei pipeline.\nDuring the time of inspection, it appears that the pipeline segments inside the vault numbers 1,\n2, 4, 6, and 13 to 21 were not visually examined for atmospheric corrosion in 2007.\nMeanwhile, HECO’s letter dated April 15, 2011 to my staff stated that HECO had contracted\nthe atmospheric corrosion monitoring to Kendrick Consulting and their contractor did perform\nthe atmospheric corrosion inspection. Furthermore, the records indicated that HECO had been\nmonitored for atmospheric corrosion in August 2007. Unfortunately, HECO could not provide\ninspection records of atmospheric corrosion monitoring for vault numbers 1, 2, 4, 6, and 13\nto 21.\n\n\n\n6. §195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is located: Then the frequency of inspection is:\nOnshore At least once every 3 calendar years, but\nwith intervals not exceeding 39 months\nOffshore At least once each calendar year, but\nwith intervals not exceeding 15 months\nHECO failed to conduct atmospheric corrosion inspection at least once every 3 calendar years,\nbut with interval not exceeding 39 months for the pipeline segment inside vault number 4 of\ntheir Iwilei pipeline. Based on a review of atmospheric corrosion control records, it does not\nappear that the tests required by §195.583 were done in 2010. Furthermore, HECO’s\natmospheric corrosion record of vault number 4 of their Iwilei pipeline in 2010 indicates an\natmospheric corrosion inspection was not completed because the vault cover could not be\nremoved.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the item identified in\nthis letter. Failure to do so will result in HECO 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 5-2012-6012W. 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 G. Davis (#133322)\n\n520126012W_warning letter_04192012.pdf\n\n@\nu.s. oeporfment\nof Tronsporlotion\nPip.llne ond\nHozqrclous ltcrt€riols sqfely\nAdmlnislroflon\n12300 W. Dakota Ave., Suite 110\nLakewood, CO 80228\nWARNING LETTER\nCERTIFIED MAIL - RE,TURN RECEIPT REOUESTED\nApril19,2012\nMr. Floyd Shiroma\nD irector\nHawaiian Electric Company Inc.\n4?5 Kamehanlrelta Highway\nPearl Citv. Hl96782\ncPF s-2012-6012W\nDear Mr. Shhoma:\nOn March 24 through March 25, 2011, a representative ofthe Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected Hawaiian Electric Company's (HECO's) pipeline facilities in Honolulu, Hawaii. As\npart ofthe inspection, we reviewed your Operation and Maintenance Manual procedures, and\nimplementation records or documentation of those procedures.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code ofFederal Regulations. The items inspected and\nthe probable violations are:\nl. 5195.222 Welders: Qualification of welders.\n(a) Each welder must be qualified in accordance with section 6 of API 1104\n(incorporated by reference, see $195,3) or section IX ofthe ASME Boiler and\nPressure Vessel Code, (incorporated by reference, see $195.3) except thrt a welder\nqualified under an earlier edition than listed in $195.3 rnay weld but may not re-\nqualify under that eerlier editiol.\n\n\n\nHECO did not document in sufficient detail the results of the welder qualiffing tests in\naccordance with Section 6 of API 1104. During the time of inspection, neither the number of\ntensile strength test results nor the number ofroot bead test results were annotated on the\nqualification record for Mr. Eti Niaulituatoo. Following the inspections, HECO submitted to\nmy inspectors a letter, dated April 1 5 ,\n201 1\n, indicating that an amended qualification record for\nMr. Eti Niaulituatoo had been made. The new qualification record detailed acceptable tensile\nstrength and root/face bend test results for Mr. Niaulituatoo. An operator must ensure the\nwelder qualification records, including test results, are always documented and detailed enough\nto show compliance with 5195 .222, and referenced standards within that regulation.\n2. $195.404 Maps and Records.\n(a) Each operator shall mainiain current maps and records ofits pipeline\nsystems that include at least the following information;\n(1) Location and identification ofthe following pipeline facilities;\n(i) Breakout tanks;\n(ii) Pump stations;\n(iii) Scraper and sphere facilities;\n(iv) Pipeline valves;\n(v) Facilities to which $195.402(c) (9) applies;\n(vi) Rights-of-way; and\n(vii) Safety devices to which $195,428 applies.\nAt the time of inspection, HECO did not have current maps of its pipeline system. HECO's\nalignment sheets for the Iwilei pipeline have not been updated since the original construction.\nInterviews with HECO personnel revealed that FIECO had hired Coffrnan Engineering to\ndevelop new alignment sheets, and that the new alignment sheets will include all modifications,\npipeline crossings, and repairs. The previously mentioned April 156 letter from HECO stated\nthat HECO is in the process ofupdating their alignment sheets.\n3. $195.404 Maps and Records,\nA record ofeach inspection and test required by this subpart shall be maintained\nfor at least 2 years or until the next inspection or test is performed, whichever is\nlonger.\nHECO failed to correctly maintain records that show the proper date ofthe inspection and\ntesting for the reliefvalves per 195.428 at the Iwilei pump station. During the time of\ninspection, HECO's 2009 record for the testing and inspection ofthe Taylor reliefvalve at the\nIwilei pump station indicated an inspection date of February 1,2010. Interviews with HECO\npersonnel revealed that the Taylor reliefvalve was removed and it was sent to a contractor for\ntesting. In the interim, HECO installed a newly inspected and tested pressure relief valve, but\nthe 2009 inspection and test record ofthe previous pressure reliefvalve had been misplaced.\n\n\n\nSubsequently, HECO requested a copy ofthe inspection and test record from the contractor. A\ncopy of inspection and test record provided by the contractor was dated February 1, 2010 but\nthis appears to be the date the maintenance records was queried. Fortunately, HECO provided\nmy staffa calibration seal with a date of August 2009 for the original Taylor relief valve. An\noperator is required to maintain inspection records ofall inspections being done under Subpart\nF * Operation and Maintenance for at least two (2) years or until the next inspection or test is\nperformed.\n4. $f95.430Firefightingequipment, Each operator shall maintain adequate firefighting equipment at each pump\nstation and breakout tank area. The equipment must be-\n(a) In proper operating condition at all times;\nHECO did not maintain their firefrghting equipment at the Iwilei Fuel Storage Facility (IFSF)\nduring the period preceding our inspection. During the time of inspection, HECO's records\nshow that their fue foam system was inspected in April 2009, and the inspection report had\nfour (4) recommendations for the Iwilei Fuel Storage Facility. It appears that none of the\nrecommendations had been implemented and addressed. Meanwhile, HECO's letter dated\nApril 15, 2012 to my staff indicated HECO plans to change their firefighting equipment\nprocedure on how HECO will document the inspection and testing report, and follow-up the\nrecommendations.\n5. $195.589 What corrosion control informrtion do I have to maintain?\n(c) You must maintain a record of each analysis, check, demonstration,\nexamination, inspection, investigation, review, survey, and test required by this\nsubpart in sullicient detail to demonstrate the adequacy of corrosion control\nmeasures or that corrosion requiring control measures does not exist. You must\nretain these records for at least 5 years, except that records related to Secs.\n195.569, 195.573(a) and (b), and 195.579(b) (3) and (c) must be retained for as long\nas the pipeline remains in service.\nIIECO failed to maintain atmospheric corrosion moniloring records for their lwilei pipeline.\nDuring the time of inspection, it appears that the pipeline segments inside the vault numbers l,\n2, 4,6, and 13 to 21 were not visually examined for atmospheric corrosion in 2007.\nMeanwhile, HECO's letter dated April 15, 2011 to my staff stated that IIECO had contracted\nthe atmospheric corrosion monitoring to Kendrick Consulting and their contractor did perform\nthe atmospheric conosion inspection. Furthermore, the records indicated that FIECO had been\nmonitored for atmospheric corrosion in August 2007. Unfortunately, HECO could not provide\ninspection records of atmospheric corrosion monitoring for vault numbers 1,2, 4, 6, and 13\nto 21.\n\n\n\n6. $195.583 What must I do to monitor atmospheric corrosion control?\n(a) You must inspect each pipeline or portion of pipeline that is exposed to the\natmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is located: Onshore Offshore Then the frequencv of inspection is:\nAt least once every 3 calendar years, but\nwith intervrls not exceeding 39 nonths\nAt least once each calendar year, but\nwith intervals not exceeding 15 months\nHECO failed to conduct atmospheric conosion inspection at least once every 3 calendar years,\nbut with interval not exceeding 39 months for the pipeline segment inside vault number 4 of\ntheir Iwilei pipeline. Based on a review ofatmospheric corrosion control records, it does not\nappear that the tests required by $195.583 were done in 2010. Furthermore, HECO's\natmospheric corrosion record ofvault number 4 of their Iwilei pipeline in 2010 indicates an\natmospheric corrosion inspection was not completed because the vault cover could not be\nremoved.\nUnder 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of$1,000,000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the item identified in\nthis letter. Failure to do so will result in HECO being subject to additional enforcement action.\nNo reply to this letter is required. Ifyou choose to reply, in your correspondence please refer to\nCPF 5-2012-6012W. Be advised that a.ll matsrial 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 ofthe document with the portions\nyou believe qualifr 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).\nSincerelv.\nt ' l A ,/t// .'a / / /\n. / / / / / 1 /--r2,2 r/, ./\n\\__--./.\\!--- / t,_\nChris Hoidal\nDirector. Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 G. Davis (#133322)","truncated":false,"body_characters":19032}