{"operation":"document","citation":"CPF 520170013W","title":"ISLAND ENERGY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-08-18","effective_on":null,"summary":"CLOSED warning letter citing 192.491(c), 192.743(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520170013w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520170013w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520170013w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520170013W","body":"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.\n\nOfficial case documents:\n\n520170013W_Operator Response To Notice_09082017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170013W/520170013W_Operator%20Response%20To%20Notice_09082017.pdf\n\n520170013W_Warning Letter_08182017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170013W/520170013W_Warning%20Letter_08182017.pdf\n\n520170013W_Warning Letter_08182017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170013W/520170013W_Warning%20Letter_08182017_text.pdf\n\n520170013W_Warning Letter_08182017_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 18, 2017\nMr. Peter Guadagni\nGeneral Manager\nIsland Energy\n440 Walnut Ave\nVallejo, CA 94592\nCPF 5-2017-0013W\nDear Mr. Guadagni:\nOn January 24 through 27, 2017, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected\nthe Island Energy procedures for gas distribution system in Vallejo, California.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. §192.491 Corrosion control records.\n(c) Each operator shall maintain a record of each test, survey, or inspection required by\nthis subpart in sufficient detail to demonstrate the adequacy of corrosion control measures\nor that a corrosive condition does not exist. These records must be retained for at least 5\nyears, except that records related to §§192.465(a) and (e) and 192.475(b) must be retained\nfor as long as the pipeline remains in service.\nIsland Energy failed to document the inspection of the aboveground meter sets for atmospheric\ncorrosion. A review of the corrosion records revealed that Island Energy did not have a location\nto record the atmospheric corrosion inspection. Island Energy conducts the inspection at least\n\n\n\nevery three years, not to exceed 39 months. This inspection is evidenced by the fact that Island\nEnergy manually reads each meter set at least monthly for billing purposes.\n2. §192.743 Pressure limiting and regulating stations: Capacity of relief devices\n(a) Pressure relief devices at pressure limiting stations and pressure regulating stations\nmust have sufficient capacity to protect the facilities to which they are connected. Except\nas provided in §192.739(b), the capacity must be consistent with the pressure limits of\n§192.201(a). This capacity must be determined at intervals not exceeding 15 months, but\nat least once each calendar year, by testing the devices in place or by review and\ncalculations.\nIsland Energy failed to verify and document the capacity of the system emergency relief valve in\n2015 and 2016. A review of maintenance records revealed the failure to verify the capacity of the\nrelief valve.\nAs of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil\npenalty not to exceed $209,002 per violation per day the violation persists up to a maximum of\n$2,090,022 for a 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(s) identified in\nthis letter. Failure to do so will result in Island Energy being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2017-0013W. 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 the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Dunphy (#148456)","truncated":false,"body_characters":4579}