{"operation":"document","citation":"CPF 520190021W","title":"ISLAND ENERGY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-09-03","effective_on":null,"summary":"CLOSED warning letter citing 192.491(a), 192.491(c), 192.603(b), 192.615(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190021w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190021w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520190021w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520190021W","body":"Warning Letter involving ISLAND ENERGY. PHMSA's enforcement data identifies the cited regulations as 192.491(a),  192.491(c),  192.603(b),  192.615(c). The case was opened on 2019-09-03 and is reported as closed as of 2019-09-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520190021W_Operator Response to Notice_09232019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190021W/520190021W_Operator%20Response%20to%20Notice_09232019.pdf\n\n520190021W_Warning Letter_09032019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190021W/520190021W_Warning%20Letter_09032019.pdf\n\n520190021W_Warning Letter_09032019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520190021W/520190021W_Warning%20Letter_09032019_text.pdf\n\n520190021W_Warning Letter_09032019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 3, 2019\nMr. Garrett Evans\nCity Manager\nCity of Pittsburg\n65 Civic Avenue\nPittsburg, CA 94565\nCPF 5-2019-0021W\nDear Mr. Evans:\nOn April 8 through 12, 2019, representatives of the California Public Utilities Commission\n(CPUC) on behalf of the Pipeline and Hazardous Materials Safety Administration (PHMSA),\npursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected your natural gas\ndistribution system (Island Energy) on Mare Island 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\ninspected and the probable violations are:\n1. §192.615 Emergency plans.\n(a) . . .\n(c) Each operator shall establish and maintain liaison with appropriate fire,\npolice, and other public officials to:\n(1) Learn the responsibility and resources of each government organization that\nmay respond to a gas pipeline emergency;\n\n\n\n(2) Acquaint the officials with the operator's ability in responding to a gas\npipeline emergency;\n(3) Identify the types of gas pipeline emergencies of which the operator notifies\nthe officials; and,\n(4) Plan how the operator and officials can engage in mutual assistance to\nminimize hazards to life or property.\nIsland Energy could not locate for inspection the 2018 mailing list of public officials.\n2. §192.603 General provisions\n(a) . . .\n(b) Each operator shall keep records necessary to administer the procedures\nestablished under §192.605.\nIsland Energy failed to properly document the March 28, 2018 service abandonment at\nBuilding 115. Specifically, Island Energy did not record on Form 727 if the service was\npurged of natural gas. Also, Island Energy could not present the 2017 maintenance record for\nthe system pressure relief valve.\n3. §192.491 Corrosion control records.\n(a) Each operator shall maintain records or maps to show the location of\ncathodically protected piping, cathodic protection facilities, galvanic anodes, and\nneighboring structures bonded to the cathodic protection system. Records or\nmaps showing a stated number of anodes, installed in a stated manner or spacing,\nneed not show specific distances to each buried anode.\nThe Island Energy system maps did not show the location of system rectifiers or anodes.\n4. §192.491 Corrosion control records.\n(a) . . .\n(c) Each operator shall maintain a record of each test, survey, or inspection\nrequired by this subpart in sufficient detail to demonstrate the adequacy of\ncorrosion control measures or that a corrosive condition does not exist. These\nrecords must be retained for at least 5 years, except that records related to\n§192.465(a) and (e) and §192.475(b) must be retained for as long as the pipeline\nremains in service.\nIsland Energy could not present the 2018 cathodic protection monitoring records for the\nsystem.\n2\n\n\n\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to\nexceed $213,268 per violation per day the violation persists, up to a maximum of $2,132,679\nfor a related series of violations. For violation occurring on or after November 2, 2015 and\nbefore November 27, 2018, the maximum penalty may not exceed $209,002 per violation per\nday, with a maximum penalty not to exceed $2,090,022. For violations occurring prior to\nNovember 2, 2015, the maximum penalty may not exceed $200,000 per violation per day, with\na maximum penalty not to exceed $2,000,000 for a related series of violations. We have\nreviewed the circumstances and supporting documents involved in this case, and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time.\nWe advise you to correct the items identified in this letter. Failure to do so will result in Island\nEnergy being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2019-0021W. 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\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc. PHP-60 Compliance Registry\nJason Dunphy, WR (#165643)\nDoug Buchanan, General Manager Island Energy, 995 Walnut Ave., Vallejo, CA\n94592\n3","truncated":false,"body_characters":5661}