{"operation":"document","citation":"CPF 520080008M","title":"HAWAII GAS — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-03-18","effective_on":null,"summary":"CLOSED notice of amendment citing 192.903(a), 192.915(a), 192.917(a)(2), 192.919(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080008m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080008m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080008m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520080008M","body":"Notice of Amendment involving HAWAII GAS. PHMSA's enforcement data identifies the cited regulations as 192.903(a),  192.915(a),  192.917(a)(2),  192.919(e). The case was opened on 2008-03-18 and is reported as closed as of 2009-03-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520080008M_notice of amendment_03182008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520080008M/520080008M_notice%20of%20amendment_03182008.pdf\n\n520080008m_notice of amendment_03182008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520080008M/520080008m_notice%20of%20amendment_03182008_text.pdf\n\n520080008M_operator response_05092008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520080008M/520080008M_operator%20response_05092008.pdf\n\n520080008m_notice of amendment_03182008_text.pdf\n\no\nU. s. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nMarch 18, 2008\nMr. Thomas Young\nVice President, Operations\nThe Gas Company\n515 Kamakee Street\nHonolulu, HI 96802-3000\nCPF 5-2008-0008M\nDear Mr. Young:\nOn December 10 to 14, 2007 a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected The Gas\nCompany's (TGC) procedures for Integrity Management Program (IMP) in Honolulu, Hawaii.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTGC plans or procedures, as described below:\n1. $192. 903 What definitions apply to this subpart?\nHigh consequence area (HCA) means an area established by one of the methods\ndescribed in paragraphs (1) or (2) as follows:\n(1) An area defined as—\n(i) A Class 3 location under $192. 5; or\n(ii) A Class 4 location under $192. 5; or\n\n\n\n(iii) Any area in a Class 1 or Class 2 location where the potential impact radius is\ngreater than 660 feet (200 meters), and the area within a potential impact circle\ncontains 20 or more buildings intended for human occupancy; or\n(iv) Any area in a Class 1 or Class 2 location where the potential impact circle\ncontains an identified site.\n(2) The area within a potential impact circle containing—\n(i) 20 or more buildings intended for human occupancy, unless the exception in\nparagraph (4) applies; or\n(ii) An identified site.\n(3) Where a potential impact circle is calculated under either method (1) or (2) to\nestablish a high consequence area, the length of the high consequence area extends\naxially along the length of the pipeline from the outermost edge of the first potential\nimpact circle that contains either an identified site or 20 or more buildings intended\nfor human occupancy to the outermost edge of the last contiguous potential impact\ncircle that contains either an identified site or 20 or more buildings intended for\nhuman occupancy. (See Figure E. I. A. in appendix E. )\nThe Gas Company uses both methods and chooses the most conservative results. TGC\nconducted a class study by Bass Trigon, but it could not produce documentation of the actual\ndwelling study along side its pipeline. Even though TGC has identified the entire segment as\nbeing located in a HCA, the site study failed to count the actual number of buildings within the\npotential impact circle. The building count can direct the operator's attention to the more\npopulated areas.\n2. $192. 919 What must be in the baseline assessment plan?\nAn operator must include each of the following elements in its written baseline\nassessment plan:\n(e) A procedure to ensure that the baseline assessment is being conducted in a\nmanner that minimizes environmental and safety risks\nThe Gas Company has no procedures to protect workers, member of public, and environment\nduring assessments. The IMP identifies the assessment methods not the procedures to protect\npublic during assessment.\n3. $192. 917 How does an operator identify potential threats to pipeline integrity and\nuse the threat identification in its integrity program?\n(a) Threat identification. An operator must identify and evaluate all potential\nthreats to each covered pipeline segment. Potential threats that an operator must\nconsider include, but are not limited to, the threats listed in ASME/ANSI B31. 8S\n(ibr, see $192. 7), section 2, which are grouped under the following four categories:\n\n\n\n(1) Time dependent threats such as internal corrosion, external corrosion, and\nstress corrosion cracking;\n(2) Static or resident threats, such as fabrication or construction defects;\n(3) Time independent threats such as third party damage and outside force\ndamage; and\n(4) Human error\n(e) Actions to address particular threats. If an operator identifies any of the\nfollowing threats, the operator must take the following actions to address the threat\n(2) Cyclic fatigue. An operator must evaluate whether cyclic fatigue or other\nloading condition (including ground movement, suspension bridge condition) could\nlead to a failure of a deformation, including a dent or gouge, or other defect in the\ncovered segment. An evaluation must assume the presence of threats in the covered\nsegment that could be exacerbated by cyclic fatigue. An operator must use the\nresults from the evaluation together with the criteria used to evaluate the\nsignificance of this threat to the covered segment to prioritize the integrity baseline\nassessment or reassessment\nThe Gas Company, in its IMP, has not adopted all potential threats as identified in ASME\nB31. 8S. Cyclic fatigue and Other potential threats need to be included.\n4. $192. 915 What knowledge and training must personnel have to carry out an\nintegrity management program?\n(a) Supervisory personnel. The integrity management program must provide that\neach supervisor whose responsibilities relate to the integrity management program\npossesses and maintains a thorough knowledge of the integrity management\nprogram and of the elements for which the supervisor is responsible. The program\nmust provide that any person who qualifies as a supervisor for the integrity\nmanagement program has appropriate training or experience in the area for which\nthe person is responsible.\nThe Gas Company requires a B. S. degree without any prior pipeline experience, or 5 years of\npipeline experience, for its IMP team members, A college degree alone without prior pipeline\nexperience does not qualify an individual to: conduct integrity assessments, review and analyze\nassessment results, make decisions on action to be taken based on assessment results, or to\nimplement preventive and mitigative measures.\nRes onse to this Notice\nThis Notice is provided pursuant to 49 U. S. C. $ 60108(a) and 49 C. F. R. $ 190. 237. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U. S. C. 552(b), along with the complete original document\n\n\n\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U. S. C. 552(b). If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the inadequacies\n(49 C. F. R. ) 190. 237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 60 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIn correspondence concerning this matter, please refer to CPF 5-2008-000SM and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 H. Monfared (¹120224)\nEnclosure: Response Options for Pipeline Operators in Comphance Proceedings","truncated":false,"body_characters":8785}