{"operation":"document","citation":"CPF 520160025M","title":"HAWAII GAS — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-11-15","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(1), 192.907(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160025m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160025m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160025m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520160025M","body":"Notice of Amendment involving HAWAII GAS. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(1),  192.907(a). The case was opened on 2016-11-15 and is reported as closed as of 2017-02-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520160025M_Closure Letter_02072017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160025M/520160025M_Closure%20Letter_02072017.pdf\n\n520160025M_Closure Letter_02072017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160025M/520160025M_Closure%20Letter_02072017_text.pdf\n\n520160025M_Notice of Amendment_11152016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160025M/520160025M_Notice%20of%20Amendment_11152016.pdf\n\n520160025M_Notice of Amendment_11152016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160025M/520160025M_Notice%20of%20Amendment_11152016_text.pdf\n\n520160025M_Operator Response to Notice_12162016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160025M/520160025M_Operator%20Response%20to%20Notice_12162016.pdf\n\n520160025M_Closure Letter_02072017_text.pdf\n\nVIA FED EX – TRACKING # 7783 7406 7809\nFebruary 7, 2017\nMs. Alicia Moy\nPresident & CEO\nHawaii Gas\n745 Fort Street Mall, Ste. 1800\nHonolulu, HI 96813\nCPF 5-2016-0025M\nCase Closure\nDear Ms. Moy:\nOn October 20-24, 2014 and October 27-30, 2014, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Hawaii Gas’ Operations and Maintenance\nProcedures Manual and Integrity Management Program Procedures that cover its 22.6 mile synthetic\nnatural gas (SNG) transmission pipeline system on the island of Oahu, Hawaii. As a result of the\ninspection, Hawaii Gas was issued a Notice of Amendment on November 15, 2016, which proposed\namendment of your procedures.\nHawaii Gas submitted its amended procedures on December 16, 2016. My staff reviewed the\namended procedures and supporting documents. It appears that the inadequacies outlined in this\nNotice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you for\nyour cooperation.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 C. Ishikawa (#147745)\n\n520160025M_Notice of Amendment_11152016_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 15, 2016\nMs. Alicia Moy\nPresident & CEO\nHawaii Gas\n745 Fort Street Mall, Ste. 1800\nHonolulu, Hawaii 96813\nCPF 5-2016-0025M\nDear Ms. Moy:\nOn October 20-24, 2014 and October 27-30, 2014, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Hawaii Gas’ Operations and Maintenance Procedures Manual and Integrity Management\nProgram Procedures that cover its 22.6 mile synthetic natural gas (SNG) transmission pipeline system\non the island of Oahu, Hawaii.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within Hawaii\nGas’ plans or procedures, as described below:\n1. §192.907 What must an operator do to implement this subpart?\n(a) General. No later than December 17, 2004, an operator of a covered pipeline\nsegment must develop and follow a written integrity management program that contains\nall the elements described in § 192.911 and that addresses the risks on each covered\ntransmission pipeline segment. The initial integrity management\nprogram must consist, at a minimum, of a framework that describes the process for\nimplementing each program element, how relevant decisions will be made and by whom,\na time line for completing the work to implement the program element, and how\ninformation gained from experience will be continuously incorporated into the program.\nThe framework will evolve into a more detailed and comprehensive program. An\noperator must make continual improvements to the program.\n\n\n\nHawaii Gas did not have a detailed and comprehensive written integrity management (IM) program.\nSpecifically, Hawaii Gas’ written IM procedures, IM-007 titled “Preventive and Mitigative Measures,”\ndid not adequately describe the method for selection and implementation of additional preventive and\nmitigative measures (P&MM). A review of Hawaii Gas’ Risk Assessment and P&MM Evaluation\nReport, dated February 10, 2014, showed P&MM results categories of “mandatory,” “desired,” and\n“optional.” It was unclear how additional measures would be implemented or scheduled based on\nthese result categories. Further, while the IM procedures referenced use of an “action plan” and\n“completion report” to document the decision-making process, the Risk Assessment and P&MM\nEvaluation Report referenced use of a “P&MM tracking form.” None of these documents were\nprovided during the inspection. Hawaii Gas must amend its procedures to clarify and reflect its process\nfor selection and implementation of additional preventive and mitigative measures.\nHawaii Gas also did not have a detailed and comprehensive written IM program that reflects its\ncurrent IM implementation processes. For example, Hawaii Gas’ IM procedure, IM-002 titled “Data\nIntegration” stated “Hawaii Gas SMEs [Subject Matter Experts] obtain data for Data Integration from\nboth internal and external sources. The majority of the data has been reviewed by SME’s and inputted\ninto an Excel spreadsheet/database. The database is used to capture and maintain data and to serve as a\ncentralized database for Data Integration, Risk Assessment and Preventive and Mitigative Measures.”\nDuring the inspection, Hawaii Gas failed to provide evidence of a centralized Excel database to\ndemonstrate that one was created and maintained for its IM program. IM-003 titled “Risk Assessment”\nprovides another example where Hawaii Gas’ written IM program did not reflect its actual, current IM\nimplementation processes. This procedure revealed use of a combination of SMEs and relative risk\nassessment models in its risk assessment process. IM-003 stated “The Risk Algorithm is contained in\nthe same Excel spreadsheet that is used for Data Integration. The model uses weighting factors that\nSME’s have assigned based on data in the database.” However, Hawaii Gas failed to provide evidence\nthat demonstrated a risk assessment model was implemented during its risk assessment process.\nHawaii Gas must amend its procedures to clarify and reflect its current IM implementation processes,\nspecifically methods for data integration and risk assessment.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies\nEach operator shall include the following in its operating and maintenance plan:\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 safety\nduring maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of the\nrequirements of this subpart and Subpart M of this part.\nHawaii Gas’ written operations and maintenance (O&M) procedures manual did not include the\nretention period for odorizing program documentation in accordance with §192.709(c). For example,\nHawaii Gas’ O&M procedure, D-960 Odorizing Program, Section VIII stated, “The results of the\nodorometer tests (sniff test) performed by the Customer Service Department are filed with the\nCompliance Engineer for a period of three (3) years.” Federal Regulation §192.709(c) requires “A\nrecord of each patrol, survey, inspection, and test required by Subparts L and M of this part must be\nretained for at least 5 years or until the next patrol, survey, inspection, or test is completed, whichever\nis longer.” Hawaii Gas must amend its procedures to specify the five (5) year retention period required\nby §192.709(c).\n\n\n\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as part\nof this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all material\nyou submit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the document\nwith the 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. 552(b). If you\ndo not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to\ncontest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to\nfind facts as alleged in this 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 this\nNotice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R.\n§ 190.237). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 30 days of receipt of this Notice. This period may be extended by\nwritten request for good cause. Once the inadequacies identified herein have been addressed in your\namended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Hawaii Gas maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Chris Hoidal, Director, Western Region, Pipeline and Hazardous Materials\nSafety Administration. In correspondence concerning this matter, please refer to CPF 5-2016-0025M\nand, for each document you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nChris Hoidal,\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 C. Ishikawa (#147745)","truncated":false,"body_characters":10419}