{"operation":"document","citation":"CPF 520160026","title":"HAWAII GAS — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-11-16","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.491(c), 192.603(b), 192.605(a), 192.706, 192.709(a), 192.739(a)(2), 192.805(b), 192.907(a), 192.917(a), 192.935(a), 192.945(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160026.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160026.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520160026","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520160026","body":"Notice of Probable Violation involving HAWAII GAS. PHMSA's enforcement data identifies the cited regulations as 192.491(c),  192.603(b),  192.605(a),  192.706,  192.709(a),  192.739(a)(2),  192.805(b),  192.907(a),  192.917(a),  192.935(a),  192.945(a). The case was opened on 2016-11-16 and is reported as closed as of 2019-10-21. Proposed civil penalty: $60,300. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520160026_NOPV PCP PCO_11162016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160026/520160026_NOPV%20PCP%20PCO_11162016.pdf\n\n520160026_NOPV PCP PCO_11162016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160026/520160026_NOPV%20PCP%20PCO_11162016_text.pdf\n\n520160026_Operator Response to Notice_12162016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160026/520160026_Operator%20Response%20to%20Notice_12162016.pdf\n\n520160026_Region Withdrawal of Notice Letter_10212019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160026/520160026_Region%20Withdrawal%20of%20Notice%20Letter_10212019.pdf\n\n520160026_Region Withdrawal of Notice Letter_10212019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160026/520160026_Region%20Withdrawal%20of%20Notice%20Letter_10212019_text.pdf\n\n520160026_NOPV PCP PCO_11162016_text.pdf\n\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 16, 2016\nMs. Alicia Moy\nPresident & CEO\nHawaii Gas\n745 Fort Street Mall, Ste. 1800\nHonolulu, HI 96813\nCPF 5-2016-0026\nDear Ms. Moy:\nOn October 20-24 and October 27-30, 2014, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to\nChapter 601 of 49 United States Code, inspected Hawaii Gas’ 22.6 mile synthetic natural gas\n(SNG) transmission pipeline system on the island of Oahu, Hawaii.\nAs a result of the inspection, it is alleged that Hawaii Gas has committed probable violations\nof the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items\ninspected and the probable violations are:\n1. §192.491 Corrosion control records.\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 corrosion\ncontrol measures or that a corrosive condition does not exist. These records must be\nretained for at least 5 years, except that records related to §§192.465(a) and (e) and\n192.475(b) must be retained for as long as the pipeline remains in service.\n\n\n\nHawaii Gas did not maintain a record of each test, survey, or inspection required by this\nsubpart in sufficient detail to demonstrate the adequacy of corrosion control measures or\nthat a corrosive condition does not exist on its synthetic natural gas (SNG) transmission\npipeline system.\nSection 192.475(a) prohibits the transportation of corrosive gas by pipeline unless the\ncorrosive effect of the gas on the pipeline has been investigated and steps have been taken\nto minimize internal corrosion. Yet, Hawaii Gas did not provide any records or other\ndocumentation to demonstrate that it did not transport corrosive gas or that it had\ninvestigated the corrosive effects of the gas on its SNG pipeline system and taken steps to\nminimize internal corrosion.\n2. §192.603 General provisions\n… (b) Each operator shall keep records necessary to administer the procedures\nestablished under §192.605.\nHawaii Gas did not keep records necessary to administer the procedures it established\nunder §192.605 for its SNG transmission pipeline system.\nAt the time of inspection, the PHMSA inspector noted that the maximum allowable\noperating pressure (MAOP) of Hawaii Gas’ SNG transmission pipeline system was\nrecorded as 500 psig in Hawaii Gas’ Integrity Management (IM) documentation. The\nestablishment of MAOP is a normal operating procedure required by §192.605(b).\nHowever, Hawaii Gas did not provide any additional records to substantiate how it\nactually established the MAOP of its SNG transmission pipeline system.\n3. §192.605 Procedural manual for operations, maintenance, and emergencies\nEach operator shall include the following in its operating and maintenance plan:\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nHawaii Gas did not follow its manual of written procedures for conducting operations and\nmaintenance activities on its SNG transmission pipeline system.\nHawaii Gas’ written Operations and Maintenance (O&M) Procedures Manual D-960\nOdorizing Program, Section VI stated “The SNG will be sampled at least four times per\nyear at representative locations within the SNG distribution system for verification of\nodorant adequacy. Standard SNG distribution system test locations are: 1) Jenny's Drive\nIn (Waipahu) 94-861 Farrington Highway, 2) Manoa Marketplace 2851 East Manoa\nRoad, 3) Residential home (Hawaii Kai) 576 Pepeekeo Place.”\n2\n\n\n\n4. During the records review, the PHMSA inspector discovered that Hawaii Gas did not\nmeet its frequency for sampling of gas at least four times per year. In 2011, only two\nodorant test site records were found. Those two records were dated May 10, 2011, and\nDecember 5, 2011. In 2012, only two odorant test site record were provided, and they\nwere dated May 8, 2012, and October 11, 2012. And, in 2013 only one SNG odorant test\nsite record dated August 14, 2013, was provided.\nAdditionally, Hawaii Gas failed to follow its written procedures for conducting the\ncalibration of its odorization test equipment on an annual basis. Hawaii Gas’ O&M\nProcedures Manual D-960 Odorizing Program, Section VII stated, “The odorometer will\nbe calibrated on an annual basis by the manufacturer.” During the records review, the\nPHMSA inspector discovered that Hawaii Gas did not meet its annual calibration\nfrequency. The most recent record provided for the odorometer with serial number 1698\nhad a calibration date of October 15, 2010, performed by Heath Consultants.\n§192.706 Transmission lines: Leakage surveys.\nLeakage surveys of a transmission line must be conducted at intervals not exceeding\n15 months, but at least once each calendar year. However, in the case of a\ntransmission line which transports gas in conformity with § 192.625 without an odor\nor odorant, leakage surveys using leak detector equipment must be conducted—\n(a) In Class 3 locations, at intervals not exceeding 7 1∕2 months, but at least twice\neach calendar year; and\n(b) In Class 4 locations, at intervals not exceeding 4 1∕2 months, but at least four\ntimes each calendar year.\nHawaii Gas did not conduct leakage surveys on its SNG transmission pipeline system at\nintervals not exceeding 15 months, but at least once each calendar year.\nHawaii Gas failed to perform a leakage survey of its SNG transmission pipeline system\nduring calendar year 2013. An internal Hawaii Gas memorandum dated February 21,\n2014, revealed that there was no documentation of performing a leakage survey on the\nSNG transmission line for 2013. After Hawaii Gas discovered the missed leakage survey,\nit performed a leakage survey on February 21, 2014. The leakage survey identified three\nleaks found on mains, which have since been repaired. Hawaii Gas performed a second\nleakage survey on September 3, 2014. There were no leaks found.\n5. §192.709 Transmission lines: Record keeping.\nEach operator shall maintain the following records for transmission line for the\nperiods specified:\n(a) The date, location, and description of each repair made to pipe (including pipe-\nto-pipe connections) must be retained for as long as the pipe remains in service.\nHawaii Gas did not maintain records for its SNG transmission pipeline system regarding\nthe date, location, and description of each repair made to pipe (including pipe-to-pipe\nconnections). These records must be retained for as long as the pipe remains in service.\nHawaii Gas did not adequately document the date and describe each repair made to\nregulator station equipment on its SNG transmission pipeline system that resulted from3\n\n\n\nperiodic regulator station inspections. The transmission regulator station report for the\nKunia regulator station dated July 29, 2013, stated, “pilot spring corroded at first stage\nand water in booth” under “work performed/condition as left.” Also, the transmission\nregulator station report for the Palama Meat Co. regulator station dated July 28, 2014,\nstated, “metal shaving in first and second stage port and change pilot springs corroded\nfrom liquid in system” under “work performed/condition as left.”\nThe documentation for the above conditions does not include a description of how each\nrepair had been made, if the repairs had actually been made, or if these unrepaired\nconditions remained.\n6. §192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture discs), and pressure\nregulating station and its equipment must be subjected at intervals not exceeding 15\nmonths, but at least once each calendar year, to inspections and tests to determine\nthat it is\n… (2) Adequate from the standpoint of capacity and reliability of operation for the\nservice in which it is employed;\nHawaii Gas did not ensure that each pressure limiting station, relief device (except rupture\ndiscs), and pressure regulating station and its equipment on its SNG transmission pipeline\nsystem was adequate from the standpoint of capacity and reliability of operation for the\nservice in which it is employed.\nHawaii Gas’ inspection and testing report for the Malakole Regulator Station on the SNG\ntransmission pipeline dated April 7, 2014, had a recorded lock up pressure of 170 psig for\nits first stage regulator that exceeded the regulator's set outlet pressure of 80 psig. The\nreport also had a recorded lock up pressure of 24 psig for its second stage regulator that\nexceeded the regulator's set outlet pressure of 12 psig.\n7. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n… (b) Ensure through evaluation that individuals performing covered tasks are\nqualified;\nHawaii Gas did not ensure through evaluation that individuals performing covered tasks\non its SNG transmission pipeline system were qualified.\nThree Hawaii Gas individuals were identified on SNG odorant test site records as having\nperformed odorization tests between 2011 and 2014. During the Operator Qualification\n(OQ) program records review, the PHMSA inspector noted there were no records of\ncompletion of Module 251 “Odorization” by these individuals. Hawaii Gas’ OQ program\nuses the Midwest Gas Association (MGA) module list, which includes module 251 and\nother covered task modules. Accordingly, the PHMSA inspector was unable to verify if\nthe three individuals who performed odorization tests between 2011 and 2014 were\nqualified to do so.\n4\n\n\n\n8. 9. Additionally, four individuals were identified on the Transmission Line Inspection\nReports D-934-1 as having performed patrolling on the SNG transmission pipeline system\nbetween 2012 and 2014. During the OQ program records review, the PHMSA inspector\nnoted there were no records of completion of module 271 “Leak Survey and Patrols;”\nwhich is also on the MGA module list. The PHMSA inspector was unable to verify if the\nfour individuals who performed patrols between 2012 and 2014 were qualified to do so.\n§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\ncontains all the elements described in § 192.911 and that addresses the risks on each\ncovered transmission pipeline segment. The initial integrity management program\nmust consist, at a minimum, of a framework that describes the process for\nimplementing each program element, how relevant decisions will be made and by\nwhom, a time line for completing the work to implement the program element, and\nhow information gained from experience will be continuously incorporated into the\nprogram. The framework will evolve into a more detailed and comprehensive\nprogram. An operator must make continual improvements to the program.\nHawaii Gas did not follow its written integrity management program (IMP) procedures for\nits SNG transmission pipeline system.\nHawaii Gas’ IMP Manual\n- Section 3.3 titled “Program Evaluation” stated, “In order to effectively manage IMP\nand its performance Hawaii Gas conducts the following activities as part of the\nPerformance Plan requirements: Annual program review, annual pipeline system\nreview, and triennial program third-party audit (‘mock’ audit based on PHMSA\nInspection Protocols.)” However, the PHMSA inspector discovered during the IMP\nrecords review that Hawaii Gas did not conduct periodic evaluations of its pipeline\nintegrity program on an annual basis. The last documented IMP annual review was on\nSeptember 19, 2012.\n- Section 6.2.3 titled “Roles and Responsibilities” stated, “The IMP Engineer\nmaintains...current IMP Organizational Chart with names of Hawaii Gas’ personnel\nand contractors, vendors, and consulting companies involved in IMP activities.\" At\nthe time of the inspection, however, Hawaii Gas did not provide the PHMSA inspector\nwith an “IMP Organizational Chart.”\n§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 threats\nto each covered pipeline segment. Potential threats that an operator must consider\ninclude, but are not limited to, the threats listed in ASME/ANSI B31.8S\n(incorporated by reference, see §192.7), section 2, which are grouped under the\nfollowing four categories:\n5\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.\nHawaii Gas did not identify and evaluate all potential threats to its SNG transmission\npipeline system.\nA review of the Hawaii Gas’ Risk Assessment and P&MM Evaluation Report dated\nFebruary 10, 2014 showed no indication that interactive threats were considered by\nHawaii Gas’ subject matter experts. Section 2.5.1 titled “Identification of Potential\nThreats” of Hawaii Gas’ IMP Manual dated August, 9, 2012 stated that “the interactive\nnature of other threats must also be considered.” Further, ASME/ANSI B31.8S states that\n“[t]he interactive nature of threats (i.e., more than one threat occurring on a section of a\npipeline at the same time) shall be considered.”\n10. §192.935 What additional preventive and mitigative measures must an operator\ntake?\n(a) General requirements. An operator must take additional measures beyond those\nalready required by Part 192 to prevent a pipeline failure and to mitigate the\nconsequences of a pipeline failure in a high consequence area. An operator must base\nthe additional measures on the threats the operator has identified to each pipeline\nsegment. (See § 192.917) An operator must conduct, in accordance with one of the\nrisk assessment approaches in ASME/ANSI B31.8S (incorporated by reference, see §\n192.7), section 5, a risk analysis of its pipeline to identify additional measures to\nprotect the high consequence area and enhance public safety. Such additional\nmeasures include, but are not limited to, installing Automatic Shut-off Valves or\nRemote Control Valves, installing computerized monitoring and leak detection\nsystems, replacing pipe segments with pipe of heavier wall thickness, providing\nadditional training to personnel on response procedures, conducting drills with local\nemergency responders and implementing additional inspection and maintenance\nprograms.\nHawaii Gas did not provide records or other documentation to demonstrate that it had\ntaken any additional preventive and mitigative measures (P&MM) beyond those already\nrequired by Part 192 to prevent a pipeline failure and to mitigate the consequences of a\npipeline failure in a high consequence area on its SNG transmission pipeline.\nHawaii Gas failed to provide the P&MM tracking form that was referenced in its Risk\nAssessment and P&MM Evaluation Report dated February 10, 2014. The PHMSA\ninspector was unable to ascertain if additional P&MM identified in the report had actually\nbeen implemented or scheduled for implementation.\n6\n\n\n\n11. §192.945 What methods must an operator use to measure program effectiveness?\n(a) General. An operator must include in its integrity management program methods\nto measure whether the program is effective in assessing and evaluating the integrity\nof each covered pipeline segment and in protecting the high consequence areas.\nThese measures must include the four overall performance measures specified in\nASME/ANSI B31.8S (incorporated by reference, see § 192.7 of this part), section 9.4,\nand the specific measures for each identified threat specified in ASME/ANSI B31.8S,\nAppendix A. An operator must submit the four overall performance measures as\npart of the annual report required by § 191.17 of this subchapter.\nHawaii Gas did not provide records or other documentation to demonstrate that it\nmeasured its integrity management (IM) program’s effectiveness in assessing and\nevaluating the integrity of its SNG transmission pipeline and in protecting high\nconsequence areas.\nHawaii Gas did not provide adequate documentation to demonstrate that its IM program’s\neffectiveness performance measures were trended over time or an analysis of these trends.\nFor example, there were no records to show a trending analysis of equipment or material\nfailures as a means to evaluate pipeline equipment deterioration or records to trending of\nleading indicators such as inadvertent over-pressurization, right-of-way encroachments\nwithout a one-call notification, or other abnormal operating conditions such as those listed\nin 192.605(c).\nProposed Civil Penalty\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a\nrelated series of violations. For violations occurring between January 4, 2012 to August 1,\n2016, the maximum penalty may not exceed $200.000 per violation per day, with a maximum\npenalty not to exceed $2,000,000 for a related series of violations. For violations occurring\nprior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per\nday, with a maximum penalty not to exceed $1,000,000 for related series of violations. The\nCompliance Officer has reviewed the circumstances and supporting documentation involved\nin the above probable violations and has recommended that you be preliminarily assessed a\ncivil penalty of $60,300 as follows:\nItem number PENALTY\n3 $14,800\n6 $14,800\n7 $16,900\n10 $13,800\nWarning Items\nWith respect to items 1, 4, 5, & 8 we have reviewed the circumstances and supporting\ndocuments involved in this case and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time. We advise you to promptly correct\nthese items. Failure to do so may result in additional enforcement action.7\n\n\n\nProposed Compliance Order\nWith respect to items 2, 3, 6, 7, 9, 10, & 11 pursuant to 49 United States Code § 60118, the\nPipeline and Hazardous Materials Safety Administration proposes to issue a Compliance\nOrder to Hawaii Gas. Please refer to the Proposed Compliance Order, which is enclosed and\nmade a part of this Notice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline\nOperators in Compliance Proceedings. Please refer to this document and note the response\noptions. All material you submit in response to this enforcement action may be made publicly\navailable. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust 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\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations 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.\nIn your correspondence on this matter, please refer to CPF 5-2016-0026 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\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 C. Ishikawa (#147745)\n8\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to Hawaii Gas a Compliance Order incorporating\nthe following remedial requirements to ensure the compliance of Hawaii Gas with the pipeline\nsafety regulations:\n1. In regard to Item Number 2 of the Notice pertaining to Hawaii Gas’ failure to keep\nrecords necessary to substantiate how it established the MAOP of its pipeline\nsystem, Hawaii Gas must provide records to PHMSA’s Western Region Director\n(Director) to verify how it had previously established the MAOP of its pipeline\nsystem. If Hawaii Gas does not possess MAOP records, it must either develop\nwritten records to accurately document how it had previously established the\nMAOP of its pipeline or, if the process by which the MAOP was established is\nunknown, it must reestablish the MAOP of the pipeline in accordance with Part\n192 and provide the records to the Director.\n2. In regard to Item Number 3 of the Notice pertaining to Hawaii Gas’ failure to\nfollow its manual of written procedures for conducting operations and\nmaintenance activities on its SNG transmission pipeline system, Hawaii Gas must\ntrain all its operations and maintenance personnel on the proper use of its written\nO&M procedures manual to ensure all future odorant tests are performed in\naccordance with Hawaii Gas’ written procedures. In addition, Hawaii Gas must\ncalibrate or verify that all its odorant test equipment has been calibrated within the\ntimes frames specified in its written O&M. Hawaii gas must also conduct an\nodorant test of its pipeline system after receipt of this Notice, and provide the\nrecords to the Director.\n3. 4. 5. In regard to Item Number 6 of the Notice pertaining to Hawaii Gas’ failure to\nensure that each pressure regulating station and its equipment on its SNG\ntransmission pipeline system was adequate from the standpoint of capacity and\nreliability of operation for the service in which it is employed,, Hawaii Gas must\nconduct an inspection and testing of its Malakole Regulator Station and ensure the\nlock-up pressure for its first stage regulator is properly set and recorded.\nIn regard to Item Number 7 of the Notice pertaining to Hawaii Gas’ failure to\nensure through evaluation that individuals performing covered tasks on its SNG\ntransmission pipeline system were qualified, Hawaii Gas must modify its written\nOperator Qualification (OQ) program with procedures designed to ensure that only\nproperly qualified individuals perform covered tasks on its pipeline system.\nIn regard to Item Number 9 of the Notice pertaining to Hawaii Gas’ failure to\nidentify and evaluate all potential threats to its SNG transmission pipeline system,\nHawaii Gas must amend its IM Program to specifically address the form used in its\nevaluation titled, Risk Assessment and P&MM Evaluation Report, to show\nindications that interactive threats are considered.\n9\n\n\n\n6. 7. 8. 9. In regard to Item Number 10 of the Notice pertaining to Hawaii Gas’ failure to\nprovide records or other documentation to demonstrate that it had taken any\nadditional preventive and mitigative measures (P&MM) beyond those already\nrequired by Part 192, Hawaii Gas must create and provide an up-to-date P&MM\ntracking form to the Director, or equivalent documentation, that would show if\nadditional P&MM were implemented or scheduled for implementation.\nIn regard to Item Number 11 of the Notice pertaining to Hawaii Gas’ failure to\nprovide records or other documentation to demonstrate that it measured its IM\nprogram’s effectiveness, Hawaii Gas must gather data and create trending analyses\nof equipment or material failures as a means to evaluate pipeline equipment\ndeterioration and of leading indicators such as inadvertent over-pressurization,\nright-of-way encroachments without a one-call notification, or other abnormal\noperating conditions such as those listed in 192.605(c). After completion, Hawaii\nGas must provide a written summary of the analyses, including statistical diagrams\nor charts, to the Director.\nHawaii Gas must submit new written procedures, records or other documentation\nto Chris Hoidal, Director, Western Region, Pipeline and Hazardous Materials\nSafety Administration within 90 days of the date of issuance of the Final Order to\nshow that the above eight (8) items were completed as required by this\nCompliance Order.\nIt is requested (not mandated) that Hawaii Gas maintain documentation of the\nsafety improvement costs associated with fulfilling this Compliance Order and\nsubmit the total to Chris Hoidal, Director, Western Region, Pipeline and\nHazardous Materials Safety Administration. It is requested that these costs be\nreported in two categories: 1) total cost associated with preparation/revision of\nplans, procedures, studies and analyses, and 2) total cost associated with\nreplacements, additions and other changes to pipeline infrastructure.\n10\n\n520160026_Region Withdrawal of Notice Letter_10212019_text.pdf\n\nWITHDRAWAL of NOTICE LETTER\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED AND EMAIL\nOctober 21, 2019\nMs. Alicia Moy\nPresident and Chief Executive Officer\nHawaii Gas\n515 Kamakee St\nHonolulu, HI 96814\nCPF 5-2016-0026\nDear Ms. Moy:\nOn November 16, 2016, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) issued a Notice of Probable Violation, Proposed Civil Penalty, and Proposed\nCompliance Order (Notice) to Hawaii Gas for alleged violations of the pipeline safety\nregulations. The alleged violations were identified during inspections on October 20-24 and\nOctober 27-30, 2014 of Hawaii Gas’ 22.6 mile synthetic natural gas (SNG) transmission\npipeline system on the island of Oahu, Hawaii. The inspections were conducted by a\nrepresentative of the Pipeline and Hazardous Materials Safety Administration (PHMSA),\nOffice of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code.\nHawaii Gas responded to the Notice by letter dated December 16, 2016 (Response) contesting\nsome of the allegations of violation and providing additional information on how it had or\nproposed to correct other violations it was not contesting.\nThe Director, Western Region, PHMSA, has reviewed the facts and circumstances\nsurrounding this enforcement matter, including the additional information provided by Hawaii\nGas in its Response and determined that enforcement is not warranted in this case.\nAccordingly, the Notice is hereby withdrawn in its entirety and this case is now closed with\nno further action required by Hawaii Gas.\n\n\n\nIf you have any questions concerning this letter, please contact Mr. Dustin Hubbard, Director,\nWestern Region, PHMSA, at 720-963-3160.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nMr. Mustafa Demirbag, Executive Director of Operations, Hawaii Gas","truncated":false,"body_characters":28731}