# HAWAII GAS — Notice of Probable Violation

- **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:** Not available
- **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).
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- **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.

Official case documents:

520160026_NOPV PCP PCO_11162016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160026/520160026_NOPV%20PCP%20PCO_11162016.pdf

520160026_NOPV PCP PCO_11162016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160026/520160026_NOPV%20PCP%20PCO_11162016_text.pdf

520160026_Operator Response to Notice_12162016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160026/520160026_Operator%20Response%20to%20Notice_12162016.pdf

520160026_Region Withdrawal of Notice Letter_10212019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520160026/520160026_Region%20Withdrawal%20of%20Notice%20Letter_10212019.pdf

520160026_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

520160026_NOPV PCP PCO_11162016_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 16, 2016
Ms. Alicia Moy
President & CEO
Hawaii Gas
745 Fort Street Mall, Ste. 1800
Honolulu, HI 96813
CPF 5-2016-0026
Dear Ms. Moy:
On October 20-24 and October 27-30, 2014, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to
Chapter 601 of 49 United States Code, inspected Hawaii Gas’ 22.6 mile synthetic natural gas
(SNG) transmission pipeline system on the island of Oahu, Hawaii.
As a result of the inspection, it is alleged that Hawaii Gas has committed probable violations
of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items
inspected and the probable violations are:
1. §192.491 Corrosion control records.
… (c) Each operator shall maintain a record of each test, survey, or inspection
required by this subpart in sufficient detail to demonstrate the adequacy of corrosion
control measures or that a corrosive condition does not exist. These records must be
retained for at least 5 years, except that records related to §§192.465(a) and (e) and
192.475(b) must be retained for as long as the pipeline remains in service.



Hawaii Gas did not maintain a record of each test, survey, or inspection required by this
subpart in sufficient detail to demonstrate the adequacy of corrosion control measures or
that a corrosive condition does not exist on its synthetic natural gas (SNG) transmission
pipeline system.
Section 192.475(a) prohibits the transportation of corrosive gas by pipeline unless the
corrosive effect of the gas on the pipeline has been investigated and steps have been taken
to minimize internal corrosion. Yet, Hawaii Gas did not provide any records or other
documentation to demonstrate that it did not transport corrosive gas or that it had
investigated the corrosive effects of the gas on its SNG pipeline system and taken steps to
minimize internal corrosion.
2. §192.603 General provisions
… (b) Each operator shall keep records necessary to administer the procedures
established under §192.605.
Hawaii Gas did not keep records necessary to administer the procedures it established
under §192.605 for its SNG transmission pipeline system.
At the time of inspection, the PHMSA inspector noted that the maximum allowable
operating pressure (MAOP) of Hawaii Gas’ SNG transmission pipeline system was
recorded as 500 psig in Hawaii Gas’ Integrity Management (IM) documentation. The
establishment of MAOP is a normal operating procedure required by §192.605(b).
However, Hawaii Gas did not provide any additional records to substantiate how it
actually established the MAOP of its SNG transmission pipeline system.
3. §192.605 Procedural manual for operations, maintenance, and emergencies
Each operator shall include the following in its operating and maintenance plan:
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least one each
calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
Hawaii Gas did not follow its manual of written procedures for conducting operations and
maintenance activities on its SNG transmission pipeline system.
Hawaii Gas’ written Operations and Maintenance (O&M) Procedures Manual D-960
Odorizing Program, Section VI stated “The SNG will be sampled at least four times per
year at representative locations within the SNG distribution system for verification of
odorant adequacy. Standard SNG distribution system test locations are: 1) Jenny's Drive
In (Waipahu) 94-861 Farrington Highway, 2) Manoa Marketplace 2851 East Manoa
Road, 3) Residential home (Hawaii Kai) 576 Pepeekeo Place.”
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4. During the records review, the PHMSA inspector discovered that Hawaii Gas did not
meet its frequency for sampling of gas at least four times per year. In 2011, only two
odorant test site records were found. Those two records were dated May 10, 2011, and
December 5, 2011. In 2012, only two odorant test site record were provided, and they
were dated May 8, 2012, and October 11, 2012. And, in 2013 only one SNG odorant test
site record dated August 14, 2013, was provided.
Additionally, Hawaii Gas failed to follow its written procedures for conducting the
calibration of its odorization test equipment on an annual basis. Hawaii Gas’ O&M
Procedures Manual D-960 Odorizing Program, Section VII stated, “The odorometer will
be calibrated on an annual basis by the manufacturer.” During the records review, the
PHMSA inspector discovered that Hawaii Gas did not meet its annual calibration
frequency. The most recent record provided for the odorometer with serial number 1698
had a calibration date of October 15, 2010, performed by Heath Consultants.
§192.706 Transmission lines: Leakage surveys.
Leakage surveys of a transmission line must be conducted at intervals not exceeding
15 months, but at least once each calendar year. However, in the case of a
transmission line which transports gas in conformity with § 192.625 without an odor
or odorant, leakage surveys using leak detector equipment must be conducted—
(a) In Class 3 locations, at intervals not exceeding 7 1∕2 months, but at least twice
each calendar year; and
(b) In Class 4 locations, at intervals not exceeding 4 1∕2 months, but at least four
times each calendar year.
Hawaii Gas did not conduct leakage surveys on its SNG transmission pipeline system at
intervals not exceeding 15 months, but at least once each calendar year.
Hawaii Gas failed to perform a leakage survey of its SNG transmission pipeline system
during calendar year 2013. An internal Hawaii Gas memorandum dated February 21,
2014, revealed that there was no documentation of performing a leakage survey on the
SNG transmission line for 2013. After Hawaii Gas discovered the missed leakage survey,
it performed a leakage survey on February 21, 2014. The leakage survey identified three
leaks found on mains, which have since been repaired. Hawaii Gas performed a second
leakage survey on September 3, 2014. There were no leaks found.
5. §192.709 Transmission lines: Record keeping.
Each operator shall maintain the following records for transmission line for the
periods specified:
(a) The date, location, and description of each repair made to pipe (including pipe-
to-pipe connections) must be retained for as long as the pipe remains in service.
Hawaii Gas did not maintain records for its SNG transmission pipeline system regarding
the date, location, and description of each repair made to pipe (including pipe-to-pipe
connections). These records must be retained for as long as the pipe remains in service.
Hawaii Gas did not adequately document the date and describe each repair made to
regulator station equipment on its SNG transmission pipeline system that resulted from3



periodic regulator station inspections. The transmission regulator station report for the
Kunia regulator station dated July 29, 2013, stated, “pilot spring corroded at first stage
and water in booth” under “work performed/condition as left.” Also, the transmission
regulator station report for the Palama Meat Co. regulator station dated July 28, 2014,
stated, “metal shaving in first and second stage port and change pilot springs corroded
from liquid in system” under “work performed/condition as left.”
The documentation for the above conditions does not include a description of how each
repair had been made, if the repairs had actually been made, or if these unrepaired
conditions remained.
6. §192.739 Pressure limiting and regulating stations: Inspection and testing.
(a) Each pressure limiting station, relief device (except rupture discs), and pressure
regulating station and its equipment must be subjected at intervals not exceeding 15
months, but at least once each calendar year, to inspections and tests to determine
that it is
… (2) Adequate from the standpoint of capacity and reliability of operation for the
service in which it is employed;
Hawaii Gas did not ensure that each pressure limiting station, relief device (except rupture
discs), and pressure regulating station and its equipment on its SNG transmission pipeline
system was adequate from the standpoint of capacity and reliability of operation for the
service in which it is employed.
Hawaii Gas’ inspection and testing report for the Malakole Regulator Station on the SNG
transmission pipeline dated April 7, 2014, had a recorded lock up pressure of 170 psig for
its first stage regulator that exceeded the regulator's set outlet pressure of 80 psig. The
report also had a recorded lock up pressure of 24 psig for its second stage regulator that
exceeded the regulator's set outlet pressure of 12 psig.
7. §192.805 Qualification program.
Each operator shall have and follow a written qualification program. The program
shall include provisions to:
… (b) Ensure through evaluation that individuals performing covered tasks are
qualified;
Hawaii Gas did not ensure through evaluation that individuals performing covered tasks
on its SNG transmission pipeline system were qualified.
Three Hawaii Gas individuals were identified on SNG odorant test site records as having
performed odorization tests between 2011 and 2014. During the Operator Qualification
(OQ) program records review, the PHMSA inspector noted there were no records of
completion of Module 251 “Odorization” by these individuals. Hawaii Gas’ OQ program
uses the Midwest Gas Association (MGA) module list, which includes module 251 and
other covered task modules. Accordingly, the PHMSA inspector was unable to verify if
the three individuals who performed odorization tests between 2011 and 2014 were
qualified to do so.
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8. 9. Additionally, four individuals were identified on the Transmission Line Inspection
Reports D-934-1 as having performed patrolling on the SNG transmission pipeline system
between 2012 and 2014. During the OQ program records review, the PHMSA inspector
noted there were no records of completion of module 271 “Leak Survey and Patrols;”
which is also on the MGA module list. The PHMSA inspector was unable to verify if the
four individuals who performed patrols between 2012 and 2014 were qualified to do so.
§192.907 What must an operator do to implement this subpart?
(a) General. No later than December 17, 2004, an operator of a covered pipeline
segment must develop and follow a written integrity management program that
contains all the elements described in § 192.911 and that addresses the risks on each
covered transmission pipeline segment. The initial integrity management program
must consist, at a minimum, of a framework that describes the process for
implementing each program element, how relevant decisions will be made and by
whom, a time line for completing the work to implement the program element, and
how information gained from experience will be continuously incorporated into the
program. The framework will evolve into a more detailed and comprehensive
program. An operator must make continual improvements to the program.
Hawaii Gas did not follow its written integrity management program (IMP) procedures for
its SNG transmission pipeline system.
Hawaii Gas’ IMP Manual
- Section 3.3 titled “Program Evaluation” stated, “In order to effectively manage IMP
and its performance Hawaii Gas conducts the following activities as part of the
Performance Plan requirements: Annual program review, annual pipeline system
review, and triennial program third-party audit (‘mock’ audit based on PHMSA
Inspection Protocols.)” However, the PHMSA inspector discovered during the IMP
records review that Hawaii Gas did not conduct periodic evaluations of its pipeline
integrity program on an annual basis. The last documented IMP annual review was on
September 19, 2012.
- Section 6.2.3 titled “Roles and Responsibilities” stated, “The IMP Engineer
maintains...current IMP Organizational Chart with names of Hawaii Gas’ personnel
and contractors, vendors, and consulting companies involved in IMP activities." At
the time of the inspection, however, Hawaii Gas did not provide the PHMSA inspector
with an “IMP Organizational Chart.”
§192.917 How does an operator identify potential threats to pipeline integrity and
use the threat identification in its integrity program?
(a) Threat identification. An operator must identify and evaluate all potential threats
to each covered pipeline segment. Potential threats that an operator must consider
include, but are not limited to, the threats listed in ASME/ANSI B31.8S
(incorporated by reference, see §192.7), section 2, which are grouped under the
following four categories:
5



(1) Time dependent threats such as internal corrosion, external corrosion, and
stress corrosion cracking;
(2) Static or resident threats, such as fabrication or construction defects;
(3) Time independent threats such as third party damage and outside force
damage; and
(4) Human error.
Hawaii Gas did not identify and evaluate all potential threats to its SNG transmission
pipeline system.
A review of the Hawaii Gas’ Risk Assessment and P&MM Evaluation Report dated
February 10, 2014 showed no indication that interactive threats were considered by
Hawaii Gas’ subject matter experts. Section 2.5.1 titled “Identification of Potential
Threats” of Hawaii Gas’ IMP Manual dated August, 9, 2012 stated that “the interactive
nature of other threats must also be considered.” Further, ASME/ANSI B31.8S states that
“[t]he interactive nature of threats (i.e., more than one threat occurring on a section of a
pipeline at the same time) shall be considered.”
10. §192.935 What additional preventive and mitigative measures must an operator
take?
(a) General requirements. An operator must take additional measures beyond those
already required by Part 192 to prevent a pipeline failure and to mitigate the
consequences of a pipeline failure in a high consequence area. An operator must base
the additional measures on the threats the operator has identified to each pipeline
segment. (See § 192.917) An operator must conduct, in accordance with one of the
risk assessment approaches in ASME/ANSI B31.8S (incorporated by reference, see §
192.7), section 5, a risk analysis of its pipeline to identify additional measures to
protect the high consequence area and enhance public safety. Such additional
measures include, but are not limited to, installing Automatic Shut-off Valves or
Remote Control Valves, installing computerized monitoring and leak detection
systems, replacing pipe segments with pipe of heavier wall thickness, providing
additional training to personnel on response procedures, conducting drills with local
emergency responders and implementing additional inspection and maintenance
programs.
Hawaii Gas did not provide records or other documentation to demonstrate that it had
taken any additional preventive and mitigative measures (P&MM) beyond those already
required by Part 192 to prevent a pipeline failure and to mitigate the consequences of a
pipeline failure in a high consequence area on its SNG transmission pipeline.
Hawaii Gas failed to provide the P&MM tracking form that was referenced in its Risk
Assessment and P&MM Evaluation Report dated February 10, 2014. The PHMSA
inspector was unable to ascertain if additional P&MM identified in the report had actually
been implemented or scheduled for implementation.
6



11. §192.945 What methods must an operator use to measure program effectiveness?
(a) General. An operator must include in its integrity management program methods
to measure whether the program is effective in assessing and evaluating the integrity
of each covered pipeline segment and in protecting the high consequence areas.
These measures must include the four overall performance measures specified in
ASME/ANSI B31.8S (incorporated by reference, see § 192.7 of this part), section 9.4,
and the specific measures for each identified threat specified in ASME/ANSI B31.8S,
Appendix A. An operator must submit the four overall performance measures as
part of the annual report required by § 191.17 of this subchapter.
Hawaii Gas did not provide records or other documentation to demonstrate that it
measured its integrity management (IM) program’s effectiveness in assessing and
evaluating the integrity of its SNG transmission pipeline and in protecting high
consequence areas.
Hawaii Gas did not provide adequate documentation to demonstrate that its IM program’s
effectiveness performance measures were trended over time or an analysis of these trends.
For example, there were no records to show a trending analysis of equipment or material
failures as a means to evaluate pipeline equipment deterioration or records to trending of
leading indicators such as inadvertent over-pressurization, right-of-way encroachments
without a one-call notification, or other abnormal operating conditions such as those listed
in 192.605(c).
Proposed Civil Penalty
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a
related series of violations. For violations occurring between January 4, 2012 to August 1,
2016, the maximum penalty may not exceed $200.000 per violation per day, with a maximum
penalty not to exceed $2,000,000 for a related series of violations. For violations occurring
prior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per
day, with a maximum penalty not to exceed $1,000,000 for related series of violations. The
Compliance Officer has reviewed the circumstances and supporting documentation involved
in the above probable violations and has recommended that you be preliminarily assessed a
civil penalty of $60,300 as follows:
Item number PENALTY
3 $14,800
6 $14,800
7 $16,900
10 $13,800
Warning Items
With respect to items 1, 4, 5, & 8 we have reviewed the circumstances and supporting
documents involved in this case and have decided not to conduct additional enforcement
action or penalty assessment proceedings at this time. We advise you to promptly correct
these items. Failure to do so may result in additional enforcement action.7



Proposed Compliance Order
With respect to items 2, 3, 6, 7, 9, 10, & 11 pursuant to 49 United States Code § 60118, the
Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance
Order to Hawaii Gas. Please refer to the Proposed Compliance Order, which is enclosed and
made a part of this Notice.
Response to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline
Operators in Compliance Proceedings. Please refer to this document and note the response
options. All material you submit in response to this enforcement action may be made publicly
available. If you believe that any portion of your responsive material qualifies for
confidential treatment under 5 U.S.C. 552(b), along with the complete original document you
must provide a second copy of the document with the portions you believe qualify for
confidential treatment redacted and an explanation of why you believe the redacted
information qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond
within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the
allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to
find facts as alleged in this Notice without further notice to you and to issue a Final Order.
In your correspondence on this matter, please refer to CPF 5-2016-0026 and for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings
cc: PHP-60 Compliance Registry
PHP-500 C. Ishikawa (#147745)
8



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Hawaii Gas a Compliance Order incorporating
the following remedial requirements to ensure the compliance of Hawaii Gas with the pipeline
safety regulations:
1. In regard to Item Number 2 of the Notice pertaining to Hawaii Gas’ failure to keep
records necessary to substantiate how it established the MAOP of its pipeline
system, Hawaii Gas must provide records to PHMSA’s Western Region Director
(Director) to verify how it had previously established the MAOP of its pipeline
system. If Hawaii Gas does not possess MAOP records, it must either develop
written records to accurately document how it had previously established the
MAOP of its pipeline or, if the process by which the MAOP was established is
unknown, it must reestablish the MAOP of the pipeline in accordance with Part
192 and provide the records to the Director.
2. In regard to Item Number 3 of the Notice pertaining to Hawaii Gas’ failure to
follow its manual of written procedures for conducting operations and
maintenance activities on its SNG transmission pipeline system, Hawaii Gas must
train all its operations and maintenance personnel on the proper use of its written
O&M procedures manual to ensure all future odorant tests are performed in
accordance with Hawaii Gas’ written procedures. In addition, Hawaii Gas must
calibrate or verify that all its odorant test equipment has been calibrated within the
times frames specified in its written O&M. Hawaii gas must also conduct an
odorant test of its pipeline system after receipt of this Notice, and provide the
records to the Director.
3. 4. 5. In regard to Item Number 6 of the Notice pertaining to Hawaii Gas’ failure to
ensure that each pressure regulating station and its equipment on its SNG
transmission pipeline system was adequate from the standpoint of capacity and
reliability of operation for the service in which it is employed,, Hawaii Gas must
conduct an inspection and testing of its Malakole Regulator Station and ensure the
lock-up pressure for its first stage regulator is properly set and recorded.
In regard to Item Number 7 of the Notice pertaining to Hawaii Gas’ failure to
ensure through evaluation that individuals performing covered tasks on its SNG
transmission pipeline system were qualified, Hawaii Gas must modify its written
Operator Qualification (OQ) program with procedures designed to ensure that only
properly qualified individuals perform covered tasks on its pipeline system.
In regard to Item Number 9 of the Notice pertaining to Hawaii Gas’ failure to
identify and evaluate all potential threats to its SNG transmission pipeline system,
Hawaii Gas must amend its IM Program to specifically address the form used in its
evaluation titled, Risk Assessment and P&MM Evaluation Report, to show
indications that interactive threats are considered.
9



6. 7. 8. 9. In regard to Item Number 10 of the Notice pertaining to Hawaii Gas’ failure to
provide records or other documentation to demonstrate that it had taken any
additional preventive and mitigative measures (P&MM) beyond those already
required by Part 192, Hawaii Gas must create and provide an up-to-date P&MM
tracking form to the Director, or equivalent documentation, that would show if
additional P&MM were implemented or scheduled for implementation.
In regard to Item Number 11 of the Notice pertaining to Hawaii Gas’ failure to
provide records or other documentation to demonstrate that it measured its IM
program’s effectiveness, Hawaii Gas must gather data and create trending analyses
of equipment or material failures as a means to evaluate pipeline equipment
deterioration and of leading indicators such as inadvertent over-pressurization,
right-of-way encroachments without a one-call notification, or other abnormal
operating conditions such as those listed in 192.605(c). After completion, Hawaii
Gas must provide a written summary of the analyses, including statistical diagrams
or charts, to the Director.
Hawaii Gas must submit new written procedures, records or other documentation
to Chris Hoidal, Director, Western Region, Pipeline and Hazardous Materials
Safety Administration within 90 days of the date of issuance of the Final Order to
show that the above eight (8) items were completed as required by this
Compliance Order.
It is requested (not mandated) that Hawaii Gas maintain documentation of the
safety improvement costs associated with fulfilling this Compliance Order and
submit the total to Chris Hoidal, Director, Western Region, Pipeline and
Hazardous Materials Safety Administration. It is requested that these costs be
reported in two categories: 1) total cost associated with preparation/revision of
plans, procedures, studies and analyses, and 2) total cost associated with
replacements, additions and other changes to pipeline infrastructure.
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520160026_Region Withdrawal of Notice Letter_10212019_text.pdf

WITHDRAWAL of NOTICE LETTER
CERTIFIED MAIL – RETURN RECEIPT REQUESTED AND EMAIL
October 21, 2019
Ms. Alicia Moy
President and Chief Executive Officer
Hawaii Gas
515 Kamakee St
Honolulu, HI 96814
CPF 5-2016-0026
Dear Ms. Moy:
On November 16, 2016, the Pipeline and Hazardous Materials Safety Administration
(PHMSA) issued a Notice of Probable Violation, Proposed Civil Penalty, and Proposed
Compliance Order (Notice) to Hawaii Gas for alleged violations of the pipeline safety
regulations. The alleged violations were identified during inspections on October 20-24 and
October 27-30, 2014 of Hawaii Gas’ 22.6 mile synthetic natural gas (SNG) transmission
pipeline system on the island of Oahu, Hawaii. The inspections were conducted by a
representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA),
Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code.
Hawaii Gas responded to the Notice by letter dated December 16, 2016 (Response) contesting
some of the allegations of violation and providing additional information on how it had or
proposed to correct other violations it was not contesting.
The Director, Western Region, PHMSA, has reviewed the facts and circumstances
surrounding this enforcement matter, including the additional information provided by Hawaii
Gas in its Response and determined that enforcement is not warranted in this case.
Accordingly, the Notice is hereby withdrawn in its entirety and this case is now closed with
no further action required by Hawaii Gas.



If you have any questions concerning this letter, please contact Mr. Dustin Hubbard, Director,
Western Region, PHMSA, at 720-963-3160.
Sincerely,
Dustin Hubbard
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
Mr. Mustafa Demirbag, Executive Director of Operations, Hawaii Gas
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