# HAWAII GAS — Warning Letter

- **operation:** document
- **citation:** CPF 520170002W
- **title:** HAWAII GAS — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2017-02-09
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.195(b), 192.355(b).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520170002w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520170002w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520170002w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520170002W
**body:**

Warning Letter involving HAWAII GAS. PHMSA's enforcement data identifies the cited regulations as 192.195(b),  192.355(b). The case was opened on 2017-02-09 and is reported as closed as of 2017-02-09. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520170002W_Warning Letter_02092017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170002W/520170002W_Warning%20Letter_02092017.pdf

520170002W_Warning Letter_02092017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520170002W/520170002W_Warning%20Letter_02092017_text.pdf

520170002W_Warning Letter_02092017_text.pdf

WARNING LETTER
VIA FED EX – TRACKING # 7783 9512 7666
February 9, 2017
Ms. Alicia Moy
President & CEO
Hawaii Gas
745 Fort Street Mall, Ste. 1800
Honolulu, HI 96813
CPF 5-2017-0002W
Dear Ms. Moy:
On February 22-26, 2016, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
Oahu Natural Gas distribution system in Oahu, Hawaii.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violations are:
1. §192.355 Customer meters and regulators: Protection from damage.
(b) Service regulator vents and relief vents. Service regulator vents and relief
vents must terminate outdoors, and the outdoor terminal must— (1) Be rain and
insect resistant; (2) Be located at a place where gas from the vent can escape
freely into the atmosphere and away from any opening into the building; and (3)
Be protected from damage caused by submergence in areas where flooding may
occur.



Service regulator vents were found to be near building openings. The vent from service
regulator (meter #127137) was closer than 18" to a window air-conditioner. This service
regulator was located at 528 Manancia Place, Honolulu, Hawaii. Additionally, a service
regulator vent at 2865A Hapue Loop, Halawa Heights, Oahu, Hawaii was also noted to be
near a window. These conditions and other similar ones need to be corrected.
2. §192.195 Protection against accidental over pressuring.
(b) Additional requirements for distribution systems. Each distribution system
that is supplied from a source of gas that is at a higher pressure than the
maximum allowable operating pressure for the system must— (1) Have pressure
regulation devices capable of meeting the pressure, load, and other service
conditions that will be experienced in normal operation of the system, and that
could be activated in the event of failure of some portion of the system; and (2) Be
designed so as to prevent accidental overpressuring.
The monitor regulator at regulator station R-16 Middle & N King Street in Honolulu, Hawaii
was not functioning at the time of inspection, due to dirty plugged sensing lines. The operator
felt that dirt was interfering with the function of the pilot of the monitor regulator. A non-
functioning monitor regulator would not prevent accidental over-pressuring the system,
should the worker regulator fail. This condition and other similar conditions at other regulator
stations must be corrected.
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 violation 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 a related series of violations. 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 correct the item(s) identified in this letter. Failure to do so will
result in Hawaii Gas being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 5-2017-0002W. Be advised that all material you submit in response to this
enforcement action is subject to being 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).
Sincerely,
Chris Hoidal,
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 D. Hassell (#151680)
- **truncated:** false
- **body characters:** 5064
