# DANVILLE, CITY OF — Warning Letter

**Citation:** CPF 120170002W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2017-06-15

CLOSED warning letter citing 192.725(b).

## Document text

Warning Letter involving DANVILLE, CITY OF. PHMSA's enforcement data identifies the cited regulation as 192.725(b). The case was opened on 2017-06-15 and is reported as closed as of 2017-06-15. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120170002W_Warning Letter_06152017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120170002W/120170002W_Warning%20Letter_06152017.pdf

120170002W_Warning Letter_06152017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120170002W/120170002W_Warning%20Letter_06152017_text.pdf

120170002W_Warning Letter_06152017_text.pdf

WARNING LETTER
OVERNIGHT EXPRESS DELIVERY
June 15, 2017
Kelly P. Kinnett, P.E.
Water and Gas Director
City of Danville
1040 Monument Street
Danville, VA 24540
CPF 1-2017-0002W
Dear Mr. Kinnett:
On January 18, 2017, inspectors from the Virginia State Corporation Commission (VA SCC)
acting as Agents for the Pipeline and Hazardous Materials Safety Administration (PHMSA)
pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected the City of Danville’s (City)
records in Danville, VA.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violation(s) are:
1. §192.725(b) Test requirements for reinstating service lines.
(b) Each service line temporarily disconnected from the main must be tested from the
point of disconnection to the service line valve in the same manner as a new service
line, before reconnecting. However, if provisions are made to maintain continuous
service, such as by installation of a bypass, any part of the original service line used
to maintain continuous service need not be tested.
The City failed to test each service line temporarily disconnected from the point of disconnection
to the service line valve in the same manner as a new service line, before reconnecting.



CPF 1-2017-0002W
During the inspection conducted on January 18, 2017, the VA SCC inspector reviewed the City’s
leak records. Work order 170122 (WO), created on February 20, 2016, indicated that the City did
not pressure test a Grade 1 leak at 415 Old Spring Road in the City of Danville to the service line
valve in the same manner as a new service line, before reconnecting.
The WO indicated that a mechanical fitting was removed and reconnected by butt fusing the two
remaining ½‐inch plastic service lines back together. The fusion was soap tested. The line was not
pressure tested back to the service line valve.
The VA SCC issued a Notice of Investigation to the City on January 26, 2017. The City responded
to VA SCC on February 13, 2017. In their response, the City acknowledged that they did not test
the service as required per §192.725 at 415 Old Spring Rd. The City reviewed leaks from 2013 to
2016 to determine if this is an isolated incident or a systemic failure in training.
As of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil
penalty not to exceed $209,002 per violation per day the violation persists up to a maximum of
$2,090,022 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 the City of Danville being subject to additional
enforcement action.
No reply to this letter is required. If you choose to reply, please submit all correspondence in this
matter to Robert Burrough, Acting Director, PHMSA Eastern Region, 820 Bear Tavern Road,
Suite 103, West Trenton, NJ 08628. Please refer to CPF 1- 2017-0002W on each document you
submit, and whenever possible provide a signed PDF copy in electronic format. Smaller files may
be emailed to robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the
original paper copy to the Eastern Region Office.
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,
Robert Burrough
Acting Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
120170002W_Warning Letter_06152017_text (MR) Page 2 of 2

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/120170002W>
- Source ID: `phmsa-enforcement`
- SHA-256: `c0ed8ca4f30da2993f4a415020407b737bec98637dbe776188f6efb38ced6eda`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T16:46:52.850Z
- Document slug: `phmsa-enforcement-120170002w`

### Source metadata

```json
{
  "cpf": "120170002W",
  "operator": "DANVILLE, CITY OF",
  "region": "Eastern",
  "pipelineType": "GAS INTRASTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.725(b)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
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      "name": "120170002W_Warning Letter_06152017.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/120170002W/120170002W_Warning%20Letter_06152017.pdf",
      "bytes": 175922,
      "category": "agency_document"
    },
    {
      "name": "120170002W_Warning Letter_06152017_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/120170002W/120170002W_Warning%20Letter_06152017_text.pdf",
      "bytes": 113406,
      "category": "agency_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "DANVILLE, CITY OF"
}
```
