{"operation":"document","citation":"CPF 120100003W","title":"RICHMOND, CITY OF — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-05-03","effective_on":null,"summary":"CLOSED warning letter citing 192.303, 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120100003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120100003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120100003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120100003W","body":"Warning Letter involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulations as 192.303,  192.605(a). The case was opened on 2010-05-03 and is reported as closed as of 2010-05-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120100003W_Warning Letter_05032010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120100003W/120100003W_Warning%20Letter_05032010.pdf\n\n120100003W_Warning Letter_05032010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120100003W/120100003W_Warning%20Letter_05032010_text.pdf\n\n120100003W_Warning Letter_05032010_text.pdf\n\nU.S. Department 820 Bear Tavern Road, Suite 306\nOf Transportation West Trenton, NJ 08628\nPipeline and 609.989.2171\nHazardous Materials\nSafety Administration\nWARNING LETTER\nEXPRESS OVERNIGHT DELIVERY\nMay 3, 2010\nMr. Christopher L. Beschler\nDirector, Department of Public Utilities\nDeputy Chief Administrative Officer,\nCity of Richmond\nDepartment of Public Utilities\n730 East Broad Street, 6th Floor\nRichmond, VA 23219\nCPF 1-2010-0003W\nBetween December 5, 2006, and May 1, 2007, a State Inspector from the Virginia State\nCorporation Commission (VA SCC) acting as Agent for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nyour pipeline facilities in Richmond, VA.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1. § 192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this part.\nThe City of Richmond’s (City) contractor (RTS Construction) failed to follow comprehensive\nwritten welding specifications by exceeding the maximum welding rod size approved for the\nwelding procedure.\n\n\n\nCPF 1-2010-0003W\nOn December 5, 2006, the VA SCC inspector observed contractor welding operations in the\n1100 block of East Broad Street in Richmond, Virginia. Visual inspection indicated that a 3/16”\ndiameter welding rod was being used for the hot pass of the welding operation. The maximum\nsize rod permitted by the welding procedure for this pass was 5/32”. The welding procedure\nused was “Welding Procedure Specification (WPS) No. SMAW-Butt-42K-1”, dated August 4,\n2005. The contractor welder acknowledged the use of the wrong size rod for the welding\nprocedure.\n2. §192.605 Procedural manual for operations, maintenance, and emergencies.\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 procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once each calendar year.\nThis manual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\nThe City’s contractor (RTS Construction) failed to follow comprehensive written procedures by\nnot reaming the ends of an existing steel service to remove rough edges prior to insertion of a 1\ninch plastic service piping as required by the City’s O&M Manual, Chapter 3, Section III.\nOn December 12, 2006, the VA SCC inspector observed the City’s contractor replacing a steel\nservice with plastic pipe at 13 Lexington Road in Richmond, and noticed a damaged section of\n1inch plastic pipe. Apparently, the damage resulted from a failure to ream the old steel pipe\nservice ends prior to inserting the plastic pipe. The RTS foreman stated that he did not ream the\nends of the pipe because he did not have a reaming tool. The RTS foreman left the job site to\nacquire a reaming tool. When he returned to the job site, he reamed the ends of the steel pipe,\nand inserted a new section of 1 inch plastic piping.\n3. §192.605 Procedural manual for operations, maintenance, and emergencies.\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 procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once each calendar year.\nThis manual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\n120100003W_Warning Letter_05032010 Page 2 of 3\n\n\n\nCPF 1-2010-0003W\nThe City’s contractor (Trafford Construction) failed to follow comprehensive written procedures,\nby not properly setting a holiday detector to the correct voltage as required by the City’s O&M\nManual, Chapter 3, Section II.\nOn May 1, 2007, the VA SCC inspector observed the pipe coating jeeping operations of the\nCity’s contractor at Hungary Road in Henrico County, Virginia. The holiday detector used for\njeeping the pipe was set to 6,500 volts, and the jeeping of the main had already begun. The\nvoltage setting for jeeping the fusion bonded epoxy coating on the 8 inch main should have been\nset between 1,600 to 3,000 volts. The VA SCC inspector discussed the observed conditions with\nthe contractor, and with a City representative.\nThe holiday detector manufacturer’s voltage setting sheet, supplied to the VA SCC inspector at\nthe job site, listed the 1,600 to 3,000 volt setting for fusion bonded epoxy pipe.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the items identified in this letter.\nFailure to do so will result in the City being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2010-0003W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nByron E. Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCc: Jim Hotinger, VA SCC\n120100003W_Warning Letter_05032010 Page 3 of 3","truncated":false,"body_characters":7240}