{"operation":"document","citation":"CPF 120100006W","title":"RICHMOND, CITY OF — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-10-13","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a), 192.725(a), 192.739(a), 192.747(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120100006w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120100006w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120100006w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120100006W","body":"Warning Letter involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.725(a),  192.739(a),  192.747(a). The case was opened on 2010-10-13 and is reported as closed as of 2010-10-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120100006W_Warning Letter_10132010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120100006W/120100006W_Warning%20Letter_10132010.pdf\n\n120100006W_Warning Letter_10132010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120100006W/120100006W_Warning%20Letter_10132010_text.pdf\n\n120100006W_Warning Letter_10132010_text.pdf\n\nU.S. Department 820 Bear Tavern Road, Suite 103\nOf Transportation West Trenton, NJ 08628\nPipeline and 609.989.2171\nHazardous Materials\nSafety Administration\nWARNING LETTER\nUPS OVERNIGHT DELIVERY\nOctober 13, 2010\nMr. Christopher L. Beschler\nDirector Department of Public Utilities\nDeputy Chief Administrative Officer\nCity of Richmond\nDepartment of Public Utilities\n400 Jefferson Davis Highway\nRichmond, VA 23224\nCPF 1-2010-0006W\nDear Mr. Beschler:\nBetween June 9, 2006 and August 8, 2008, a State Inspector from the Virginia State Corporation\nCommission (VA SCC) acting as Agent for the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\npipeline facilities in the City of Richmond (City), Virginia.\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. § 192.725 Test requirements for reinstating service lines.\n(a) Except as provided in paragraph (b) of this section, each disconnected service\nline must be tested in the same manner as a new service line, before being\nreinstated.\n\n\n\nCPF 1-2010-0006W\nThe City’s contractor (Henkels & McCoy) failed to test each disconnected service line in the\nsame manner as a new service line, before being reinstated at 12113 Morestead Court in Henrico\nCounty.\nOn June 9, 2006 the VA SCC inspector visited the site location, observed the actions of the crew,\ntook photographs, and brought this issue to the attention of City representatives, and to the City’s\ncontractor who then took action to test the disconnected service line in accordance with the code\nrequirement. The VA SCC also followed-up with correspondence to the City.\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\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once 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.\nThe City’s contractor (Trafford) failed to follow City operations and maintenance (O&M)\nprocedures by not performing tests as required with a combustible gas indicator and oxygen\nanalyzer before entering an excavation at the intersection of Creighton Road and Cedar Fork\nRoad in Henrico County, VA.\nOn September 25, 2007 the VA SCC inspector visited the site location, observed the actions of\nthe contractor crew, and brought this issue to the attention of a City representative, and to the\nCity’s contractor who then took a combustible gas indicator reading in the 6 ft. excavation which\nindicated no presence of natural gas. The VA SCC followed-up with correspondence to the City\nregarding this matter.\n3. § 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—\nPage 2 of 4\n120100006W_Warning Letter_10132010\n\n\n\nCPF 1-2010-0006W\n(1) In good mechanical condition;\n(2) Adequate from the standpoint of capacity and reliability of operation for the\nservice in which it is employed;\n(3) Except as provided in paragraph (b) of this section, set to control or relieve at\nthe correct pressure consistent with the pressure limits of §192.201(a); and\n(4) Properly installed and protected from dirt, liquids, or other conditions that\nmight prevent proper operation.\nThe City failed to inspect each pressure limiting station, relief device, and pressure regulating\nstation and its equipment at intervals not exceeding 15 months, but at least once each calendar\nyear at regulator station numbers 73 & 74 as required by the code.\nThe VA SCC inspector noted this finding during the 2008 inspection of City records. The VA\nSCC followed-up with correspondence to the City regarding this matter.\n4. § 192.747 Valve maintenance: Distribution systems.\n(a) Each valve, the use of which may be necessary for the safe operation of a\ndistribution system, must be checked and serviced at intervals not exceeding 15\nmonths, but at least once each calendar year\nThe City failed to check and service each valve, the use of which may be necessary for the safe\noperation of a distribution system, at intervals not exceeding 15 months, but at least once each\ncalendar year, for critical valve numbers 551 & 761.\nThe VA SCC inspector noted this finding during the 2008 inspection of City records. The VA\nSCC followed-up with correspondence to the City regarding this matter.\n5. § 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\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once 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.\nPage 3 of 4\n120100006W_Warning Letter_10132010\n\n\n\nCPF 1-2010-0006W\nThe City’s contractor (Henkels & McCoy) failed to correctly install an excess flow valve in\naccordance with written manufacturer’s procedures, and as required by City’s O&M procedures.\nThe City contractor installed an excess flow valve backwards at 1121 Hyde Lane in Henrico\nCounty, Virginia.\nThe VA SCC inspector noted this finding during the 2008 inspection of City records. The VA\nSCC followed-up with correspondence to the City regarding this matter.\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 of Richmond, VA being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2010-0006W. 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: VA SCC\nPage 4 of 4\n120100006W_Warning Letter_10132010","truncated":false,"body_characters":8417}