{"operation":"document","citation":"CPF 120130010","title":"DANVILLE, CITY OF — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-12-23","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.483(c), 192.727(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120130010.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120130010.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120130010","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120130010","body":"Notice of Probable Violation involving DANVILLE, CITY OF. PHMSA's enforcement data identifies the cited regulations as 192.483(c),  192.727(d). The case was opened on 2013-12-23 and is reported as closed as of 2017-05-19. Proposed civil penalty: $18,700. Assessed civil penalty: $0. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120130010_Closure Letter_05192017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120130010/120130010_Closure%20Letter_05192017.pdf\n\n120130010_Closure Letter_05192017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120130010/120130010_Closure%20Letter_05192017_text.pdf\n\n120130010_Consent Agreement and Order_07192016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120130010/120130010_Consent%20Agreement%20and%20Order_07192016.pdf\n\n120130010_Consent Agreement and Order_07192016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120130010/120130010_Consent%20Agreement%20and%20Order_07192016_text.pdf\n\n120130010_NOPV PCP_12232013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120130010/120130010_NOPV%20PCP_12232013.pdf\n\n120130010_NOPV PCP_12232013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120130010/120130010_NOPV%20PCP_12232013_text.pdf\n\n120130010_Operator Response  Request for Hearing_01232014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120130010/120130010_Operator%20Response%20%20Request%20for%20Hearing_01232014.pdf\n\n120130010_Consent Agreement and Order_07192016_text.pdf\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, DC 20590\nIn the Matter of )\nCity of Danville, Virginia, ) CPF No. 1-2013-0010\na municipal corporation, )\nRespondent. )\n)\n)\n)\n)\nCONSENT AGREEMENT AND ORDER\nOn May 8, 2013, pursuant to Chapter 601 of 49 United States Code, inspectors from the Virginia\nState Corporation Commission (VA SCC), acting as agents for the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), inspected the City\nof Danville’s (City or Respondent) pipeline facilities in Danville, Virginia. The City’s pipeline\nfacilities consist of approximately 359 miles of distribution mains, 26 district regulators to\nsupply gas at necessary pressures, and gas-storage capacity.\nAs a result of this inspection, the Director, Eastern Region, Office of Pipeline Safety (Director),\nissued to Respondent, by letter dated December 23, 2013, a Notice of Probable Violation and\nProposed Civil Penalty (Notice), which also included a warning pursuant to 49 C.F.R. § 190.205,\na copy of which is attached hereto as Appendix A. In accordance with 49 C.F.R. § 190.207, the\nNotice proposed finding that Respondent had committed two violations of 49 C.F.R. Part 192 and\nproposed assessing a civil penalty of $18,700 for one of the alleged violations. The warning item\nrequired no further action, but warned the operator to correct the probable violation.\nThe City responded to the Notice by letter dated January 23, 2014 (Response), and requested a\nhearing, which was held on September 11, 2014. Respondent has proposed, as part of this\nproceeding and two unrelated enforcement actions, CPF No. 1-2012-0006 and CPF No. 1-2013-\n0009, to resolve these matters via administrative consent agreements.\nHaving agreed that settlement of this proceeding will avoid further administrative proceedings or\nlitigation, pursuant to 49 C.F.R. Part 190, and upon consent and agreement of Respondent and\nPHMSA (collectively, the Parties), the Parties hereby agree as follows:\nA. General Provisions.\n1. Respondent acknowledges that its pipeline system is subject to the jurisdiction of\nthe federal Pipeline Safety Laws, 49 U.S.C. 60101, et seq., and the regulations and administrative\n\n\n\nCPF No. 1-2013-0010\n2\norders issued thereunder. As used in this Consent Agreement and Order (Agreement), the terms\n“pipeline system” and “pipeline facility” shall be defined as in 49 C.F.R. Part 192. Respondent\nacknowledges that it received proper notice of PHMSA’s action in this proceeding and that the\nNotice states claims upon which relief may be granted pursuant to 49 U.S.C. 60101, et seq., and\nthe regulations and orders issued thereunder.\n2. Respondent consents to the issuance of this Agreement and hereby waives any\nfurther procedural requirements with respect to its issuance. Respondent waives all rights to\ncontest the adequacy of notice or the validity of this Agreement, including all rights to\nadministrative or judicial hearings, reviews, or appeals.\n3. This Agreement shall apply to and be binding upon PHMSA and Respondent, its\nofficers, directors, and employees, and its successors, assigns, or other entities or persons\notherwise bound by law. Respondent agrees to provide a copy of this Agreement and any\nincorporated work plans and schedules to all City officers, employees, agents, and successors-in-\ninterest whose duties might reasonably include compliance with this Agreement.\n4. This Agreement constitutes the final, complete, and exclusive agreement and\nunderstanding between the Parties with respect to the settlement embodied in this Agreement, and\nthe Parties acknowledge that there are no representations, agreements, or understandings relating\nto the settlement other than those expressly contained in this Agreement and its appendices.\n5. Nothing in this Agreement affects or relieves the City of its responsibility to\ncomply with all applicable requirements of the federal Pipeline Safety Laws, 49 U.S.C. § 60101,\net seq., and the regulations and orders issued thereunder. Nothing in this Agreement alters\nPHMSA’s right of access, entry, inspection, and information-gathering or its authority to bring\nany enforcement action against Respondent pursuant to the federal Pipeline Safety Laws, the\nregulations and orders issued thereunder, or any other provision of federal or state law.\n6. This Agreement does not waive or modify any federal, state, or local laws or\nregulations that are applicable to the City or its pipeline system. This Agreement is not a permit,\nor a modification of any permit, under any federal, state, or local laws or regulations.\nRespondent remains responsible for achieving and maintaining compliance with all applicable\nfederal, state, and local laws, regulations and permits.\n7. This Agreement does not create rights in, or grant any cause of action to, any third\nparty not a party to this Agreement. The U.S. Department of Transportation (DOT) is not liable\nfor any injuries or damages to persons or property arising from acts or omissions of Respondent\nor its officers, employees, agents, or successors-in-interest in carrying out the work required by\nthis Agreement. The City agrees to hold harmless DOT, its officers, employees, agents, and\nrepresentatives from any and all causes of action arising from any acts or omissions of\nRespondent or its contractors in carrying out the work required by this Agreement.\n8. The Parties agree that the facts as alleged in each item of the Notice are true and\ncorrect and that each item may be considered by PHMSA to be a prior offense in any future\nPHMSA enforcement action taken against the City.\n\n\n\nCPF No. 1-2013-0010\n3\n9. Respondent agrees to complete the corrective actions specified in Section B\n(Additional Work to be Performed) of this Agreement.\n10. Respondent agrees that the activities described in Section B of this Agreement, and\nin all work plans and schedules incorporated thereunder, are not required by any federal, state, or\nlocal law or regulation and do not include actions which Respondent would likely be required to\nperform:\na. as injunctive relief, including as a mitigation project, in the instant case;\nb. as injunctive relief in any other existing legal action initiated by PHMSA or\nany other regulatory agency against Respondent;\nc. as part of an existing settlement or order in another legal action; or\nd. under any other federal, state, or local requirement.\nB. Additional Work to be Performed.\n11. Respondent agrees to perform the actions set forth in the Work Plan, incorporated\nherein as Appendix B to this Agreement. Respondent will complete the actions described in\nPart 2 of the Work Plan (General Information and Proposed Action Description) and will adhere\nto the schedule set forth in Part 3 of the Work Plan (Project Schedule).\n12. Respondent agrees to revise the Work Plan as necessary to incorporate new\ninformation obtained during the evaluations and remedial activities performed under the Work\nPlan. Respondent shall submit any such plan revisions to the Director for prior approval. The\nDirector may approve Work Plan revision elements incrementally.\n13. The Director may grant an extension of time for completion of any of the work to\nbe performed under this Section B (Additional Work to be Performed) upon Respondent’s timely,\nwritten request that demonstrates both good cause for an extension and provides sufficient detail\nto enable the Director to evaluate Respondent’s request.\n14. Respondent agrees to maintain documentation of the costs associated with\nimplementation of the Work Plan and agrees to make this information available to PHMSA upon\nrequest.\nC. Review and Approval Process.\n15. With respect to any submission by the City under Section B (Additional Work to\nbe Performed) of this Agreement that requires the approval of the Director, the Director may:\n(a) approve, in whole or in part, the submission; (b) disapprove the submission on specified\nconditions; (c) disapprove, in whole or in part, the submission; or (d) any combination of the\nforegoing. In the event of approval in whole, in part, or upon conditions, the City will proceed to\ntake all actions required by the submission as modified by the Director, subject to Respondent’s\nright to invoke the procedures in Section D (Dispute Resolution) with respect to any conditions\nidentified by the Director. In the event that the Director does not approve all or any portion of a\n\n\n\nCPF No. 1-2013-0010\n4\nsubmission, the Director will provide the City with a written notice of the deficiencies.\nRespondent will correct all deficiencies within the time specified by the Director and resubmit it\nfor acceptance. If Respondent fails to correct the specified deficiencies, the Director may invoke\nthe dispute resolution process provided in Section D below.\nD. Dispute Resolution.\n16. The Director and Respondent will attempt to informally resolve any disputes\narising under this Agreement. If the City and the Director are unable to informally resolve the\ndispute within 15 business days, Respondent may request in writing, within 10 business days, a\nwritten determination resolving the dispute by the Associate Administrator for Pipeline Safety,\nPHMSA. Along with its request, Respondent will provide the Associate Administrator with all\ninformation Respondent believes is relevant to the dispute. If the request is submitted as\nprovided herein, the Associate Administrator will issue a written determination that shall\nconstitute final agency action. The existence of a dispute and PHMSA’s consideration of\nmatters placed in dispute shall not excuse, toll, or suspend any term or timeframe for completion\nof any work to be performed under this Agreement during the pendency of the dispute resolution\nprocess, except as agreed by the Regional Director or the Associate Administrator in writing.\nE. Enforcement.\n17. This Agreement, including all plans and schedules incorporated by reference, is\nsubject to all enforcement authorities available to PHMSA under 49 U.S.C. § 60101, et seq., and\n49 C.F.R. Part 190, including administrative civil penalties under 49 U.S.C. § 60122, of up to\n$200,000 per violation for each day the violation continues and referral of the case to the\nAttorney General for judicial enforcement, if PHMSA determines that Respondent is not\ncomplying with the terms of this Agreement in accordance with determinations made by the\nDirector, or if appealed, in accordance with decisions of the Associate Administrator. All other\nwork plans and associated schedules developed under Section B shall be automatically\nincorporated into this Agreement and are enforceable in the same manner.\nF. Civil Penalties.\n18. PHMSA agrees to withdraw the civil penalty for Item 1, proposed in the Notice, in\nexchange for completion of the Project Schedule outlined in Part 3 of the Work Plan.\n19. If the Work Plan is not implemented within the timeframe contemplated in the\nProject Schedule, subject to any extensions approved by the Director, PHMSA reserves the right\nto take further enforcement action, including assessment of the civil penalties proposed in the\nNotice.\nG. Miscellaneous.\n20. Respondent agrees to maintain records demonstrating compliance with all\nrequirements of this Agreement for a period of at least five years following completion of all\nwork to be performed. PHMSA and the VA SCC will have the right to inspect the records and\nfacilities of the City, or any contractor, agent, or successor-in-interest thereof, upon reasonable\n\n\n\nCPF No. 1-2013-0010\n5\nnotice, to confirm that the compliance terms of this Agreement are being undertaken in\nconformity with the terms of this Agreement.\n21. Except as otherwise provided herein, this Agreement may be modified only by the\nmutual agreement of the Parties as set forth in writing and signed by the Parties.\n22. Each undersigned representative of the Parties certifies that he is fully authorized\nby the party represented to enter into the terms and conditions hereof and to execute and legally\nbind that party to it.\n23. Respondent certifies that it is not a party to any open federal financial assistance\ntransaction that is funding or could fund the same activities described in this Agreement,\nincluding all activities described in the Work Plan or any other incorporated plan or schedule.\nRespondent further certifies that it has inquired of City departments and of any parties acting on\nthe behalf of the City whether they are a party to any open federal financial assistance transaction\nthat is funding or could fund the same activities described in this Agreement, and has been\ninformed by said parties that they are not subject to such a transaction.\nH. Effective Date and Term.\n24. The “Effective Date,” as used herein, is the date on which this Agreement is\nsigned by both Respondent and PHMSA. Unless otherwise specified, all deadlines for actions\nrequired by the Agreement run from the Effective Date.\nI. Termination.\n25. This Agreement will terminate upon the completion of all terms set forth in\nSection B (Additional Work to Be Performed), as determined by the Director. Respondent may\nrequest, and PHMSA will provide, written confirmation of the termination of this Agreement.\nNothing in this Agreement prevents Respondent from completing any of the obligations earlier than\nthe deadlines provided for herein.\nThe Parties hereby agree to all conditions and terms of this Agreement:\nFor PHMSA: For City of Danville, Virginia:\n_______________________________ _________________________________\nAlan K. Mayberry Name: ___________________________\nActing Associate Administrator for Title: ___________________________\nPipeline Safety, PHMSA City of Danville, Virginia\n\n\n\nCPF No. 1-2013-0010\n6\nAPPENDIX A\n\n\n\nNOTICE OF PROBABLE VIOLATION\nand\nPROPOSED CIVIL PENALTY\nOVERNIGHT EXPRESS MAIL\nDecember 23, 2013\nMr. Steve Saum, Dir. Of Utilities\nCity of Danville, VA\n1040 Monument St.\nDanville, VA 24541\nCPF 1-2013-0010\nDear Mr. Saum:\nOn May 8, 2013, an inspector from the Virginia State Corporation Commission (VA SCC) acting\nas Agent for the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to\nChapter 601 of 49 United States Code inspected the City of Danville’s (City) pipeline facilities\nin Danville, 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 violation(s) are:\n1. § 192.483 Remedial measures: General.\n(c) Except for cast iron or ductile iron pipe, each segment of buried or submerged pipe\nthat is required to be repaired because of external corrosion must be cathodically\nprotected in accordance with this subpart.\nThe City of Danville (City) failed to cathodically protect, in accordance with Subpart I, each\nsegment of buried or submerged pipe that is required to be repaired because of external\ncorrosion. Specifically, the City repaired a segment of externally corroded buried pipe and failed\non one occasion to cathodically protect the pipe as required by §192.483(c) after corrosion was\nfound.\nOn 11/15/2011, the City repaired a corrosion leak on a 2 inch bare steel service line with a leak\nclamp. On 5/23/2013, after the finding was identified during the 5/8/2013 VA SCC inspection,\nthe City replaced the service line with plastic pipe.\n2. § 192.727 Abandonment or deactivation of facilities\n(d) Whenever service to a customer is discontinued, one of the following must be\ncomplied with:\n\n\n\n1-2013-0010\n(1) The valve that is closed to prevent the flow of gas to the customer must be\nprovided with a locking device or other means designed to prevent the opening of the\nvalve by persons other than those authorized by the operator.\n(2) A mechanical device or fitting that will prevent the flow of gas must be installed in\nthe service line or in the meter assembly.\n(3) The customer's piping must be physically disconnected from the gas supply and\nthe open pipe ends sealed.\nThe City failed on one occasion to secure a deactivated service line as required by\n§192.727(d)(1) through §192.727(d)(3).\nSpecifically, the City did not secure the deactivated service line when the City removed a meter\nfrom a service line at 321 Moffett Street on 12/12/2011. The supply valves on the inlet and\noutlet of the pressure regulator were shutoff, however the valves were not locked and the end of\nthe service line was open to the atmosphere.\nThe City deactivated the service line at 321 Moffett Street incorrectly on 12/12/2011. The City\ncorrectly secured the deactivated service 5/8/2013, after the finding was discovered during the\n5/8/13 VA SCC inspection.\nThe City did not have a work order on the meter removal, nor did the City know the names of the\nCity personnel who removed the meter.\nProposed Civil Penalty\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. The Compliance Officer has reviewed the circumstances and\nsupporting documentation involved in the above probable violations and has recommended that\nyou be preliminarily assessed a civil penalty of $18,700 as follows:\nItem number PENALTY\n1 $18,700\nWarning Items\nWith respect to item 2, we have reviewed the circumstances and supporting documents involved\nin this case and have decided not to conduct additional enforcement action or penalty assessment\nproceedings at this time. We advise you to promptly correct this item. Failure to do so may\nresult in additional enforcement action.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators\nin Compliance Proceedings. Please refer to this document and note the response options. All\nmaterial submit in response to this enforcement action may be made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. 552(b). If you do not respond within 30 days of receipt of this Notice, this\n\n\n\n1-2013-0010\nconstitutes a waiver of your right to contest the allegations in this Notice and authorizes the\nAssociate Administrator for Pipeline Safety to find facts as alleged in this Notice without further\nnotice to you and to issue a Final Order.\nIn your correspondence on this matter, please refer to CPF 1-2013-0010, and for each document\nyou submit, please provide a copy in electronic format whenever possible, and please whenever\npossible provide a signed PDF copy in electronic format. Smaller files may be emailed to\nByron.Coy@dot.gov. Larger files should be sent on a CD accompanied by the original paper\ncopy to the Eastern Region Office.\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number.\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCc: James Hotinger, VA SCC\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n\n\n\nCPF No. 1-2013-0010\n7\nAPPENDIX B\n\n\n\nCPF No. 1-2013-0010\n8\nWork Plan for the development and implementation of a plan for replacement or\nabandonment of bare steel customer services.\nCity of Danville, Virginia\nCPF 1-2013-0010\n1. Introduction\nThe U.S. Department of Transportation's Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) has allowed the City of Danville, Virginia (City), the opportunity to\nperform the following supplemental safety actions as an alternative to paying a proposed civil\npenalty for alleged violations of the pipeline safety regulations in 49 C.F.R. Part 192. The City\nis to perform these risk-mitigating actions relative to the violations, which improve the continued\nsafe operations of the natural gas distribution and provide value that offsets the proposed civil\npenalties. Should PHMSA determine that the proposed actions provide safety and/or\nenvironmental value beyond the enforcement of the civil penalty, the City will enter into a\nConsent Agreement with PHMSA to perform the proposed actions within agreed-upon time\nframes.\n2. General Information and Proposed Action Description\nPHMSA’s Notice of Probable Violation in CPF 1-2013-0010 identified two items of probable\nviolation and included a proposed civil penalty for the first item. In the first item, PHMSA\nalleged that the City failed to cathodically protect each segment of buried or submerged pipe that\nis required to be repaired because of external corrosion, in violation of 49 C.F.R. § 192.483(c).\nThe probable violation was identified at one location (101 Marshall Terrace) and included a\nproposed civil penalty of $18,700. The second item resulted in a warning to correct its failure to\nsecure, on one occasion at one location (321 Moffett Street), a deactivated service line as\nrequired by 49 C.F.R. § 192.727(d)(1) through (3).\nThe City has reviewed potential remedial actions which could be performed by the City and used\nin the development of a Consent Agreement with PHMSA. Following consideration, it has been\ndetermined that the best remedial action aligned with the probable violation is development and\nimplementation of a training program for all construction and maintenance personnel in the\nCity's Water and Gas Engineering Department. The training program will focus on the repair of\nsteel customer-service pipeline segments and the evaluation and considerations for cathodic\ncontrol measures on these pipeline segments. The Water and Gas Engineering Department and\nthe Corrosion Department will be responsible for coordination, development and implementation\nof the training program. All training will be performed on-site in a classroom setting. Records\nof attendance and training content will be documented.\nIn addition to development and implementation of a training program, the City will replace\nremaining bare steel services in the City's natural gas system and provide training for the City’s\npersonnel.\nThe City's Water and Gas Engineering Department, with the assistance of a qualified outside\nconsultant, will develop a formal risk-based plan for the replacement or abandonment of all bare\nsteel customer service pipeline segments. The risk-based analysis and prioritization will be\n\n\n\nCPF No. 1-2013-0010\n9\ncorrelated to the pipe age, leak history, type of structure serviced, status of service, and other\nfactors. The plan shall include a replacement schedule that is anticipated to be completed within\nthree (3) years with a replacement ratio of 50% (year 1), 25% (year 2) and 25% (year 3).\nReplacement or abandonment of bare steel services for years 2 and 3 will be performed outside\nof the proposed action for development of the Consent Agreement. The City plans to utilize the\nservices of RK&k of Richmond, Virginia, to assist in preparing the plan.\n3.\nProject Schedule\nReplacement Program\nEstimated schedule:\nProgram Development:\nJuly 1, 2016 through August 1, 2016\nYear 1 Replacement:\nSeptember 1, 2016 through June 30, 2017\nYear 2 Replacement:\nJuly 1, 2017 through June 30, 2018\nYear 3 Replacement:\nJuly 1, 2018 through June 30, 2019\nTraining Program\nEstimated schedule**:\nTraining Program Development:\nJuly 1, 2016 through September 30, 2016\nOn-Site Training:\nOctober 1, 2016 through November 30, 2016\nEstimated Project Costs\nThe estimated costs for work associated with the replacement program are as follows:\nDevelopment of Replacement Program Plan\nConsultant (RK&K)\n$2,500\nCity Personnel\n$9,600\nService Replacement (labor and materials)\nSubtotal Estimated Cost\n$60,000\n$72,100\nThe estimated costs for work associated with personnel training are as follows:\nTraining program development\n$3,610\nCity personnel training\n$3,000\nSubtotal Estimated Cost\n$6,610\nTotal Estimated Cost\n$78,710\n** The City plans to compress the schedule for the training program development and implementation. The City\nreserves the right to adjust the actual schedule to accommodate this goal.\n\n120130010_Closure Letter_05192017_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nMay 19, 2017\nKelly P. Kinnett, P.E.\nWater and Gas Director\nCity of Danville\n1040 Monument Street\nDanville, VA 24540\nCPF 1-2013-0010\nDear Mr. Kinnett:\nOn July 19, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued\nto the City of Danville (City) a Consent Agreement and Order in the above-referenced case. Based\non our review of the documentation the City provided, it has been determined that the City has\ncomplied with the terms of the Consent Agreement and Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\ncc: Mr. Massoud Tahamtani, VA SCC\nMr. Drew Eaken, VA SCC","truncated":false,"body_characters":27051}