RICHMOND, CITY OF — Warning Letter

120150002W_Warning Letter_02122015_text.pdf, page 1Official PDFU.S. Department Of Transportation Pipeline and 609.989.2171 Hazardous Materials Safety Administration 820 Bear Tavern Road, Suite 103 West Trenton, NJ 08628 WARNING LETTER OVERNIGHT EXPRESS MAIL February 12, 2015 Mr. Robert Steidel Director, City of Richmond Department of Public Utilities 730 East Broad Street Richmond, VA 23219 CPF 1-2015-0002W Dear Mr. Steidal: Between February 24 and August 7, 2014, an inspector from the Virginia State Corporation Commission (VA SCC) acting as Agent for the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code inspected the City of Richmond’s (City) pipeline facilities in Richmond, Virginia. As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation(s) are: 1. §192.605 Procedural manual for operations, maintenance, and emergencies. (b) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations. (3) Making construction records, maps, and operating history available to appropriate operating personnel. The City failed to make accurate construction records, maps, and operating history available to appropriate operating personnel. The City’s GIS mapping system had an incorrect valve (retired valve on an old system that was indicated as an active valve on a live system) that the City attempted to utilize to stop a gas leak. Evidence is based on VA SCC Notice of Investigation (NOI) to the City, and City responses to the VA SCC NOI. We understand that the City has corrected the map in question.#

120150002W_Warning Letter_02122015_text.pdf, page 21-2015-0002W 2. §192.285 Plastic pipe: Qualifying persons to make joints. c) A person must be requalified under an applicable procedure, if during any 12-month period that person: (1) Does not make any joints under that procedure; or The City failed to re-qualify an individual to perform mechanical joints during any 12-month period in which that individual does not make any joints under that procedure. During this inspection on August 7, 2014, VA SCC staff witnessed a Willbros T & D Services crew installing mechanical joints on a 4 inch plastic main line. The crew foreman performing the joining did not have a current plastic joining task certification card. The foreman’s qualification had expired on July 17, 2014, 20 days prior to the date of that the joining work was being done. After this discovery, joints previously completed by the foreman were removed and re- installed by an individual on the crew that had current qualifications. Evidence is based on VA SCC Notice of Investigation (NOI) to the City, and City responses to the VA SCC NOI. Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per violation per day the violation persists up to a maximum of $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 the City being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, please address your correspondence to: Byron Coy, PE, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, W. Trenton, NJ 08628 and please refer to CPF 1-2015-0002W. 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). Additionally, if you choose to respond to this (or any other case), please ensure that any response letter pertains solely to one CPF case number. Sincerely, Byron Coy, PE Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Cc: Mr. James Hotinger, VA SCC 120150002W_WL_02122015 Page 2 of 2#