{"operation":"document","citation":"CPF 120150007W","title":"RICHMOND, CITY OF — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-03-17","effective_on":null,"summary":"CLOSED warning letter citing 192.455(a)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120150007w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120150007w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120150007w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120150007W","body":"Warning Letter involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulation as 192.455(a)(2). The case was opened on 2015-03-17 and is reported as closed as of 2015-03-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120150007W_Warning Letter_03172015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150007W/120150007W_Warning%20Letter_03172015.pdf\n\n120150007W_Warning Letter_03172015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150007W/120150007W_Warning%20Letter_03172015_text.pdf\n\n120150007W_Warning Letter_03172015_text.pdf\n\nU.S. Department Of Transportation Pipeline and 609.989.2171\nHazardous Materials\nSafety Administration\n820 Bear Tavern Road, Suite 103\nWest Trenton, NJ 08628\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nMarch 17, 2015\nMr. Robert Steidel\nDirector, City of Richmond\nDepartment of Public Utilities\n730 East Broad Street\nRichmond, VA 23219\nCPF 1-2015-0007W\nDear Mr. Steidal:\nBetween June 3 and 6, 2013, an inspector from the Virginia State Corporation Commission (VA SCC)\nacting as Agent for the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of\nPipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code inspected the City of\nRichmond’s (City) pipeline facilities in Richmond, Virginia.\nAs a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation(s)\nare:\n1. §192.455 External corrosion control: Buried or submerged pipelines installed after July\n31, 1971.\na) Except as provided in paragraphs (b), (c), and (f) of this section, each buried or submerged\npipeline installed after July 31, 1971, must be protected against external corrosion, including the\nfollowing:\n(2) It must have a cathodic protection system designed to protect the pipeline in accordance with\nthis subpart, installed and placed in operation within 1 year after completion of construction.\nThe City failed on one occasion to have a cathodic protection (CP) system, designed to protect its pipeline\nin accordance with this subpart, installed and placed in operation within 1 year after completion of\nconstruction on a buried pipeline installed after July 31, 1971.\nThe City did not put a ¾” diameter coated steel service line under CP within one year after completion of\nconstruction as required by §192.455(a)(2).\nThe service line located at 6100 Belmont Rd, Richmond, VA was installed in 1979. At the time of the\nVASCC inspection, there was no CP installed.\nEvidence is based on VA SCC Notice of Investigation (NOI) to the City, and City responses to the VA\nSCC NOI. We understand that the service line to 6100 Belmont Road was replaced on 08/31/2013 with\nplastic.\n\n\n\n1-2015-0007W\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per\nviolation per day the violation persists up to a maximum of $2,000,000 for a related series of violations.\nFor violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per\nviolation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time. We advise\nyou to correct the item(s) identified in this letter. Failure to do so will result in the City being subject to\nadditional enforcement action.\nNo reply to this letter is required. If you choose to reply, please address your correspondence to: Byron\nCoy, PE, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, W. Trenton, NJ 08628\nand please refer to CPF 1-2015-0007W. Be advised that all material you submit in response to this\nenforcement action 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 complete\noriginal document you must provide a second copy of the document with the portions you believe qualify\nfor confidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response letter\npertains solely to one CPF case number.\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCc:\nMr. Massoud Tahamtani, VA SCC\nMr. Jim Fisher, VA SCC\n120150007W_WL_03172015 Page 2 of 2","truncated":false,"body_characters":4746}