RICHMOND, CITY OF — Warning Letter

120150009W_Warning Letter_06262015_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 DELIVERY June 26, 2015 Mr. Robert Steidel Director, City of Richmond Department of Public Utilities 730 East Broad Street Richmond, VA 23219 CPF 1-2015-0009W Dear Mr. Steidel: On January 13, 2015, 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 item inspected and the probable violation is: 1. §192.619 Maximum allowable operating pressure: Steel or plastic pipelines. (a) No person may operate a segment of steel or plastic pipeline at a pressure that exceeds a maximum allowable operating pressure determined under paragraph (c) or (d) of this section, or the lowest of the following: (1) The design pressure of the weakest element in the segment, determined in accordance with subparts C and D of this part. However, for steel pipe in pipelines being converted under §192.14 or uprated under subpart K of this part, if any variable necessary to determine the design pressure under the design formula (§192.105) is unknown, one of the following pressures is to be used as design pressure: The City operated a segment of pipeline at a pressure that exceeded the established maximum allowable operating pressure (MAOP). Both the City pressure control and pressure limiting regulators froze in the open position at the City’s Dioceses Regulator Station. The City over-pressured 2,400 feet of a 4 inch steel pipeline.#

120150009W_Warning Letter_06262015_text.pdf, page 2Evidence is based on VA SCC Notice of Investigation (NOI) to the City, and City response to the VA 1-2015-0009W The City piping system was over-pressured to 487 psig for 20 minutes, exceeding the MAOP of 275 psig. No customers were affected or connected to the over pressured section of pipeline. The affected pipeline ran from the supplier to a district regulator station. Both a water bath heater upstream of the regulators and Vortex heaters on the pilots were utilized in an effort to eliminate the possibility of a freeze up situation. 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 1-2015-0009W. 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. Massoud Tahamtani, VA SCC Mr. Jim Fisher, VA SCC 120150009W_WL_06262016 Page 2 of 2#