{"operation":"document","citation":"CPF 120150009W","title":"RICHMOND, CITY OF — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-06-26","effective_on":null,"summary":"CLOSED warning letter citing 192.619(a)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120150009w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120150009w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120150009w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120150009W","body":"Warning Letter involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulation as 192.619(a)(1). The case was opened on 2015-06-26 and is reported as closed as of 2015-06-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120150009W_Warning Letter_06262015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150009W/120150009W_Warning%20Letter_06262015.pdf\n\n120150009W_Warning Letter_06262015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150009W/120150009W_Warning%20Letter_06262015_text.pdf\n\n120150009W_Warning Letter_06262015_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\nJune 26, 2015\nMr. Robert Steidel\nDirector, City of Richmond\nDepartment of Public Utilities\n730 East Broad Street\nRichmond, VA 23219\nCPF 1-2015-0009W\nDear Mr. Steidel:\nOn January 13, 2015, an inspector from the Virginia State Corporation Commission (VA SCC) acting as\nAgent for the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline\nSafety (OPS), pursuant to Chapter 601 of 49 United States Code inspected the City of Richmond’s (City)\npipeline 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 item inspected and the probable violation is:\n1. §192.619 Maximum allowable operating pressure: Steel or plastic pipelines.\n(a) No person may operate a segment of steel or plastic pipeline at a pressure that exceeds a\nmaximum allowable operating pressure determined under paragraph (c) or (d) of this section, or\nthe lowest of the following:\n(1) The design pressure of the weakest element in the segment, determined in accordance with\nsubparts C and D of this part. However, for steel pipe in pipelines being converted under §192.14\nor uprated under subpart K of this part, if any variable necessary to determine the design\npressure under the design formula (§192.105) is unknown, one of the following pressures is to be\nused as design pressure:\nThe City operated a segment of pipeline at a pressure that exceeded the established maximum allowable\noperating pressure (MAOP).\nBoth the City pressure control and pressure limiting regulators froze in the open position at the City’s\nDioceses Regulator Station. The City over-pressured 2,400 feet of a 4 inch steel pipeline.\n\n\n\nEvidence is based on VA SCC Notice of Investigation (NOI) to the City, and City response to the VA\n1-2015-0009W\nThe City piping system was over-pressured to 487 psig for 20 minutes, exceeding the MAOP of 275 psig.\nNo customers were affected or connected to the over pressured section of pipeline. The affected pipeline\nran from the supplier to a district regulator station. Both a water bath heater upstream of the regulators\nand Vortex heaters on the pilots were utilized in an effort to eliminate the possibility of a freeze up\nsituation.\nSCC NOI.\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 1-2015-0009W. 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: Mr. Massoud Tahamtani, VA SCC\nMr. Jim Fisher, VA SCC\n120150009W_WL_06262016 Page 2 of 2","truncated":false,"body_characters":5017}