{"operation":"document","citation":"CPF 120150010W","title":"RICHMOND, CITY OF — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-08-24","effective_on":null,"summary":"CLOSED warning letter citing 192.455(a)(2), 192.605(b)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120150010w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120150010w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120150010w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120150010W","body":"Warning Letter involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulations as 192.455(a)(2),  192.605(b)(3). The case was opened on 2015-08-24 and is reported as closed as of 2015-08-24. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120150010W_Warning Letter_08242015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150010W/120150010W_Warning%20Letter_08242015.pdf\n\n120150010W_Warning Letter_08242015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150010W/120150010W_Warning%20Letter_08242015_text.pdf\n\n120150010W_Warning Letter_08242015_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\nAugust 24, 2015\nMr. Robert Steidel\nDirector, City of Richmond\nDepartment of Public Utilities\n730 East Broad Street\nRichmond, VA 23219\nCPF 1-2015-0010W\nDear Mr. Steidel:\nOn February 12, 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 Safety\n(OPS), pursuant to Chapter 601 of 49 United States Code inspected the City of Richmond’s (City) pipeline\nfacilities 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. §192.455 External corrosion control: Buried or submerged pipelines installed after July 31, 1971.\n(a) Except as provided in paragraphs (b), (c), and (f) of this section, each buried or submerged pipeline\ninstalled after July 31, 1971, must be protected against external corrosion, including the following:\n(2) It must have a cathodic protection system designed to protect the pipeline in accordance with this\nsubpart, installed and placed in operation within 1 year after completion of construction.\nThe City failed on two occasions to have a cathodic protection system designed to protect the pipeline in\naccordance with this subpart, installed and placed in operation within 1 year after completion of construction\n(City leak records #576281 and #575621):\nCity leak record #576281: VA SCC inspector found that a City steel main constructed on Queens Thorpe\nCourt in 1972 had no cathodic protection. The City had scheduled this line for replacement prior to the VA\nSCC inspection on February 12, 2015.\nCity leak record #575621: VA SCC inspector found that a two inch steel main constructed on Greendale\nRoad in 1966, with a main extension constructed in 1972, has no cathodic protection. The City has scheduled\nthis line for replacement. VA SCC identified the missed main extension constructed during the VA SCC\ninspection on February 12, 2015.\nEvidence is based on the VA SCC Notice of Investigation (NOI) to the City, City leak records, and the City\nresponse to the VA SCC NOI.\n\n\n\n1-2015-0010W\n2. 192.605 Procedural manual for operations, maintenance, and emergencies.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of this section must\ninclude procedures for the following, if applicable, to provide safety during maintenance and\noperations.\n(3) Making construction records, maps, and operating history available to appropriate operating\npersonnel.\nThe City failed to make accurate construction records, maps, and operating history available to appropriate\noperating personnel (City leak record #576281).\nRegarding City leak record #576281, the VA SCC inspector observed that the mapping of this segment of\nline stated that the line was 1 ¼ inch diameter cast iron, when it actually was 1-½ inch diameter coated steel.\nThe probable violation has existed since 1972. The City has corrected the incorrect map.\nEvidence is based on the VA SCC Notice of Investigation (NOI) to the City, City leak record, and the City\nresponse to the VA SCC 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. For\nviolations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation\nper day, with a maximum penalty not to exceed $1,000,000 for a related series of violations. We have\nreviewed the circumstances and supporting documents involved in this case, and have decided not to conduct\nadditional enforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem(s) identified in this letter. Failure to do so will result in the City being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, please address your correspondence to: Byron Coy,\nPE, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, W. Trenton, NJ 08628 and please\nrefer to CPF 1-2015-0010W. Be advised that all material you submit in response to this enforcement action\nis subject to being made publicly available. If you believe that any portion of your responsive material\nqualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential treatment\nunder 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\n120150010W Page 2 of 2","truncated":false,"body_characters":5925}