# RICHMOND, CITY OF — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120150011
- **title:** RICHMOND, CITY OF — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2015-09-03
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.725(b).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-120150011.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120150011.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120150011
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120150011
**body:**

Notice of Probable Violation involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulation as 192.725(b). The case was opened on 2015-09-03 and is reported as closed as of 2016-06-16. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120150011_Closure Letter_06162016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150011/120150011_Closure%20Letter_06162016.pdf

120150011_Closure Letter_06162016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150011/120150011_Closure%20Letter_06162016_text.pdf

120150011_Final Order_04262016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150011/120150011_Final%20Order_04262016.pdf

120150011_Final Order_04262016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150011/120150011_Final%20Order_04262016_text.pdf

120150011_NOPV_PCO_09032015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150011/120150011_NOPV_PCO_09032015.pdf

120150011_NOPV_PCO_09032015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150011/120150011_NOPV_PCO_09032015_text.pdf

120150011_Operator Response to Notice_12172015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150011/120150011_Operator%20Response%20to%20Notice_12172015.pdf

120150011_Closure Letter_06162016_text.pdf

OVERNIGHT EXPRESS DELIVERY
June 16, 2016
Mr. Robert Steidel
Director, City of Richmond
Department of Public Utilities
730 East Broad Street
Richmond, VA 23219
CPF 1-2015-0011
Dear Mr. Steidel:
On April 26, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
to the City of Richmond, Virginia (City) a Final Order in the above-referenced case. This Order
included a Compliance Order. Based on our review of the documentation the City provided, it has
been determined that the City has complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Byron Coy, PE
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Cc: Mr. Massoud Tahamtani, VA SCC
Mr. Jim Fisher, VA SCC
Mr. Drew Eaken, VA SCC

120150011_Final Order_04262016_text.pdf

April 26, 2016
Mr. Robert Steidel
Director
City of Richmond
Department of Public Utilities
730 East Broad Street
Richmond, VA 23219
Re: CPF No. 1-2015-0011
Dear Mr. Steidel:
Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of
violation and specifies actions that need to be taken by the City of Richmond to comply with the
pipeline safety regulations. When the terms of the compliance order have been completed, as
determined by the Director, Eastern Region, this enforcement action will be closed. Service of
the Final Order by certified mail is deemed effective upon the date of mailing, or as otherwise
provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Byron Coy, Director, Eastern Region, OPS
Mr. Massoud Tahamtani, Director, Virginia State Corporation Commission, Division of
Utility and Railroad Safety, P.O. Box 1197, Richmond, VA 23218-1197
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
In the Matter of )
City of Richmond, Virginia ) CPF No. 1-2015-0011
a municipal corporation, )
Respondent. )
)
)
)
)
FINAL ORDER
On February 12, 2015, pursuant to 49 U.S.C. § 60117, a representative of the Virginia State
Corporation Commission (VA SCC), acting as an agent of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline
safety inspection of the facilities and records of the City of Richmond (City or Respondent) in
Richmond, Virginia. The City of Richmond’s system is a municipally-owned gas distribution
system consisting of approximately 1,865 miles of main pipelines and 91,487 miles of service
pipelines.1
As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,
by letter dated September 3, 2015, a Notice of Probable Violation and Proposed Compliance
Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that the
City had violated 49 C.F.R. § 192.725(b) and proposed ordering Respondent to take certain
measures to correct the alleged violation.
The City responded to the Notice by letter dated December 17, 2015 (Response). The City did
not contest the allegation of violation, but provided information concerning the corrective actions
it had taken and submitted copies of its relevant procedures. Respondent did not request a
hearing and, therefore, has waived its right to one.
1 See Pipeline Safety Violation Report (Violation Report), (July 16, 2014) (on file with PHMSA), at 1.



CPF No. 1-2015-0011
2
FINDING OF VIOLATION
In its Response, the City did not contest the allegation in the Notice that it violated 49 C.F.R.
Part 192, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.725(b), which states:
§ 192.725 Test requirements for reinstating service lines.
(a) ….
(b) Each service line temporarily disconnected from the main must be
tested from the point of disconnection to the service line valve in the same
manner as a new service line, before reconnecting. However, if provisions
are made to maintain continuous service, such as by installation of a
bypass, any part of the original service line used to maintain continuous
service need not be tested.
The Notice alleged that Respondent violated 49 C.F.R. § 192.725(b) by failing to test each
service line temporarily disconnected from the main from the point of disconnection to the
service line valve in the same manner as a new service line, before reconnecting. Specifically,
the Notice alleged that the Respondent failed to pressure test two lines after each was installed
prior to reconnecting the lines to the main. The Notice stated the lines were disconnected on
May 13, 2014 and November 8, 2014, respectively, but pressure tests were not conducted on
either line until after the VA SCC inspection on February 12, 2015.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.725(b) by failing to test two
service lines that had been disconnected from the main prior to reconnecting.
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Item 1 in the Notice for violation of
49 C.F.R. § 192.725(b). Under 49 U.S.C. § 60118(a), each person who engages in the
transportation of gas or who owns or operates a pipeline facility is required to comply with the
applicable safety standards established under chapter 601. The Director has indicated that
Respondent has taken the following action specified in the proposed compliance order:
1. With respect to the violation of § 192.725(b) (Item 1), Respondent has provided
relevant portions of its Utility Natural Gas Procedures Manual and its City Operator
Qualification (OQ) materials and training guides used to qualify personnel
responsible for leak repairs and reinstating service on the City’s service lines.



CPF No. 1-2015-0011
3
Accordingly, I find that compliance has been achieved with respect to this violation, in part.
Therefore, a portion of the compliance terms proposed in the Notice for Item 1 are not included
in this Order.
As for the remaining compliance terms, pursuant to the authority of 49 U.S.C. § 60118(b) and
49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance
with the pipeline safety regulations applicable to its operations:
1. With respect to the violation of § 192.725(b) (Item 1), Respondent shall conduct
refresher training for all personnel responsible for leak repairs and reinstating service
on City service lines.
2. The City shall submit documentation that training was completed to PHMSA
Eastern Region within 180 days of receipt of this Final Order. The documentation
shall include at minimum: name(s) of instructor(s), names of trainees, date(s) of
training, and trainee signatures.
3. It is requested (not mandated), that Respondent maintain documentation of the
safety improvement costs associated with fulfilling this Final Order and submit the
total to Mr. Byron Coy, Director, Eastern Region, Pipeline and Hazardous Materials
Safety Administration. It is requested these costs be reported in two categories:
1) total costs associated with preparation/revision of plans, procedures, studies and
analyses; and 2) total cost associated with replacements, additions and other changes
to pipeline infrastructure.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
Failure to comply with this Order may result in administrative assessment of civil penalties not
to exceed $200,000 for each violation for each day the violation continues or in referral to the
Attorney General for appropriate relief in a district court of the United States.
The terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
__________________________________ ________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety
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