{"operation":"document","citation":"CPF 120150012W","title":"RICHMOND, CITY OF — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-09-03","effective_on":null,"summary":"CLOSED warning letter citing 192.619(a)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120150012w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120150012w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120150012w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120150012W","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 2015-09-03 and is reported as closed as of 2015-09-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120150012W_Warning Letter_09032015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150012W/120150012W_Warning%20Letter_09032015.pdf\n\n120150012W_Warning Letter_09032015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120150012W/120150012W_Warning%20Letter_09032015_text.pdf\n\n120150012W_Warning Letter_09032015_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\nSeptember 03, 2015\nMr. Robert Steidel\nDirector, City of Richmond\nDepartment of Public Utilities\n730 East Broad Street\nRichmond, VA 23219\nCPF 1-2015-0012W\nDear Mr. Steidel:\nOn April 22, 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 or\nuprated under subpart K of this part, if any variable necessary to determine the design pressure\nunder the design formula (§192.105) is unknown, one of the following pressures is to be used as\ndesign pressure. . .\nThe City operated a segment of pipeline at a pressure that exceeded the maximum allowable operating\npressure determined under §192.619(a)(1).\nWhile preparing to blow down approximately 500 feet of high pressure City main, the City over-\npressured a low pressure (LP) cast iron system when a City employee opened a regulator station tap valve\non an intermediate pressure (IP) line that was connected to a City 12 inch LP main. The pressure of the\nLP piping reached approximately 21 inches of water column. The MAOP of the LP system is 12 inches\nof water column.\nDuring the inspection, the VA SCC interviewed City personnel and took photos of the City computer\nscreens. Based on the data shown on the computer screens, discussions with City personnel, and system\n\n\n\n1-2015-0012W\ntelemetry, the LP system was over-pressured for approximately 25 minutes. A City employee opened the\nregulator station block valve to purge the 500 feet of intermediate pressure (IP) City main without\nverifying that a station bypass valve was closed. The bypass valve was actually in the open position,\nwhich connected the IP blow down gas (at 22 psig) to a City 12 inch LP main. This action caused a\nmomentary over-pressurization of the LP distribution system.\nEvidence is based on the VA SCC Notice of Investigation (NOI) to the City, and the City response to the\nVA SCC NOI, City procedures, VA SCC photographs, and interviews with City personnel.\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 1-2015-0012W. 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\n120150012W_Warning Letter_09032015 Page 2 of 2","truncated":false,"body_characters":5586}