{"operation":"document","citation":"CPF 120160003W","title":"DANVILLE, CITY OF — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-03-03","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120160003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120160003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120160003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120160003W","body":"Warning Letter involving DANVILLE, CITY OF. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2016-03-03 and is reported as closed as of 2016-03-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120160003W_Operator Response to Notice_03142016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120160003W/120160003W_Operator%20Response%20to%20Notice_03142016.pdf\n\n120160003W_Warning Letter_03032016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120160003W/120160003W_Warning%20Letter_03032016.pdf\n\n120160003W_Warning Letter_03032016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120160003W/120160003W_Warning%20Letter_03032016_text.pdf\n\n120160003W_Warning Letter_03032016_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nMarch 03, 2016\nMr. Jason Grey\nDirector of Utilities\nCity of Danville, VA\n1040 Monument Street\nDanville, VA 24540\nCPF 1-2016-0003W\nDear Mr. Grey:\nOn January 26, 2016, an inspector from the Virginia State Corporation Commission (VA SCC) acting as\nAgent for the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter\n601 of 49 United States Code, inspected the City of Danville’s (City) leakage repair records in Danville,\nVirginia.\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 items inspected and the probable violation(s)\nare:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of written\nprocedures for conducting operations and maintenance activities and for emergency response. For\ntransmission lines, the manual must also include procedures for handling abnormal operations.\nThis manual must be reviewed and updated by the operator at intervals not exceeding 15 months,\nbut at least once each calendar year. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\nThe City failed to follow its operations and maintenance (O&M) plan. The City’s Natural Gas O&M\nPlan, Chapter 2, Section G-6, 3.7.3 Revision 2, dated 3/20/2015 states in part: “Where there is residual\ngas in the ground after the repair of a Grade 1 leak, a follow-up inspection shall be made as soon as\npracticable after allowing the soil atmosphere to vent and stabilize. The follow-up inspection should be\nperformed within fifteen (15) days from the date of repair not to exceed thirty (30) days.”\nDuring the inspection conducted on January 26, 2016, the VA SCC inspector reviewed the City’s leak\nrepair records for 2015. The VA SCC identified five grade 1 leaks that were not rechecked within 15\ndays from the date of the repair.\n\n\n\n1-2016-0003W\nEvidence is based on VA SCC Notice of Investigation (NOI) report to the City, and City response to the\nVA 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.\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. We\nhave reviewed the circumstances and supporting documents involved in this case, and have decided not to\nconduct additional enforcement action or penalty assessment proceedings at this time. We advise you to\ncorrect the item identified in this letter. Failure to do so will result in the City being subject to additional\nenforcement 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 1-2016-0003W. 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, P.E.\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nCc: Mr. Massoud Tahamtani, VA SCC\nMr. Jim Fisher, VA SCC\nMr. Drew Eaken, VA SCC\n120160003W_Warning Letter_03032016 Page 2 of 2","truncated":false,"body_characters":4990}