{"operation":"document","citation":"CPF 120170005W","title":"DANVILLE, CITY OF — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-12-18","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120170005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120170005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120170005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120170005W","body":"Warning Letter involving DANVILLE, CITY OF. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2017-12-18 and is reported as closed as of 2017-12-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120170005W_Warning Letter_12182017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120170005W/120170005W_Warning%20Letter_12182017.pdf\n\n120170005W_Warning Letter_12182017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120170005W/120170005W_Warning%20Letter_12182017_text.pdf\n\n120170005W_Warning Letter_12182017_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nDecember 18, 2017\nKelly P. Kinnett, P.E.\nWater and Gas Director\nCity of Danville\n1040 Monument Street\nDanville, VA 24540\nCPF 1-2017-0005W\nDear Mr. Kinnett:\nOn June 20, 2017, inspectors from the Virginia State Corporation Commission (VA SCC) acting\nas Agents for the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to\nChapter 601 of 49 United States Code (U.S.C.) inspected the City of Danville’s (City) renewal of\nthe service line located at 417 South Woodbury Avenue, Danville, VA.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violation(s) are:\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\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once each calendar year.\nThis manual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\nThe City failed to follow its manual of written procedures for conducting maintenance activities.\nSpecifically, the City failed to follow Section 3.12.6.2 of its Natural Gas Operation and\nMaintenance Plan Chapter II Part F-Construction, dated 01/16/2017, (Procedure) while renewing\nthe service line at 417 South Woodbury Avenue, Danville, VA.\n\n\n\nCPF 1-2017-0005W\nDuring the inspection, PHMSA inspector reviewed the City’s Procedure. Section 3.12.6.2\nPreventing Pipe Damage stated in part:\n“(3) Locate the squeeze-off tool a minimum of 3x the pipe diameter, or 12-inches, whichever is\ngreater, from any fusion joint, mechanical connection, prior squeeze-off point, or second squeeze-\noff tool.”\nThe PHMSA inspector observed a squeeze-off operation during a service renewal at 417 South\nWoodbury Avenue, Danville, VA. The squeeze-off was not located at the minimum required\ndistance from a mechanical connection.\nTherefore, the City failed to follow its Procedure regarding preventing pipe damage during\nmaintenance activities.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related\nseries of violations. For violations occurring prior to November 2, 2015, the maximum penalty\nmay not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000\nfor a related series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in the City being subject to additional enforcement action.\nPlease be advised that all material you submit in response to this enforcement action is subject to\nbeing made publicly available. If you believe that any portion of your responsive material qualifies\nfor 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\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. 552(b).\nNo reply to this letter is required. If you choose to reply, please submit all correspondence in this\nmatter to Robert Burrough, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103,\nWest Trenton, NJ 08628. Please refer to CPF 1-2017-0005W on each document you submit, and\nwhenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed\nto robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the original\npaper copy to the Eastern Region Office.\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120170005W_Warning Letter_12182017_text\nPage 2 of 2","truncated":false,"body_characters":5255}