{"operation":"document","citation":"CPF 12021003WL","title":"RICHMOND, CITY OF — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-02-05","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021003wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021003wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021003wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021003WL","body":"Warning Letter involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2021-02-05 and is reported as closed as of 2021-02-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021003WL_Warning Letter_02052021_(20-172182).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021003WL/12021003WL_Warning%20Letter_02052021_(20-172182).pdf\n\n12021003WL_Warning Letter_02052021_(20-172182)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021003WL/12021003WL_Warning%20Letter_02052021_(20-172182)_text.pdf\n\n12021003WL_Warning Letter_02052021_(20-172182)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL: Calvin.Farr@richmondgov.com\nFebruary 5, 2021\nCalvin Farr Jr.\nDirector - City of Richmond DPU\nCity of Richmond\n730 East Broad Street\nRichmond, VA 23219\nCPF 1-2021-003-WL\nDear Calvin Farr:\nFrom April 6, 2020 to June 23, 2020, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected City of Richmond’s (City) procedures and activities in Glen Allen, 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 item inspected and\nthe probable violation is:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each\npipeline, a manual of written procedures for conducting operations and\nmaintenance activities and for emergency response. For transmission\nlines, the manual must also include procedures for handling abnormal\noperations. This manual must be reviewed and updated by the operator\nat intervals not exceeding 15 months, but at least once each calendar\nyear. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\nThe City failed to follow for each pipeline, a manual of written procedures for conducting\noperations and maintenance activities. Specifically, the City failed to follow the manufacturer’s\n\n\n\nCPF 1-2021-003-WL\ninstructions for a stab fitting, as required by the City’s Natural Gas Procedure Manual, Procedure\nNumber 11.3.111, Construction of Services (Construction Procedure).\nThe Construction Procedure, Section IV.B.2. of Volume II stated in part, “Follow all manufacturer\ninstruction when fusing or installing fittings.” The Installation Instructions for the Honeywell\nPerfection PERMASERT® 2.0 Non-Corrosive Mechanical Coupling states in part, “2. Wipe the\ntubing with a dry, clean cloth.”\nDuring the inspection, the VA SCC inspector observed the City installing a stab fitting as part of\nthe construction of a new service line. The VA SCC inspector observed the crew foreman cut,\nchamfer, and mark the service line piping in preparation to join it to an excess flow valve with a\nstab fitting. Prior to inserting the piping into the stab fitting, the inspector observed the crew\nforeman wipe the piping with his hand and insert it into the fitting. The pipe was not wiped with\na dry, clean cloth as per the manufacturer instructions.\nTherefore, City failed to follow for each pipeline, a manual of written procedures for conducting\noperations and maintenance activities.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related\nseries of violations. For violation occurring on or after November 27, 2018 and before July 31,\n2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum\npenalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before\nNovember 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a\nmaximum penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015,\nthe maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty\nnot to exceed $2,000,000 for a related series of violations. We have reviewed the circumstances\nand supporting documents involved in this case, and have decided not to conduct additional\nenforcement 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 City of Richmond being subject to\nadditional enforcement action.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you must\nprovide 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, 840 Bear Tavern Road, Suite 300,\nWest Trenton, NJ 08628. Please refer to CPF 1-2021-003-WL 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 USB flash drive accompanied by the\noriginal paper copy to the Eastern Region Office.\n12021003WL_Warning Letter_02052021_(20-172182)_text Page 2 of 3\n\n\n\nCPF 1-2021-003-WL\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n12021003WL_Warning Letter_02052021_(20-172182)_text Page 3 of 3","truncated":false,"body_characters":5953}