{"operation":"document","citation":"CPF 520080013W","title":"PALO ALTO, CITY OF — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-06-04","effective_on":null,"summary":"CLOSED warning letter citing 192.723(b)(1), 192.747(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080013w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080013w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080013w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520080013W","body":"Warning Letter involving PALO ALTO, CITY OF. PHMSA's enforcement data identifies the cited regulations as 192.723(b)(1),  192.747(a). The case was opened on 2008-06-04 and is reported as closed as of 2008-06-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520080013W_warning letter_06042008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520080013W/520080013W_warning%20letter_06042008.pdf\n\n520080013W_warning letter_06042008.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W. Dakota Ave., Suite 110\nLakewood, CO 80228\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJune 4,2008\nMr. Javad Ghaffari\nManager, Water Gas Wastewater Utilities\nCity of Palo Alto\n250 Hamilton\nPalo Alto, CA 94301\nCPF 5-2008-0013W\nDear Mr. Ghaffari:\nOn April 7- 1 1,2008, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your\ngas distribution system in Palo Alto, California.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1. 5192.723 Distribution systems: Leakage surveys.\n(a) Each operator of a distribution system shall conduct periodic leakage surveys\nin accordance with this section.\n(b)(l) A leakage survey with leak detector equipment must be conducted in\nbusiness districts, including tests of the atmosphere in gas, electric, telephone,\nsewer, and water system manholes, at cracks in pavement and sidewalks, and at\nother locations providing an opportunity for finding gas leaks, at intervals not\nexceeding 15 months, but at least once each calendar year.\n\n\n\n2. Annual leak surveys for Palo Alto's business districts exceeded the maximum intervals\ncontained in 5 192.723(b)(l) during calendar year 2007. Numerous service lines were\nnot leak-surveyed until late January 2008. An improvement in leak survey record-\nkeeping will reduce the time required between performance of the activity, review of\nsurvey results, and follow-up of any missed locations.\n5192.747 Valve maintenance: Distribution systems.\n(a) Each valve, the use of which may be necessary for the safe operation of a\ndistribution system, must be checked and serviced at intervals not exceeding 15\nmonths, but at least once each calendar year.\nAccording to records available at the time of the inspection, annual valve inspections\nwere performed late in 2006. For example, Key Valve #26 was serviced on 3-8-05, 12-\n7-06, and 5-9-07, exceeding the maximum 15-month interval specified in 5 192.747.\nBetter scheduling and record-keeping procedures will help prevent the occurrence of late\nvalve inspections.\nUnder 49 United States Code, 5 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated 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 items identified in this letter.\nFailure to do so will result in the City of Palo Alto being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2008-0013W. Be advised that all material you submit in response to this enforcement\naction 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\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Stahoviak (#I207 17)","truncated":false,"body_characters":4220}