# PALO ALTO, CITY OF — Warning Letter

- **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:** Not available
- **summary:** CLOSED warning letter citing 192.723(b)(1), 192.747(a).
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- **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.

Official case documents:

520080013W_warning letter_06042008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520080013W/520080013W_warning%20letter_06042008.pdf

520080013W_warning letter_06042008.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
12300 W. Dakota Ave., Suite 110
Lakewood, CO 80228
WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
June 4,2008
Mr. Javad Ghaffari
Manager, Water Gas Wastewater Utilities
City of Palo Alto
250 Hamilton
Palo Alto, CA 94301
CPF 5-2008-0013W
Dear Mr. Ghaffari:
On April 7- 1 1,2008, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected your
gas distribution system in Palo Alto, California.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violations are:
1. 5192.723 Distribution systems: Leakage surveys.
(a) Each operator of a distribution system shall conduct periodic leakage surveys
in accordance with this section.
(b)(l) A leakage survey with leak detector equipment must be conducted in
business districts, including tests of the atmosphere in gas, electric, telephone,
sewer, and water system manholes, at cracks in pavement and sidewalks, and at
other locations providing an opportunity for finding gas leaks, at intervals not
exceeding 15 months, but at least once each calendar year.



2. Annual leak surveys for Palo Alto's business districts exceeded the maximum intervals
contained in 5 192.723(b)(l) during calendar year 2007. Numerous service lines were
not leak-surveyed until late January 2008. An improvement in leak survey record-
keeping will reduce the time required between performance of the activity, review of
survey results, and follow-up of any missed locations.
5192.747 Valve maintenance: Distribution systems.
(a) Each valve, the use of which may be necessary for the safe operation of a
distribution system, must be checked and serviced at intervals not exceeding 15
months, but at least once each calendar year.
According to records available at the time of the inspection, annual valve inspections
were performed late in 2006. For example, Key Valve #26 was serviced on 3-8-05, 12-
7-06, and 5-9-07, exceeding the maximum 15-month interval specified in 5 192.747.
Better scheduling and record-keeping procedures will help prevent the occurrence of late
valve inspections.
Under 49 United States Code, 5 60122, you are subject to a civil penalty not to exceed $100,000
for each violation for each day the violation persists up to a maximum of $1,000,000 for any
related series of violations. We have reviewed the circumstances and supporting documents
involved in this case, and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to correct the items identified in this letter.
Failure to do so will result in the City of Palo Alto being subject to additional enforcement
action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 5-2008-0013W. Be advised that all material you submit in response to this enforcement
action is subject to being made publicly available. If you believe that any portion of your
responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the
complete original document you must provide a second copy of the document with the portions
you believe qualify for confidential treatment redacted and an explanation of why you believe
the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Stahoviak (#I207 17)
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