{"operation":"document","citation":"CPF 520120018W","title":"CITY OF VICTORVILLE — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-08-23","effective_on":null,"summary":"CLOSED warning letter citing 192.225(a), 192.615(b)(2), 192.615(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520120018w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520120018w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520120018w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520120018W","body":"Warning Letter involving CITY OF VICTORVILLE. PHMSA's enforcement data identifies the cited regulations as 192.225(a),  192.615(b)(2),  192.615(c). The case was opened on 2012-08-23 and is reported as closed as of 2012-08-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520120018W_warning letter_08232012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520120018W/520120018W_warning%20letter_08232012.pdf\n\n520120018W_warning letter_08232012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520120018W/520120018W_warning%20letter_08232012_text.pdf\n\n520120018W_warning letter_08232012_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 23, 2012\nMr. Joe Flores\nPublic Works Manager\nCity of Victorville\nMunicipal Utility Services\n14343 Civic Drive\nVictorville, CA 92392\nCPF 5-2012-0018W\nDear Mr. Flores:\nFrom December 12 to December 15, 2011, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected your gas pipeline distribution system in Victorville, 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\nthe probable violation(s) are:\n1. 192.615 Emergency Plans\n(b) Each operator shall:\n(2) Train the appropriate operating personnel to assure that they are\nknowledgeable of the emergency procedures and verify that the training is\neffective.\n\n\n\nDuring the inspection, the City of Victorville was unable to provide training records showing\nthat the appropriate operating personnel were trained and knowledgeable in their emergency\nprocedures for the years 2010 and 2011. However, they were able to produce training records\nshowing proper training of the operating personnel for 2009. They also failed to follow their\nown Emergency Response Plan, Section A, issued March 2, 2007, which states that training\nshall be conducted annually with provisions for integrating emergency plan revision as\nnecessary.\n2. 192.615 Emergency Plans\n(c) Each operator shall establish and maintain liaison with appropriate fire,\npolice, and other public officials to:\nDuring the inspection, the City of Victorville was unable to provide records showing\nestablished liaison with local authorities. They also failed to follow their own Emergency\nResponse Plan, Section A, issued March 2, 2007, which states that annually they must\nestablish and maintain liaison with appropriate local civil authorities.\n3. 192.225 Welding Procedures\n(a) Welding must be performed by a qualified welder in accordance with\nwelding procedures qualified under section 5 of API 1104 (incorporated by\nreference, see § 192.7) or section IX of the ASME Boiler and Pressure Vessel\nCode “Welding and Brazing Qualifications” (incorporated by reference, see §\n192.7) to produce welds meeting the requirements of this subpart.\nOur inspections could not confirm that the welding conducted your contractor utilized the\ncorrect welding procedures. During the inspection, the City of Victorville provided 39\nwelding procedures that did not meet the qualifications of API Standard 1104. These welding\nprocedures were from their contractor, Sunrise Engineering, Inc. They stated that all welding\nconducted on their system was accomplished by this contractor. The procedures grouped the\nwall thickness of the pipe into one variable of .188 through .750 inches instead of grouping\nthem per the API Standard 1104. API Standard 1104 specifies if there is a change from one\nwall thickness group to another, the welder using the new procedures must be requalified.\nThe groups are defined as follows:\n1. 2. 3. Nominal pipe wall thickness less than 1/16 inches\nNominal pipe wall thickness from 1/16 inch through ¼ inch\nNominal pipe wall thickness greater than ¼ inch.\nThe City of Victorville, and their contractor, Sunrise Contractors, did not have evidence that\nall welding accomplished by them utilized a properly qualified procedure.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of\n2\n\n\n\n$1,000,000 for any related series of violations. We have reviewed the circumstances and\nsupporting 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\nthe items identified in this letter. Failure to do so will result in the City of Victorville being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2012-0018W. 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\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C.\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 P. Nguyen (#132894)\n3","truncated":false,"body_characters":5508}