RICHMOND, CITY OF — Notice of Probable Violation

party submissionOfficial PDF12025006NOPV_Operator Response to Notice_05302025_(23-272518).pdf#

case documentOfficial PDF12025006NOPV_PCO_05082025_(23-272518).pdf#

case documentOfficial PDF12025006NOPV_PCO_05082025_(23-272518)_text.pdf#

12025006NOPV_Closure Letter_01222026_(23-272518)_text.pdf, page 1Official PDFU.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 840 Bear Tavern Road, Suite 300 West Trenton, NJ 08628 609.771.7800 VIA ELECTRONIC MAIL TO: daniel.rifenburgh@rva.gov January 22, 2026 Mr. Daniel Rifenburgh Director Richmond Gas Works City of Richmond 400 Richmond Highway Richmond, Virginia 23224 RE: CPF 1-2025-006-NOPV Dear Mr. Rifenburgh: On October 29,2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to City of Richmond’s (City) a Final Order, pursuant to 49 CFR § 190.213 in the above- referenced case. This Order included a Compliance Order. Based on our review of the documentation provided, it has been determined that the City has complied with the terms of the Order. Accordingly, this case is now closed, and no further action is contemplated with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration#

12025006NOPV_Final Order_10292025_(23-272518)_text.pdf, page 1Official PDFOctober 29, 2025 VIA ELECTRONIC MAIL TO: daniel.rifenburgh@rva.gov Mr. Daniel Rifenburgh Director Richmond Gas Works City of Richmond 400 Richmond Highway Richmond, Virginia 23224 Re: CPF No. 1-2025-006-NOPV Dear Mr. Rifenburgh: Enclosed please find the Final Order issued in the above-referenced case. It makes two findings of violation and specifies actions that need to be taken by the City of Richmond to comply with the pipeline safety regulations. When the terms of the compliance order are completed, as determined by the Director, Eastern Region, this enforcement action will be closed. Service of the Final Order by e-mail is effective upon the date of transmission and acknowledgement of receipt as provided under 49 CFR § 190.5. Thank you for your cooperation in this matter. Sincerely, Linda Daugherty Acting Associate Administrator for Pipeline Safety Enclosures cc: Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA W. LeGrand Northcutt, Policy Advisor – Gas Regulatory Compliance, Richmond Gas Works, legrand.northcutt@dhcd.virginia.gov CONFIRMATION OF RECEIPT REQUESTED#

12025006NOPV_Final Order_10292025_(23-272518)_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ ) In the Matter of ) ) Richmond Gas Works ) CPF No. 1-2025-006-NOPV ) ) Respondent. ) ____________________________________) FINAL ORDER On May 10, 2023, an inspector from the Virginia State Corporation Commission, Division of Pipeline Safety (VA SCC), acting as an agent for the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected the City of Richmond’s (City or Respondent) pipeline facilities in Richmond, Virginia. As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent, by letter dated May 8, 2025, a Notice of Probable Violation and Proposed Compliance Order (Notice). In accordance with 49 CFR § 190.207, the Notice proposed finding that the City had committed 2 violations of 49 CFR Part 192 and proposed ordering the City to take certain measures to correct the alleged violations. The City responded to the Notice by letter dated May 30, 2025 (Response). Respondent did not contest either of the violations but requested the modification or suspension of the Proposed Compliance Order. On June 18, 2025, the Director issued a recommendation for final action. Respondent did not request a hearing and therefore has waived its right to one. FINDINGS OF VIOLATION The Notice alleged that Respondent violated 49 CFR Part 192, as follows: Item 1: The Notice alleged that Respondent violated 49 CFR § 192.605(a), which states: § 192.605 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For#

12025006NOPV_Final Order_10292025_(23-272518)_text.pdf, page 3transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. The Notice alleged that Respondent violated 49 CFR § 195.605(a) by failing to follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. Specifically, the Notice alleged that the City failed to follow the manufacturer’s instructions, which required proper support and anchor restraints, when installing fittings in accordance with chapter 3, section II in its Natural Gas Procedures Manual, dated 2/1/2020. The Notice alleged that the City failed, as required by its manual, to follow the manufacturer’s instructions to install support or anchor restraints when it installed a 12-inch Dresser Style 63 Type 1 expansion coupling, which subsequently developed a natural gas leak. The City did not contest this allegation of violation. In its Response, the City requested the modification or suspension of the associated Proposed Compliance Order, as discussed further below. Accordingly, based upon a review of all the evidence, I find that Respondent violated 49 CFR § 192.605(a) by failing to follow its manual of written procedures for conducting operations and maintenance activities and for emergency response. Item 2: The Notice alleged that Respondent violated 49 CFR § 192.805(h), which states: § 192.805 Qualification Program Each operator shall have and follow a written qualification program. The program shall include provisions to: (a) . . . . (h) After December 16, 2004, provide training, as appropriate to ensure that individuals performing covered tasks have the necessary knowledge and skills to perform the tasks in a manner that ensures the safe operation of pipeline facilities; and The Notice alleged that Respondent violated 49 CFR § 192.805(h) by failing to provide training, as appropriate, to ensure that individuals performing covered tasks have the necessary knowledge and skills to perform the tasks in a manner that ensures the safe operations of pipeline facilities. Specifically, the Notice alleged that the City failed to provide training for the installation of special fittings, such as the Dresser Style 63 Type 1 expansion coupling. The Notice alleged that the City’s employees tasked with joining pipe with a Dresser Style 63 Type 1 expansion joint did not have the necessary knowledge and skills to perform the task in a manner that ensures the safe operation of pipeline facilities, and the lack of requisite training resulted in a release of natural gas due to improper installation of the Dresser expansion coupling.#

12025006NOPV_Final Order_10292025_(23-272518)_text.pdf, page 4The City did not contest this allegation of violation. In its Response, the City requested the modification or suspension of the associated Proposed Compliance Order, as discussed further below. Accordingly, based upon a review of all the evidence, I find that Respondent violated 49 CFR § 192.805(h) by failing to provide training, as appropriate, to ensure that individuals performing covered tasks have the necessary knowledge and skills to perform the tasks in a manner that ensures the safe operations of pipeline facilities. These findings of violation will be considered prior offenses in any subsequent enforcement action taken against Respondent. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Items 1 and 2 for violations of 49 CFR §§ 192.605(a), and 192.805(h), respectively. Under 49 U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. With regard to both the violation of section 192.605(a) (Item 1) and the violation of section 192.805(h) (Item 2), Respondent argued the compliance terms should be suspended or modified. The City stated that it updated its Operator Qualification (OQ) Program to include content on the installation of restraining and non-restraining expansion couplings, including special fittings such as Dresser Style 63, that all of its gas construction inspectors and supervisors had completed the training, and that it had scheduled a live training to cover the installation process for the Dresser Style 63 Expansion Coupling. In the recommendation for final action, the Director stated that the City had not provided the updated OQ program, OQ training records, details of the live training, or any other supporting documentation. The Director stated that without these records, which are required under the Proposed Compliance Order, it is not possible to determine if the City has complied with the proposed corrective measures. For the above reasons, the Compliance Order is not withdrawn or modified, as set forth below. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the following actions to ensure compliance with the pipeline safety regulations applicable to its operations: 1. With respect to the violation of section 192.605(a) (Item 1), Respondent must, within 90 days of receipt of the Final Order, develop and implement a training program focused on special fittings such as Dresser Style. City gas utility construction and maintenance personnel shall be trained with the updated content and requalified for the covered task. 2. With respect to the violation of section 192.805(h) (Item 2), Respondent must update its OQ training program to specifically include training on the installation of restraining and non-restraining expansion couplings, including special#

12025006NOPV_Final Order_10292025_(23-272518)_text.pdf, page 5fittings such as Dresser Style 63 and provide the updated training program to the Director, Eastern Region, within 90 days of receipt of the Final Order. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. PHMSA requests that Respondent maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to the Director. It is requested that these costs be reported in two categories: (1) total cost associated with preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated with replacements, additions and other changes to pipeline infrastructure. Failure to comply with this Order may result in administrative assessment of civil penalties exceeding $200,000, as adjusted for inflation (see 49 CFR § 190.223 for adjusted amounts), for each violation for each day the violation continues or in referral to the Attorney General for appropriate relief in a district court of the United States. Under 49 CFR § 190.243, Respondent may submit a Petition for Reconsideration of this Final Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. The written petition must be received no later than 20 days after receipt of the Final Order by Respondent. Any petition submitted must contain a statement of the issue(s) and meet all other requirements of 49 CFR § 190.243. The filing of a petition automatically stays the payment of any civil penalty assessed. The other terms of the order, including corrective action, remain in effect unless the Associate Administrator, upon request, grants a stay. The terms and conditions of this Final Order are effective upon service in accordance with 49 CFR § 190.5. ___________________________________ __________________________ Linda Daugherty Date Issued Acting Associate Administrator for Pipeline Safety#