{"operation":"document","citation":"CPF 12025008NOA","title":"RICHMOND, CITY OF — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-07-01","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025008noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025008noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025008noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12025008NOA","body":"Notice of Amendment involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulation as 192.605(b)(1). The case was opened on 2025-07-01 and is reported as closed as of 2026-01-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12025008NOA_Closure Letter_01222026_(25-336868).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025008NOA/12025008NOA_Closure%20Letter_01222026_(25-336868).pdf\n\n12025008NOA_Closure Letter_01222026_(25-336868)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025008NOA/12025008NOA_Closure%20Letter_01222026_(25-336868)_text.pdf\n\n12025008NOA_Notice of Amendment_07012025_(25-336868).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025008NOA/12025008NOA_Notice%20of%20Amendment_07012025_(25-336868).pdf\n\n12025008NOA_Notice of Amendment_07012025_(25-336868)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025008NOA/12025008NOA_Notice%20of%20Amendment_07012025_(25-336868)_text.pdf\n\n12025008NOA_Operator Response to Notice_07232025_(25-336868).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025008NOA/12025008NOA_Operator%20Response%20to%20Notice_07232025_(25-336868).pdf\n\n12025008NOA_Closure Letter_01222026_(25-336868)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n840 Bear Tavern Road, Suite 300\nWest Trenton, NJ 08628\n609.771.7800\nVIA ELECTRONIC MAIL TO: daniel.rifenburgh@rva.gov\nJanuary 22, 2026\nMr. Daniel Rifenburgh\nDirector\nCity of Richmond\n400 Richmond Highway\nRichmond, Virginia 23224\nRE: CPF 1-2025-008-NOA\nDear Mr. Rifenburgh:\nOn May 15, 2024 an inspector from the Virginia State Corporation Commission, Division of\nPipeline Safety (VA SCC), acting as an agent for the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nCity of Richmond’s (City) procedures for gas pipeline maintenance and normal operations at 4091\nConcord Creek Place, Henrico, Virginia. On July 1, 2025, pursuant to 49 CFR § 190.206, PHMSA\nissued a Notice of Amendment which proposed amendment of the City’s procedures.\nThe City submitted its amended procedures on July 23, 2025. PHMSA has reviewed the amended\nprocedures, and it appears that the inadequacies outlined in the Notice of Amendment have been\ncorrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n12025008NOA_Notice of Amendment_07012025_(25-336868)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: daniel.rifenburgh@rva.gov\nJuly 1, 2025\nMr. Daniel Rifenburgh\nDirector\nCity of Richmond\n400 Richmond Highway\nRichmond, Virginia 23224\nCPF 1-2025-008-NOA\nDear Mr. Rifenburgh:\nOn 5/15/2024 an inspector from the Virginia State Corporation Commission, Division of\nPipeline Safety (VA SCC), acting as an agent for the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nCity of Richmond’s (City) procedures for gas pipeline maintenance and normal operations at\n4091 Concord Creek Place, Henrico, Virginia.\nAs a result of the inspection, PHMSA has identified the apparent inadequacy found within The\nCity’s plans or procedures. The item inspected and the inadequacy are described below:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual\nrequired by paragraph (a) of this section must include procedures for\nthe following, if applicable, to provide safety during maintenance and\noperations.\n(1) Operating, maintaining, and repairing the pipeline in\naccordance with each of the requirements of this subpart and\nsubpart M of this part.\n\n\n\nThe City’s written procedures were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, the City’s Operations and Maintenance Procedure Manual (\"O&M”) Volume 2,\nChapter 3, Section 7 dated 8/11/2015 and Volume 2, Chapter 2, Section 4 dated 6/11/2018 lacked\nsufficient details for tools used during tapping and stopping operations to be sufficiently grounded\nto prevent accidental ignition as required by section 192.605(b)(1).\nDuring the inspection, the VA SCC inspector reviewed Volume 2, Chapter 3, Section 7 of the\nCity's O&M. This section provides guidance for tapping plastic pipelines but did not address when\ntapping tools need to be grounded. Volume 2, Chapter 3, Section 7 of the City's O&M also stated,\nin part, \"All tapping procedures should be in accordance with the tapping equipment\nmanufacturer's recommended procedures.\" The VA SCC inspector additionally reviewed the\nmanufacturer’s manual, “Georg Fischer Electrofusion Installation and Training Manual”, Revised\nAugust 2022, which is contained in Volume 3 of the City's O&M. Under the \"Tapping\" section, it\nstated, in part: \"Follow all safety rules and protocols for grounding and static discharge when\nworking in a flammable gaseous environment.\" However, the City's O&M does not contain safety\nrules and protocols for grounding tools used during tapping or stopping operations.\nTherefore, the City’s written procedures required by section 192.605(b)(1) were inadequate. City\nof Richmond must revise its procedures to address this requirement.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part\nof this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you submit\nin response to this enforcement action is subject to being made publicly available. If you believe\nthat any portion 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 under\n5 U.S.C. § 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting this Notice,\nwe propose that you submit your amended procedures to my office within 30 days of receipt of\nthis Notice. This period may be extended by written request for good cause. Once the inadequacies\nidentified herein have been addressed in your amended procedures, this enforcement action will\nbe closed.\n\n\n\nIt is requested (not mandated) that City of Richmond maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF 1-2025-008-NOA and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":7960}