{"operation":"document","citation":"CPF 12025030WL","title":"RICHMOND, CITY OF — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-08-14","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025030wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025030wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025030wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12025030WL","body":"Warning Letter involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2025-08-14 and is reported as closed as of 2025-08-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12025030WL_Warning Letter_08142025_(24-307994).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025030WL/12025030WL_Warning%20Letter_08142025_(24-307994).pdf\n\n12025030WL_Warning Letter_08142025_(24-307994)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025030WL/12025030WL_Warning%20Letter_08142025_(24-307994)_text.pdf\n\n12025030WL_Warning Letter_08142025_(24-307994)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: daniel.rifenburgh@rva.gov\nAugust 14, 2025\nMr. Daniel Rifenburgh, Director\nRichmond Gas Works\nCity of Richmond\n400 Richmond Highway\nRichmond, Virginia 23224\nCPF 1-2025-030-WL\nDear Mr. Rifenburgh:\nOn August 29, 2024 an inspector from the Virginia State Corporation Commission, Division of\nPipeline Safety (VA SCC), acting as Agent for the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), conducted\nan inspection of the City of Richmond’s (City) pipeline near 7683 Granite Hall Avenue,\nRichmond, Virginia.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and\nthe probable violation is:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline,\na manual of written procedures for conducting operations and\nmaintenance activities and for emergency response. For\ntransmission lines, the manual must also include procedures for\nhandling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but\nat least once each calendar year. This manual must be prepared\nbefore operations of a pipeline system commence. Appropriate\nparts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\n\n\n\nThe City failed to follow its manual of written procedures for conducting operations and\nmaintenance activities. Specifically, the City failed to follow its Operations and Maintenance\nProcedures Manual (03/22/2021) (O&M) by boring towards a live gas main rather than away from\nthe main.\nThe City’s O&M, Volume 2, Chapter 3, Section 2, Paragraph H states in part: \"The direction of\nthe bore shall be away from any live gas main.\"\nDuring the inspection, the VA SCC inspector observed the City conduct pneumatic boring\nactivities near 7683 Granite Hall Avenue, Richmond, VA. The exit pit for the bore was where\nthe main/service line tie in would occur. The VA SCC inspector further observed that the boring\ntool’s head had exited the earth within the main/service line tie-in pit, therefore demonstrating that\nthe City had bored in the direction of the live gas main.\nTherefore, the City failed to follow its manual of written procedures for conducting operations and\nmaintenance activities as required by section 192.605(a).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a related\nseries of violations. For violation occurring on or after December 28, 2023 and before December\n30, 2024, the maximum penalty may not exceed $266,015 per violation per day the violation\npersists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring\non or after January 6, 2023 and before December 28, 2023, the maximum penalty may not exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related\nseries of violations. For violation occurring on or after March 21, 2022 and before January 6,\n2023, the maximum penalty may not exceed $239,142 per violation per day the violation persists,\nup to a maximum of $2,391,142 for a related series of violations. For violation occurring on or\nafter May 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134\nper violation per day the violation persists, up to a maximum of $2,251,334 for a related series of\nviolations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the\nmaximum penalty may not exceed $222,504 per violation per day the violation persists, up to a\nmaximum of $2,225,034 for a related series of violations. For violation occurring on or after July\n31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the item identified in this letter. Failure to do so will result in City\nof Richmond being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2025-030-WL. 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\n\n\n\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":6026}