RICHMOND, CITY OF — Warning Letter

12025030WL_Warning Letter_08142025_(24-307994)_text.pdf, page 1Official PDFWARNING LETTER VIA ELECTRONIC MAIL TO: daniel.rifenburgh@rva.gov August 14, 2025 Mr. Daniel Rifenburgh, Director Richmond Gas Works City of Richmond 400 Richmond Highway Richmond, Virginia 23224 CPF 1-2025-030-WL Dear Mr. Rifenburgh: On August 29, 2024 an inspector from the Virginia State Corporation Commission, Division of Pipeline Safety (VA SCC), acting as Agent for the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), conducted an inspection of the City of Richmond’s (City) pipeline near 7683 Granite Hall Avenue, Richmond, Virginia. As a result of the inspection, it is alleged that you have committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the probable violation is: 1. § 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 transmission 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.#

12025030WL_Warning Letter_08142025_(24-307994)_text.pdf, page 2The City failed to follow its manual of written procedures for conducting operations and maintenance activities. Specifically, the City failed to follow its Operations and Maintenance Procedures Manual (03/22/2021) (O&M) by boring towards a live gas main rather than away from the main. The City’s O&M, Volume 2, Chapter 3, Section 2, Paragraph H states in part: "The direction of the bore shall be away from any live gas main." During the inspection, the VA SCC inspector observed the City conduct pneumatic boring activities near 7683 Granite Hall Avenue, Richmond, VA. The exit pit for the bore was where the main/service line tie in would occur. The VA SCC inspector further observed that the boring tool’s head had exited the earth within the main/service line tie-in pit, therefore demonstrating that the City had bored in the direction of the live gas main. Therefore, the City failed to follow its manual of written procedures for conducting operations and maintenance activities as required by section 192.605(a). Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a related series of violations. For violation occurring on or after December 28, 2023 and before December 30, 2024, the maximum penalty may not exceed $266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may not exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related series of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,142 for a related series of violations. For violation occurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related series of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related series of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a 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 item identified in this letter. Failure to do so will result in City of Richmond 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 1-2025-030-WL. 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#

12025030WL_Warning Letter_08142025_(24-307994)_text.pdf, page 3you 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). Sincerely, Robert Burrough Director, Eastern Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration#