RICHMOND, CITY OF — Notice of Amendment

party submissionOfficial PDF12026014NOA_Operator Response to Notice_03272026_(25-358391).pdf#

12026014NOA_Closure Letter_04132026_(25-358391)_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 April 13, 2026 Daniel Rifenburgh Director Richmond Gas Works City of Richmond 400 Richmond Highway Richmond, Virginia 23224 RE: CPF-1-2026-014-NOA Dear Mr. Rifenburgh: On November 12, 2024, 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) procedures for gas pipeline Operator Qualification (OQ) at 400 Richmond Highway, Richmond, Virginia. The City submitted its amended procedures on March 24, 2026. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration cc: Eddie Childers, Operations Manager, City of Richmond, eddie.childers@rva.gov Jarod Cath, Engineer, City of Richmond, Jarrod.Cath@rva.gov#

12026014NOA_Notice of Amendment_03022026_(25-358391)_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 NOTICE OF AMENDMENT VIA ELECTRONIC MAIL TO: daniel.rifenburgh@rva.gov March 2, 2026 Daniel Rifenburgh, Director Richmond Gas Works City of Richmond 400 Richmond Highway Richmond, Virginia 23224 CPF 1-2026-014-NOA Dear Mr. Rifenburgh: On November 12, 2024, 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) procedures for gas pipeline Operator Qualification (OQ) at 400 Richmond Highway, Richmond, Virginia. As a result of the inspection, PHMSA has identified an apparent inadequacy found within the City’s plans or procedures. The alleged inadequacy and proposed revision are described below: 1. § 192.805 Qualification program. Each operator shall have and follow a written qualification program. The program shall include provisions to: (a) . . . (i) After December 16, 2004, notify the Administrator or a state agency participating under 49 U.S.C. Chapter 601 if an operator significantly modifies the program after the administrator or state agency has verified that it complies with this section. Notifications to PHMSA must be submitted in accordance with § 192.18.#

12026014NOA_Notice of Amendment_03022026_(25-358391)_text.pdf, page 2CPF 1-2026-014-NOA The City’s written qualification program was inadequate to ensure safe operation of a pipeline facility in accordance with section 192.805(i). Specifically, the City’s Richmond Gas Works DOT Operator Qualification Program Plan (05/05/2024) (OQ Plan), section G, failed to include an adequate procedure for identifying significant OQ Plan changes that require notification to the state agency, the Virginia State Corporation Commission. During the inspection, the VA SCC inspector reviewed the OQ Plan. Section G of the City’s OQ Plan addresses notification of significant OQ Plan changes to the Virginia State Corporation Commission. The procedure does not address significant plan changes including increases in reevaluation intervals, increased span-of-control ratios, or elimination of covered tasks. Therefore, the City’s written qualification program was inadequate to ensure safe operation of a pipeline facility in accordance with section 192.805(i). PHMSA proposes that the City revise its procedures to address the deficiency discussed above. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement Proceedings. Please refer to this document and note the response options. 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 you 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under 49 CFR § 190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that the City maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to the Director, Eastern Region, Pipeline and Hazardous Materials Page 2 of 3#

12026014NOA_Notice of Amendment_03022026_(25-358391)_text.pdf, page 3CPF 1-2026-014-NOA Safety Administration, Office of Pipeline Safety. In correspondence concerning this matter, please refer to CPF 1-2026-014-NOA and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Robert Burrough Director, Eastern Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: Eddie Childers, Operations Manager, City of Richmond, eddie.childers@rva.gov Jarod Cath, Engineer, City of Richmond, Jarrod.Cath@rva.gov Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings Page 3 of 3#