{"operation":"document","citation":"CPF 12026014NOA","title":"RICHMOND, CITY OF — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2026-03-02","effective_on":null,"summary":"CLOSED notice of amendment citing 192.805(i).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026014noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026014noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026014noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12026014NOA","body":"Notice of Amendment involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulation as 192.805(i). The case was opened on 2026-03-02 and is reported as closed as of 2026-04-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12026014NOA_Closure Letter_04132026_(25-358391).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026014NOA/12026014NOA_Closure%20Letter_04132026_(25-358391).pdf\n\n12026014NOA_Closure Letter_04132026_(25-358391)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026014NOA/12026014NOA_Closure%20Letter_04132026_(25-358391)_text.pdf\n\n12026014NOA_Notice of Amendment_03022026_(25-358391).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026014NOA/12026014NOA_Notice%20of%20Amendment_03022026_(25-358391).pdf\n\n12026014NOA_Notice of Amendment_03022026_(25-358391)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026014NOA/12026014NOA_Notice%20of%20Amendment_03022026_(25-358391)_text.pdf\n\n12026014NOA_Operator Response to Notice_03272026_(25-358391).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026014NOA/12026014NOA_Operator%20Response%20to%20Notice_03272026_(25-358391).pdf\n\n12026014NOA_Closure Letter_04132026_(25-358391)_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\nApril 13, 2026\nDaniel Rifenburgh\nDirector Richmond Gas Works\nCity of Richmond\n400 Richmond Highway\nRichmond, Virginia 23224\nRE: CPF-1-2026-014-NOA\nDear Mr. Rifenburgh:\nOn November 12, 2024, an inspector from the Virginia State Corporation Commission, Division\nof Pipeline 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\nthe City of Richmond’s (City) procedures for gas pipeline Operator Qualification (OQ) at 400\nRichmond Highway, Richmond, Virginia.\nThe City submitted its amended procedures on March 24, 2026. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\ncc: Eddie Childers, Operations Manager, City of Richmond, eddie.childers@rva.gov\nJarod Cath, Engineer, City of Richmond, Jarrod.Cath@rva.gov\n\n12026014NOA_Notice of Amendment_03022026_(25-358391)_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\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: daniel.rifenburgh@rva.gov\nMarch 2, 2026\nDaniel Rifenburgh,\nDirector Richmond Gas Works\nCity of Richmond\n400 Richmond Highway\nRichmond, Virginia 23224\nCPF 1-2026-014-NOA\nDear Mr. Rifenburgh:\nOn November 12, 2024, an inspector from the Virginia State Corporation Commission, Division\nof Pipeline 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\nthe City of Richmond’s (City) procedures for gas pipeline Operator Qualification (OQ) at 400\nRichmond Highway, Richmond, Virginia.\nAs a result of the inspection, PHMSA has identified an apparent inadequacy found within the\nCity’s plans or procedures. The alleged inadequacy and proposed revision are described below:\n1. § 192.805 Qualification program.\nEach operator shall have and follow a written qualification\nprogram. The program shall include provisions to:\n(a) . . .\n(i) After December 16, 2004, notify the Administrator or a state\nagency participating under 49 U.S.C. Chapter 601 if an operator\nsignificantly modifies the program after the administrator or state\nagency has verified that it complies with this section. Notifications to\nPHMSA must be submitted in accordance with § 192.18.\n\n\n\nCPF 1-2026-014-NOA\nThe City’s written qualification program was inadequate to ensure safe operation of a pipeline\nfacility in accordance with section 192.805(i). Specifically, the City’s Richmond Gas Works DOT\nOperator Qualification Program Plan (05/05/2024) (OQ Plan), section G, failed to include an\nadequate procedure for identifying significant OQ Plan changes that require notification to the\nstate agency, the Virginia State Corporation Commission.\nDuring the inspection, the VA SCC inspector reviewed the OQ Plan. Section G of the City’s OQ\nPlan addresses notification of significant OQ Plan changes to the Virginia State Corporation\nCommission. The procedure does not address significant plan changes including increases in\nreevaluation intervals, increased span-of-control ratios, or elimination of covered tasks.\nTherefore, the City’s written qualification program was inadequate to ensure safe operation of a\npipeline facility in accordance with section 192.805(i). PHMSA proposes that the City revise its\nprocedures to address the deficiency discussed above.\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 49 CFR § 190.211. If you do not respond within 30\ndays of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged\nin this Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting\nthis Notice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that the City maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to the Director, Eastern Region, Pipeline and Hazardous Materials\nPage 2 of 3\n\n\n\nCPF 1-2026-014-NOA\nSafety Administration, Office of Pipeline Safety. In correspondence concerning this matter, please\nrefer to CPF 1-2026-014-NOA and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Eddie Childers, Operations Manager, City of Richmond, eddie.childers@rva.gov\nJarod Cath, Engineer, City of Richmond, Jarrod.Cath@rva.gov\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\nPage 3 of 3","truncated":false,"body_characters":7971}