# DANVILLE, CITY OF — Warning Letter

- **operation:** document
- **citation:** CPF 12026016WL
- **title:** DANVILLE, CITY OF — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2026-01-21
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 192.747(b).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-12026016wl.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-12026016wl.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-12026016wl
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/12026016WL
**body:**

Warning Letter involving DANVILLE, CITY OF. PHMSA's enforcement data identifies the cited regulation as 192.747(b). The case was opened on 2026-01-21 and is reported as closed as of 2026-01-21. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12026016WL_Warning Letter_01212026_(25-354261).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026016WL/12026016WL_Warning%20Letter_01212026_(25-354261).pdf

12026016WL_Warning Letter_01212026_(25-354261)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026016WL/12026016WL_Warning%20Letter_01212026_(25-354261)_text.pdf

12026016WL_Warning Letter_01212026_(25-354261)_text.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
840 Bear Tavern Road, Suite 300
West Trenton, NJ 08628
609.771.7800
WARNING LETTER
VIA ELECTRONIC MAIL TO: greyjc@danvilleva.gov
January 21, 2026
Mr. Jason Grey
Director of Utilities
City of Danville
1040 Monument Street
Danville, Virginia 24540
CPF 1-2026-016-WL
Dear Mr. Grey:
On October 16, 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.), conducted
an inspection of the City of Danville’s (City) pipeline in Danville, Virginia.
As a result of the inspection, it is alleged that City has 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. § 192.747 Valve maintenance: Distribution systems.
(a) . . .
(b) Each operator must take prompt remedial action to correct any
valve found inoperable, unless the operator designates an alternative
valve.
The City failed to take prompt remedial action to correct any valve found inoperable, in accordance
with section 192.747(b). Specifically, the City failed to take remedial action after a critical valve
was found inoperable at its facility near Stony Mill Road.
During the inspection, the VA SCC inspector observed City personnel attempt to operate a critical
valve on October 17, 2024 at its facility near Stony Mill Road. The valve is designed so that one



CPF 1-2026-016-WL
person may operate the valve. However, the inspector observed that the valve required five City
technicians with two “cheater bars”1 for additional leverage in order for the valve to actuate.
The City’s Natural Gas Operations and Maintenance Plan, chapter II, section G-9, section 3.2
(06/05/2023) (O&M), states in part: “When conducting inspections to any critical valves within
the Division’s distribution system, personnel shall ensure that the valve is operable. To determine
operability, personnel shall partially operate the valve to ensure operability in the event of an
emergency. If the valve is found to be inoperable, prompt (with little or no delay; immediately)
remedial action shall be taken to correct it. If no adequate solution is available, a suitable
alternative valve may be designated as a critical valve by the Water and Gas Chief Engineer and
the newly identified critical valve shall be promptly inspected.”
This valve is critical and must be operated promptly by a single person during an emergency.
However, inspection revealed it requires five people to properly operate the valve. Therefore, the
City should have considered the valve inoperable and taken the remedial actions outlined in its
O&M.
Therefore, the City failed to take prompt remedial action to correct any valve found inoperable, in
accordance with section 192.747(b)
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
1 Cheater bars are often pieces of metal pipe or rods that are used to provide additional length, torque, and leverage.
See Occupational Safety and Health Administration, Inspection Detail, Inspection: 311066856 - Tesoro Refining And
Marketing Company, https://www.osha.gov/ords/imis/establishment.inspection_detail?id=311066856.
12026016WL_Warning Letter_01212026_(25-354261) Page 2 of 3



CPF 1-2026-016-WL
time. We advise you to correct the item identified in this letter. Failure to do so may result in the
City of Danville 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 1-2026-016-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
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).
Sincerely,
Robert Burrough
Director, Eastern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
12026016WL_Warning Letter_01212026_(25-354261) Page 3 of 3
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