# DANVILLE, CITY OF — Notice of Amendment

- **operation:** document
- **citation:** CPF 12026017NOA
- **title:** DANVILLE, CITY OF — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** current
- **official:** true
- **published on:** 2026-03-16
- **effective on:** Not available
- **summary:** OPEN notice of amendment citing 191.5(c), 192.281(a), 192.481(d), 192.605(b)(1), 192.605(b)(2), 192.605(b)(3), 192.605(b)(4), 192.614(c)(1), 192.615(a)(10), 192.615(a)(2), 192.720, 192.739(a), 192.741(a), 192.741(b), 192.741(c), 192.747(b).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/12026017NOA
**body:**

Notice of Amendment involving DANVILLE, CITY OF. PHMSA's enforcement data identifies the cited regulations as 191.5(c),  192.281(a),  192.481(d),  192.605(b)(1),  192.605(b)(2),  192.605(b)(3),  192.605(b)(4),  192.614(c)(1),  192.615(a)(10),  192.615(a)(2),  192.720,  192.739(a),  192.741(a),  192.741(b),  192.741(c),  192.747(b). The case was opened on 2026-03-16 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12026017NOA_Notice of Amendment_03162026_(25-343789).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026017NOA/12026017NOA_Notice%20of%20Amendment_03162026_(25-343789).pdf

12026017NOA_Notice of Amendment_03162026_(25-343789)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026017NOA/12026017NOA_Notice%20of%20Amendment_03162026_(25-343789)_text.pdf

12026017NOA_Operator Response to Notice_05052026_(25-343789).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026017NOA/12026017NOA_Operator%20Response%20to%20Notice_05052026_(25-343789).pdf

12026017NOA_Notice of Amendment_03162026_(25-343789)_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
NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: greyjc@danvilleva.gov
March 16, 2026
Jason Grey
Director of Utilities
City of Danville
1113 Goodyear Blvd.
Danville, Virginia 24541
CPF 1-2026-017-NOA
Dear Mr. Grey:
Between October 10, 2023 and April 29, 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) procedures, records,
and pipeline facilities located near 1113 Goodyear Boulevard in Danville, Virginia.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within the
City’s plans or procedures. The items inspected and the alleged inadequacies and proposed
revisions are described below:
1. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following, if
applicable, to provide safety during maintenance and operations.
(1) . . . .
(4) Gathering of data needed for reporting incidents under Part 191 of
this chapter in a timely and effective manner.
§ 191.5 Immediate notice of certain incidents.
(a) . . . .



CPF 1-2026-017-NOA
(c) Within 48 hours after the confirmed discovery of an incident, to the
extent practicable, an operator must revise or confirm its initial telephonic
notice required in paragraph (b) of this section with an estimate of the amount
of product released, an estimate of the number of fatalities and injuries, and
all other significant facts that are known by the operator that are relevant to
the cause of the incident or extent of the damages. If there are no changes or
revisions to the initial report, the operator must confirm the estimates in its
initial report.
The City’s written procedures for operations, maintenance, and emergencies were inadequate to
ensure safe operation of a pipeline facility. Specifically, the City failed to require revision or
confirmation of its initial telephonic notice of an incident within 48 hours in its procedure, Natural
Gas and Operations Maintenance Plan (06/05/2023) (O&M Procedure), section B-2, subsection
2.3, as required by sections 191.5(c) and 192.605(b)(4).
Therefore, the City’s written procedures for operations, maintenance, and emergencies were
inadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise
its procedures to address section 191.5(c).
2. § 192.281 Plastic pipe.
(a) General. A plastic pipe joint that is joined by solvent cement, adhesive,
or heat fusion may not be disturbed until it has properly set. Plastic pipe may
not be joined by a threaded joint or miter joint.
The City’s written procedures for operations, maintenance, and emergencies were inadequate to
ensure safe operation of a pipeline facility. Specifically, the City failed to prohibit joining plastic
pipe with a miter joint in its O&M Procedure, section F-3, as required by section 192.281(a).
Therefore, the City’s written procedures for operations, maintenance, and emergencies were
inadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise
its procedures to address section 192.281(a).
3. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following, if
applicable, to provide safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance
with each of the requirements of this subpart and subpart M of this part.
§ 192.720 Distribution systems: Leak repair.
Mechanical leak repair clamps installed after January 22, 2019 may not be
used as a permanent repair method for plastic pipe.
The City’s written procedures for operations, maintenance, and emergencies were inadequate to
ensure safe operation of a pipeline facility. Specifically, the City failed to specify the maximum
2



CPF 1-2026-017-NOA
duration a mechanical leak clamp can remain on a plastic pipeline as part of a temporary repair
in its O&M Procedure, section F-9, as required by sections 192.605(b)(1) and 192.720.
Therefore, the City’s written procedures for operations, maintenance, and emergencies were
inadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise
its procedures to address the above deficiency.
4. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following, if
applicable, to provide safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance
with each of the requirements of this subpart and subpart M of this part.
§ 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’s written procedures for operations, maintenance, and emergencies were inadequate to
ensure safe operation of a pipeline facility. Specifically, the City failed to specify when inoperable
valves must be corrected in its O&M Procedure, section G-9, subsection 3.2, as required by
sections 192.605(b)(1) and 192.747(b).
Therefore, the City’s written procedures for operations, maintenance, and emergencies were
inadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise
its procedures to address the above deficiency.
5. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following, if
applicable, to provide safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance
with each of the requirements of this subpart and subpart M of this part.
§ 192.741 Pressure limiting and regulating stations: Telemetering or recording
gauges.
(a) Each distribution system supplied by more than one district pressure
regulating station must be equipped with telemetering or recording pressure
gauges to indicate the gas pressure in the district.
(b) On distribution systems supplied by a single district pressure regulating
station, the operator shall determine the necessity of installing telemetering or
recording gauges in the district, taking into consideration the number of
3



CPF 1-2026-017-NOA
customers supplied, the operating pressures, the capacity of the installation,
and other operating conditions.
(c) If there are indications of abnormally high or low pressure, the
regulator and the auxiliary equipment must be inspected and the necessary
measures employed to correct any unsatisfactory operating conditions.
The City’s written procedures for operations, maintenance, and emergencies were inadequate to
ensure safe operation of a pipeline facility. Specifically, the City failed to include the requirements
to have telemetering or recording pressure gauges to indicate the gas pressure in each district
pressure regulating station in its O&M Procedure, as required by sections 192.605(b)(1) and
192.741.
During the inspection, the VA SCC inspector reviewed the City’s O&M. The VA SCC inspector
found the City lacked a procedure requiring telemetering be installed on its distribution system.
According to City personnel, after the VA SCC’s last comprehensive distribution system
inspection, this procedure was removed during an annual review and update of its O&M and never
placed back into the O&M.
Therefore, the City’s written procedures for operations, maintenance, and emergencies were
inadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise
its procedures to address section 192.741.
6. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following, if
applicable, to provide safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance
with each of the requirements of this subpart and subpart M of this part.
§ 192.739 Pressure limiting and regulating stations: Inspection and testing.
(a) Each pressure limiting station, relief device (except rupture discs), and
pressure regulating station and its equipment must be subjected at intervals
not exceeding 15 months, but at least once each calendar year, to inspections
and tests to determine that it is—
(1) In good mechanical condition;
(2) Adequate from the standpoint of capacity and reliability of
operation for the service in which it is employed;
(3) Except as provided in paragraph (b) of this section, set to control
or relieve at the correct pressure consistent with the pressure limits of §
192.201(a); and
(4) Properly installed and protected from dirt, liquids, or other
conditions that might prevent proper operation.
4



CPF 1-2026-017-NOA
The City’s written procedures for operations, maintenance, and emergencies were inadequate to
ensure safe operation of a pipeline facility. Specifically, the City failed to include its process for
testing relief devices with nitrogen in its O&M Procedure, as required by sections 192.605(b)(1)
and 192.739(a).
During the inspection, the VA SCC inspector reviewed the City’s O&M procedures. While City
personnel confirmed they have implemented a process to test relief valves using nitrogen, the
written procedures were not updated to reflect this practice.
Therefore, the City’s written procedures for operations, maintenance, and emergencies were
inadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise
its procedures to address the above deficiency.
7. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following, if
applicable, to provide safety during maintenance and operations.
(1) . . . .
(2) Controlling corrosion in accordance with the operations and
maintenance requirements of Subpart I of this part.
§ 192.481 Atmospheric corrosion control: Monitoring.
(a) . . . .
(d) If atmospheric corrosion is found on a service line during the most
recent inspection, then the next inspection of that pipeline or portion of
pipeline must be within 3 calendar years, but with intervals not exceeding 39
months.
The City’s written procedures for operations, maintenance, and emergencies were inadequate to
ensure safe operation of a pipeline facility. Specifically, the City failed to require a change in
inspection frequency if atmospheric corrosion is found on a service line in its O&M, section G-
4, subsection 2.3, as required by sections 192.605(b)(1) and 192.481(d).
Therefore, the City’s written procedures for operations, maintenance, and emergencies were
inadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise
its procedures to address section 192.481(d).
8. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following, if
applicable, to provide safety during maintenance and operations.
(1) . . . .
(3) Making construction records, maps, and operating history
available to appropriate operating personnel.
5



CPF 1-2026-017-NOA
The City’s written procedures for operations, maintenance, and emergencies were inadequate to
ensure safe operation of a pipeline facility. Specifically, the City failed to include a procedure that
makes construction records, maps, and operating history available to appropriate operator
personnel in its O&M, section C-2, as required by section 192.605(b)(3).
Therefore, the City’s written procedures for operations, maintenance, and emergencies were
inadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise
its procedures to address section 192.605(b)(3).
9. § 192.615 Emergency plans.
(a) Each operator shall establish written procedures to minimize the
hazard resulting from a gas pipeline emergency. At a minimum, the
procedures must provide for the following:
(1) . . . .
(10) Beginning action under § 192.617, if applicable, as soon after the
end of the emergency as possible.
The City’s written procedures for emergencies were inadequate to ensure safe operation of a
pipeline facility. Specifically, the City failed to include a procedure that requires it to begin a
section 192.617 failure investigation as soon as possible after the end of the emergency in its
O&M, section C-2, subsection 2.5.3.15, as required by section 192.615(a)(10).
Therefore, the City’s written procedures for operations, maintenance, and emergencies were
inadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise
its procedures to address section 192.615(a)(10).
10. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(b) Maintenance and normal operations. The manual required by
paragraph (a) of this section must include procedures for the following, if
applicable, to provide safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance
with each of the requirements of this subpart and subpart M of this part.
§ 192.614 Damage prevention program.
(a) . . . .
(c) The damage prevention program required by paragraph (a) of this
section must, at a minimum:
(1) Include the identity, on a current basis, of persons who normally
engage in excavation activities in the area in which the pipeline is located.
The City’s written procedures for operations, maintenance, and emergencies were inadequate to
ensure safe operation of a pipeline facility. Specifically, the City failed to include a procedure for
identifying persons who normally engage in excavation activities in the area in which the City's
6



CPF 1-2026-017-NOA
pipelines are located in its O&M, section C-1, as required by sections 192.605(b)(1) and
192.614(c)(1).
Therefore, the City’s written procedures for operations, maintenance, and emergencies were
inadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise
its procedures to address section 192.614(c)(1).
11. § 192.615 Emergency plans.
(a) Each operator shall establish written procedures to minimize the
hazard resulting from a gas pipeline emergency. At a minimum, the
procedures must provide for the following:
(1) . . . .
(2) Establishing and maintaining adequate means of communication
with the appropriate public safety answering point (i.e., 9-1-1 emergency
call center), where direct access to a 9-1-1 emergency call center is
available from the location of the pipeline, and fire, police, and other
public officials. Operators may establish liaison with the appropriate local
emergency coordinating agencies, such as 9- 1-1 emergency call centers or
county emergency managers, in lieu of communicating individually with
each fire, police, or other public entity. An operator must determine the
responsibilities, resources, jurisdictional area(s), and emergency contact
telephone number(s) for both local and out-of-area calls of each Federal,
State, and local government organization that may respond to a pipeline
emergency, and inform such officials about the operator's ability to
respond to a pipeline emergency and the means of communication during
emergencies.
The City’s written procedures for emergencies were inadequate to ensure safe operation of a
pipeline facility. Specifically, the City failed to include a procedure for establishing and
maintaining an adequate means of communication with the appropriate public safety answering
point, and fire, police, and other public officials in its O&M, as required by section 192.615(a)(2).
Therefore, the City’s written procedures for operations, maintenance, and emergencies were
inadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise
its procedures to address section 192.615(a)(2).
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
7



CPF 1-2026-017-NOA
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 of Danville 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 Safety Administration, Office of Pipeline Safety. In correspondence concerning this
matter, please refer to CPF 1-2026-017-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: Krysta Simpson, Water and Gas Compliance Coordinator, simpsok@danvilleva.gov
Scott Jarrett, Water and Gas Chief Engineer, jarrejs@danvilleva.gov
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
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