{"operation":"document","citation":"CPF 12026028NOA","title":"RICHMOND, CITY OF — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2026-03-24","effective_on":null,"summary":"CLOSED notice of amendment citing 192.303, 192.453, 192.473(a), 192.487(a), 192.513(c), 192.605(b)(1), 192.605(b)(2), 192.605(b)(4), 192.720, 192.756.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026028noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026028noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026028noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12026028NOA","body":"Notice of Amendment involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulations as 192.303,  192.453,  192.473(a),  192.487(a),  192.513(c),  192.605(b)(1),  192.605(b)(2),  192.605(b)(4),  192.720,  192.756. The case was opened on 2026-03-24 and is reported as closed as of 2026-06-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12026028NOA_Closure Letter_06262026_(25-353362).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026028NOA/12026028NOA_Closure%20Letter_06262026_(25-353362).pdf\n\n12026028NOA_Closure Letter_06262026_(25-353362)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026028NOA/12026028NOA_Closure%20Letter_06262026_(25-353362)_text.pdf\n\n12026028NOA_Notice of Amendment_03242026_(25-353362).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026028NOA/12026028NOA_Notice%20of%20Amendment_03242026_(25-353362).pdf\n\n12026028NOA_Notice of Amendment_03242026_(25-353362)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026028NOA/12026028NOA_Notice%20of%20Amendment_03242026_(25-353362)_text.pdf\n\n12026028NOA_Operator Response to Notice_04242026_(25-353362).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026028NOA/12026028NOA_Operator%20Response%20to%20Notice_04242026_(25-353362).pdf\n\n12026028NOA_Notice of Amendment_03242026_(25-353362)_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 EMAIL TO: daniel.rifenburgh@rva.gov\nMarch 24, 2026\nMr. Daniel Rifenburgh,\nDirector\nCity of Richmond\n400 Richmond Highway\nRichmond, Virginia 23224\nCPF 1-2026-028-NOA\nDear Mr. Rifenburgh:\nFrom March 1 to June 17, 2024, an inspector from the Virginia State Corporation Commission,\nDivision of Pipeline Safety (VA SCC), acting as an agent for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected the City of Richmond’s (City or Respondent) plans and procedures in Richmond,\nVirginia.\nAs a result of the inspection, PHMSA has identified apparent inadequacies in the City’s plans or\nprocedures. The alleged inadequacies and proposed revisions are described below:\n1. § 192.303 Compliance with specifications or standards.\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this\npart.\nThe City’s written construction procedures were inadequate to assure safe operation of a pipeline\nfacility. Specifically, the City’s procedure, Natural Gas Volume II Procedures Manual, Chapter 7,\nSection X (05/15/2015) (O&M Manual), failed to reference the correct incorporated by reference\nstandards, as required by section 192.303.\nThe O&M Manual in section 10 stated, in part:\nThe purpose of this welder qualification test procedure is to determine the ability\nof welders to produce sound butt, fillet, in-service welds, and miter fit ups and\nmitered welds. Using previously qualified Welding Procedure Specifications\n(W.P.S.), and in accordance with DOT 192 Subpart E, API 1104, with Appendix\n\n\n\nCPF 1-2026-028-NOA\nB, API 1107 and the API 5L (or the latest editions of same).\nHowever, API 1107 and API 5L are not standards incorporated by reference in section 192.225 to\ndevelop welding procedures. In addition, the O&M Manual erroneously stated that the latest\nedition of API 1104 should be used, but the edition listed in section 192.7 must be used.\nTherefore, the City’s written procedures for operations, maintenance, and emergencies were\ninadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise its\nprocedures to address section 192.303.\n2. § 192.513 Test requirements for plastic pipelines.\nEach transmission line or main must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with this\npart.\n(a) …\n(c) The test pressure must be at least 150% of the maximum operating\npressure or 50 psi (345 kPa) gauge, whichever is greater. However, the\nmaximum test pressure may not be more than 2.5 times the pressure\ndetermined under § 192.121 at a temperature not less than the pipe\ntemperature during the test.\nThe City’s written construction procedures were inadequate to assure safe operation of a pipeline\nfacility. Specifically, the City’s procedure, Utility: Natural Gas Volume I Procedures Manual,\nChapter 3, Section VIII (2/23/2022) (O&M Manual), failed to state that the maximum test pressure\nmay not be more than 2.5 times the pressure determined under § 192.121 at a temperature not less\nthan the pipe temperature during the test, in accordance with section 192.513(c).\nTherefore, the City’s written procedures for operations, maintenance, and emergencies were\ninadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise its\nprocedures to address section 192.513(c).\n3. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following, if\napplicable, to provide safety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with\neach of the requirements of this subpart and subpart M of this part.\n§ 192.720 Distribution systems: Leak repair.\nMechanical leak repair clamps installed after January 22, 2019 may not be\nused as a permanent repair method for plastic pipe.\nThe City’s written procedures for operating, maintaining, and repairing the pipeline were\ninadequate to assure safe operation of a pipeline facility. Specifically, the City’s procedure, Utility:\nNatural Gas Volume I Procedures Manual, Chapter 3, Section III (1/16/2015) (O&M), failed to\nprohibit the use of mechanical leak clamps as a permanent repair method for plastic pipelines, as\nPage 2 of 6\n\n\n\nCPF 1-2026-028-NOA\nrequired by section 192.720.\nTherefore, the City’s written procedures for operations, maintenance, and emergencies were\ninadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise its\nprocedures to address section 192.720.\n4. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by paragraph\n(a) of this section must include procedures for the following, if applicable, to\nprovide safety during maintenance and operations.\n(1) …\n(2) Controlling corrosion in accordance with the operations and\nmaintenance requirements of subpart I of this part.\n§ 192.473 External corrosion control: Interference currents.\n(a) Each operator whose pipeline system is subjected to stray currents shall\nhave in effect a continuing program to minimize the detrimental effects of such\ncurrents.\nThe City’s written procedures for controlling corrosion were inadequate to assure safe operation\nof a pipeline facility. Specifically, the City’s procedure, Utility: Natural Gas Volume II Procedures\nManual, Chapter 4, Section II (04/13/2015) failed to include provisions for identifying and\nminimizing interference currents on its pipeline system, as required by section 192.473(a).\nTherefore, the City’s written procedures for operations, maintenance, and emergencies were\ninadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise its\nprocedures to address section 192.473(a).\n5. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following, if\napplicable, to provide safety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with\neach of the requirements of this subpart and subpart M of this part.\n§ 192.487 Remedial measures: Distribution lines other than cast iron or ductile\niron lines.\n(a) General corrosion. Except for cast iron or ductile iron pipe, each\nsegment of generally corroded distribution line pipe with a remaining wall\nthickness less than that required for the MAOP of the pipeline, or a remaining\nwall thickness less than 30 percent of the nominal wall thickness, must be\nreplaced. However, corroded pipe may be repaired by a method that reliable\nengineering tests and analyses show can permanently restore the serviceability\nof the pipe. Corrosion pitting so closely grouped as to affect the overall\nstrength of the pipe is considered general corrosion for the purpose of this\nPage 3 of 6\n\n\n\nCPF 1-2026-028-NOA\nparagraph.\nThe City’s written procedures for operating, maintaining, and repairing the pipeline were\ninadequate to assure safe operation of a pipeline facility. Specifically, the City’s procedure, Utility:\nNatural Gas Volume II Procedures Manual, Chapter 4, Section II (04/13/2015) (O&M Manual),\nfailed to provide adequate guidance to operating personnel when evaluating the remaining strength\nof internally and externally corroded pipe, as required by section 192.487(a).\nSection II in the O&M Manual stated in part that “RGW shall replace the affected segment if the\nwall thickness is less than that required for the MAOP or less than 30 percent of the nominal wall\nthickness.” However, the City’s O&M Manual failed to provide any guidance to operating\npersonnel regarding what tools and processes shall be used when taking wall thickness\nmeasurements to determine the remaining wall thicknesses on internally and externally corroded\npipe.\nTherefore, the City’s written procedures for operations, maintenance, and emergencies were\ninadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise its\nprocedures to address section 192.487(a).\n6. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following, if\napplicable, to provide safety during maintenance and operations.\n(1) …\n(2) Controlling corrosion in accordance with the operations and\nmaintenance requirements of subpart I of this part.\n§ 192.453 General.\nThe corrosion control procedures required by § 192.605(b)(2), including\nthose for the design, installation, operation, and maintenance of cathodic\nprotection systems, must be carried out by, or under the direction of, a person\nqualified in pipeline corrosion control methods.\nThe City’s written procedures for controlling corrosion were inadequate to assure safe operation\nof a pipeline facility. Specifically, the City’s procedure, Utility: Natural Gas Volume II Procedures\nManual, Chapter 4, Section II (04/13/2015) (O&M Manual), failed to establish the qualifications\nrequired for an individual to lead the corrosion control department, in accordance with section\n192.453.\nSection II in the O&M Manual stated in part that “[c]orrosion control procedures, including those\nfor the design, installation, operation and maintenance of cathodic protection systems, will be\ncarried out under the direction of the Supervisor of Corrosion Technicians.” However, the O&M\nManual failed to define the specific qualifications or experience required for this role.\nPage 4 of 6\n\n\n\nCPF 1-2026-028-NOA\nTherefore, the City’s written procedures for operations, maintenance, and emergencies were\ninadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise its\nprocedures to address section 192.453.\n7. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following, if\napplicable, to provide safety during maintenance and operations.\n(1) …\n(4) Gathering of data needed for reporting incidents under Part 191 of this\nchapter in a timely and effective manner.\nThe City’s written procedures for the gathering of data needed for reporting incidents under Part\n191 were inadequate to assure safe operation of a pipeline facility. Specifically, the City’s\nprocedure, Utility: Natural Gas Volume I Procedures Manual, Chapter 3, Section III (09/01/2016),\nerroneously stated that certain incidents must be reported within two hours, instead of the one-\nhour timeframe required by section 191.5(a).\nTherefore, the City’s written procedures for operations, maintenance, and emergencies were\ninadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise its\nprocedures to address section 191.5(a).\n8. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(b) Maintenance and normal operations. The manual required by\nparagraph (a) of this section must include procedures for the following, if\napplicable, to provide safety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with\neach of the requirements of this subpart and subpart M of this part.\n§ 192.756 Joining plastic pipe by heat fusion; equipment maintenance and\ncalibration.\nEach operator must maintain equipment used in joining plastic pipe in\naccordance with the manufacturer’s recommended practices or with written\nprocedures that have been proven by test and experience to produce\nacceptable joints.\nThe City’s written procedures for operating, maintaining, and repairing the pipeline were\ninadequate to assure safe operation of a pipeline facility. Specifically, the City failed to have\nwritten procedures for maintaining equipment used in joining plastic pipe in accordance with the\nmanufacturer’s recommended practices or with written procedures that have been proven by test\nand experience to produce acceptable joints, as required by section 192.756.\nDuring the inspection, the City failed to provide a specific procedure for the maintenance of\nequipment used in joining plastic pipe. The only document produced was “Performance Pipe Heat\nFusion Joining Procedures” (June 2021). This document is specific to one brand of equipment used\nPage 5 of 6\n\n\n\nCPF 1-2026-028-NOA\nby the City and focuses on joining procedures rather than equipment maintenance requirements.\nTherefore, the City’s written procedures for operations, maintenance, and emergencies were\ninadequate to ensure safe operation of a pipeline facility. PHMSA proposes that the City revise its\nprocedures to address section 192.756.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206.\nPlease review the enclosed Response Options for Pipeline Operators in Enforcement Proceedings.\nThe Respondent must respond to this Notice within 30 days of receipt. The Region Director may\nextend this period upon receipt of a timely written request demonstrating good cause. Failure to\nrespond within 30 days (or by the extended deadline) constitutes a waiver of the right to contest\nthe allegations in the Notice and authorizes the Associate Administrator for Pipeline Safety,\nwithout further notice to the Respondent, to find the facts as alleged in the Notice and to issue an\nOrder Directing Amendment. If the Respondent’s plans or procedures are found inadequate as\nalleged in this Notice, the Respondent will be ordered to amend its plans or procedures to correct\nthe inadequacies. Once the inadequacies identified herein have been addressed in amended\nprocedures, this enforcement action will be closed.\nAll material submitted in response to this enforcement action may be made publicly available. If\nthe Respondent believes that any portion of the responsive material qualifies for confidential\ntreatment under 5 U.S.C. § 552(b), along with the complete original document, it must provide a\nsecond copy of the document with the portions that may qualify for confidential treatment redacted\nand an explanation of why the redacted information may qualify for confidential treatment under\n5 U.S.C. § 552(b).\nPHMSA requests that the Respondent maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice (preparation/revision of plans and procedures) and submit the\ntotal to the Region Director.\nIn correspondence on this matter, please refer to CPF 1-2026-028-NOA.\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Jarrod Cath, Engineer, City of Richmond, Jarrod.Cath@rva.gov\nEddie Childers, Operations Manager, City of Richmond, eddie.childers@rva.gov\nPage 6 of 6\n\n12026028NOA_Closure Letter_06262026_(25-353362)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n840 Bear Tavern Road, Suite 300\nWest Trenton, New Jersey 08628\n609.771.7800\nVIA ELECTRONIC MAIL TO: daniel.rifenburgh@rva.gov\nJune 26, 2026\nDaniel Rifenburgh\nDirector Richmond Gas Works\nCity of Richmond\n400 Richmond Highway\nRichmond, Virginia 23224\nRE: CPF-1-2026-028-NOA\nDear Mr. Rifenburgh:\nFrom March 1 to June 17, 2024, an inspector from the Virginia State Corporation Commission,\nDivision of Pipeline Safety (VA SCC), acting as an agent for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected the City of Richmond’s (City) plans and procedures in Richmond, Virginia..\nThe City submitted its amended procedures on April 24, 2026 and provided necessary information\nregarding these procedures on May 29 and June 23, 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: Ralph Worley, Operations Manager, City of Richmond, Ralph.Worley@rva.gov\nWilliam Northcutt, Operations Manager, City of Richmond, William.Northcutt@rva.gov\nJarod Cath, Engineer, City of Richmond, Jarrod.Cath@rva.gov","truncated":false,"body_characters":18300}