{"operation":"document","citation":"CPF 12026039WL","title":"DANVILLE, CITY OF — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2026-03-17","effective_on":null,"summary":"CLOSED warning letter citing 192.616(a), 192.616(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026039wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026039wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026039wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12026039WL","body":"Warning Letter involving DANVILLE, CITY OF. PHMSA's enforcement data identifies the cited regulations as 192.616(a),  192.616(c). The case was opened on 2026-03-17 and is reported as closed as of 2026-03-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12026039WL_Warning Letter_03172026_(25-360140).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026039WL/12026039WL_Warning%20Letter_03172026_(25-360140).pdf\n\n12026039WL_Warning Letter_03172026_(25-360140)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026039WL/12026039WL_Warning%20Letter_03172026_(25-360140)_text.pdf\n\n12026039WL_Warning Letter_03172026_(25-360140)_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\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: greyjc@danvilleva.gov\nMarch 17, 2026\nJason Grey\nDirector of Utilities\nCity of Danville\n1040 Monument Street\nDanville, Virginia 24540\nCPF 1-2026-039-WL\nDear Mr. Grey:\nOn July 15 and July 21, 2025, 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), Office of Pipeline Safety (OPS), Eastern Region, pursuant to\nChapter 601 of 49 United States Code (U.S.C.), inspected the City of Danville’s (the City or\nRespondent) gas distribution pipeline in Danville, Virginia.\nAs a result of the inspection, PHMSA alleges that the City violated the Pipeline Safety Regulations,\nTitle 49, Code of Federal Regulations (CFR) Part 192. PHMSA identifies three warning items.\nThe probable violations are:\n1. § 192.616 Public Awareness\n(a) Except for an operator of a master meter or petroleum gas\nsystem covered under paragraph (j) of this section, each pipeline\noperator must develop and implement a written continuing public\neducation program that follows the guidance provided in the American\nPetroleum Institute’s (API) Recommended Practice (RP) 1162\n(incorporated by reference, see § 192.7).\nThe City failed to develop and implement a written continuing public education program that\nfollows the guidance provided in the American Petroleum Institute’s (API) Recommended Practice\n(RP) 1162, in accordance with section 192.616(a). Specifically, the City failed to provide public\nawareness messaging to members of the affected public at least twice annually in accordance with\nsection 6.1.1 in the City’s Public Awareness Plan, Revision 5.0, dated December 2024.\nSection 6.1.1 in the PAP required the operator to ensure members of the affected public receive\neach of the baseline messaging content topics at least twice annually.\n\n\n\nCPF 1-2026-039-WL\nDuring the inspection, the VA SCC inspector reviewed the City’s outreach efforts to members of\nthe affected public. The City provides public awareness messaging to members of the affected\npublic through bill inserts, which are sent out in three different bills each year, each covering a\nunique topic. However, each of the baseline messaging content topics for members of the affected\npublic are only provided once annually across each of the three bill inserts. As a result, members\nof the affected public only receive baseline messaging content topics once annually rather than\ntwice annually as required by section 6.1.1 in the PAP.\nTherefore, the City failed to develop and implement a written continuing public education program\nthat follows the guidance provided in the API RP 1162, in accordance with section 192.616(a).\n2. § 192.616 Public Awareness\n(a) . . .\n(c) The operator must follow the general program\nrecommendations, including baseline and supplemental requirements\nof API RP 1162, unless the operator provides justification in its\nprogram or procedural manual as to why compliance with all or certain\nprovisions of the recommended practice is not practicable and not\nnecessary for safety.\nThe City failed to follow the general program recommendations, including baseline and\nsupplemental requirements of API RP 1162, in accordance with section 192.616(c). Specifically,\nthe City failed to provide records demonstrating that the City performed an annual assessment of\nimplementation in 2022 in accordance with section 11.1.1 in the PAP and table 8-1 in API RP\n1162.\nSection 11.1.1 in the PAP and table 8-1 in API RP 1162 require that operators perform an\nassessment of implementation annually.\nDuring the inspection, the VA SCC inspector reviewed the City’s annual program implementation\nreviews. The City failed to provide any records demonstrating performance of an annual\nimplementation review in 2022. VA SCC Staff found that a majority of the City’s records\ndocumenting public awareness program activities in 2022 were erroneously deleted by the City’s\ninformation technology department.\nTherefore, the City failed to follow the general program recommendations, including baseline and\nsupplemental requirements of API RP 1162, in accordance with section 192.616(c).\n3. § 192.616 Public Awareness\n(a) …\n(c) The operator must follow the general program recommendations, including\nbaseline and supplemental requirements of API RP 1162, unless the operator\nprovides justification in its program or procedural manual as to why compliance with\nall or certain provisions of the recommended practice is not practicable and not\nnecessary for safety.\nPage 2 of 3\n\n\n\nCPF 1-2026-039-WL\nThe City failed to follow the general program recommendations, including baseline and\nsupplemental requirements of API RP 1162, in accordance with section 192.616(c). Specifically,\nthe City failed to provide records demonstrating that the City provided public awareness messaging\nto members of the excavator stakeholder audience in 2022 in accordance with table 2-2.4 in API\nRP 1162.\nTable 2-2.4 in API RP 1162 requires that operators provide members of the excavator stakeholder\naudience with public awareness messaging annually.\nDuring the inspection, the VA SCC inspector reviewed the City’s excavator messaging efforts.\nThe City failed to provide any records demonstrating that it provided public awareness messaging\nto members of the excavator stakeholder audience in 2022. VA SCC Staff found that a majority of\nthe City’s records documenting public awareness program activities in 2022 were erroneously\ndeleted by the City’s information technology department.\nTherefore, the City failed to follow the general program recommendations, including baseline and\nsupplemental requirements of API RP 1162, in accordance with section 192.616(c).\nResponse to this Notice\nThis Notice is issued in accordance with 49 CFR § 190.205. No reply to this Notice is required.\nWarning Items\nPHMSA has reviewed the facts and evidence and has decided not to propose a civil penalty or\ncompliance order at this time. PHMSA advises the Respondent to promptly correct these items, if\nit has not already done so. Failure to do so may result in additional enforcement action.\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).\nIn correspondence on this matter, please refer to CPF 1-2026-039-WL.\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Krysta Simpson, Water and Gas Compliance Coordinator, simpsok@danvilleva.gov\nScott Jarrett, Water and Gas Chief Engineer, jarrejs@danvilleva.gov\nPage 3 of 3","truncated":false,"body_characters":7907}