{"operation":"document","citation":"CPF 12026040WL","title":"RICHMOND, 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 192.285(a), 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026040wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026040wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026040wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12026040WL","body":"Warning Letter involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulations as 192.285(a),  192.605(a). 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\n12026040WL_Warning Letter_03172026_(25-360136).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026040WL/12026040WL_Warning%20Letter_03172026_(25-360136).pdf\n\n12026040WL_Warning Letter_03172026_(25-360136)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026040WL/12026040WL_Warning%20Letter_03172026_(25-360136)_text.pdf\n\n12026040WL_Warning Letter_03172026_(25-360136)_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 EMAIL TO: daniel.rifenburgh@rva.gov\nMarch 17, 2026\nDaniel Rifenburgh\nDirector\nCity of Richmond\n400 Richmond Highway\nRichmond, Virginia 23224\nCPF 1-2026-040-WL\nDear Mr. Rifenburgh:\nOn April 25, 2025, an inspector from the Virginia State Corporation Commission, Division of\nPipeline Safety (VA SCC), acting as an agent for the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), Eastern Region, pursuant to Chapter\n601 of 49 United States Code (U.S.C.), inspected the City of Richmond’s (the City or Respondent)\nnatural gas distribution pipeline system, “MUNICIPAL-AREA #2 – VA,” in Richmond, Virginia.\nAs a result of the inspection, Eastern Region alleges that the City violated the Pipeline Safety\nRegulations, Title 49, Code of Federal Regulations (CFR) Part 192. Eastern Region identifies two\nwarning items. The probable violations are:\n1. § 192.285 Plastic pipe: Qualifying persons to make joints.\n(a) No person may make a plastic pipe joint unless that person has\nbeen qualified under the applicable joining procedure by:\n(1) Appropriate training or experience in the use of the\nprocedure; and\n(2) Making a specimen joint from pipe sections joined according\nto the procedure that passes the inspection and test set forth in\nparagraph (b) of this section.\nThe City failed to ensure a plastic pipe joint was made by a person qualified under the applicable\njoining procedure, as required by section 192.285(a). Specifically, an unqualified person prepared\ntwo plastic pipe ends for joining, a required step in the joining procedure.\n\n\n\nCPF 1-2026-040-WL\nDuring an inspection of a service line repair, the VA SCC inspector observed the City planning to\ncreate two plastic pipe joints with Elster Perfection Permasert Mechanical Couplings. To facilitate\nthe repair a MasTec contractor prepared two separate pipe ends for joining by chamfering the pipe\nends. The City’s Utility: Natural Gas Volume II Procedures Manual, Chapter 3, Section V\n(04/17/18) identified chamfering of pipe ends as a required step of the Elster Perfection Permasert\nMechanical Coupling installation procedures. Immediately prior to the two joints being created,\nthe VA SCC inspector stopped the crew and asked if the individual that chamfered the pipe ends\nwas qualified to join plastic pipe under the Elster Perfection Permasert Mechanical Coupling\njoining procedures, as the individual performed part of the joining procedure. The individual stated\nthat he was not qualified to join plastic pipe under any joining procedure.\nAfter the VA SCC inspector brought this concern to the attention of the crew and the City’s on-\nsite inspector, the crew proceeded to ask the VA SCC inspector questions about span-of-control\nratios and if a person needed to be qualified for chamfering operations. The City then discarded\nthe pipe ends that were chamfered by the unqualified person. A qualified person then prepared a\nnew section of pipe and completed the joining procedure.\nTherefore, the City failed to make a plastic pipe joint by a person qualified under the applicable\njoining procedure, as required by section 192.285(a).\n2. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each\npipeline, a manual of written procedures for conducting operations and\nmaintenance activities and for emergency response. For transmission\nlines, the manual must also include procedures for handling abnormal\noperations. This manual must be reviewed and updated by the operator\nat intervals not exceeding 15 months, but at least once each calendar\nyear. This manual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be kept at\nlocations where operations and maintenance activities are conducted.\nThe City failed to follow its manual of written procedures for conducting operations and\nmaintenance activities in accordance with section 192.605(a). Specifically, the City failed to notify\nan excavator that a service line markout was incomplete, as required by its Utility: Natural Gas\nVolume I Procedures Manual, Chapter 5, Section I (09/01/16) (DP Procedure).\nThe DP Procedure in section C.8 stated that “[i]n the event that the facilities cannot be located, the\nmarkout person shall: … (b)(4) Notify the excavator of the incomplete markout.”\nOn April 21, 2025, the City’s locating contractor, Southeast Connections, responded to a Virginia\n811 locate request (B511100037-00B) for 5009 Caledonia Road, Richmond, VA. The locator\ndetermined that a 1.25-inch plastic service line (Service Line) was unlocatable. The locator notified\ntheir supervisor, who completed an “Outside Plant Deficiency” form and submitted it to the City\nfor remediation. However, neither the locator nor their supervisor notified the excavator of the\nunlocatable Service Line and the incomplete markout.\nPage 2 of 3\n\n\n\nCPF 1-2026-040-WL\nFour days later, the excavator (a City contractor working to install a new gas main) proceeded with\nexcavation at the site. Because they were not notified of the incomplete markout—and because the\nexcavator also failed to perform an independent site inspection to identify unmarked utilities—the\nexcavator struck and damaged the unmarked Service Line.\nThe damage triggered immediate evacuations of nearby homes and a fire department response,\nthough no injuries were reported. City personnel arrived and squeezed off the damaged section of\npipe prior to VA SCC Staff’s arrival.\nA VA SCC inspector responded to the scene and determined through investigation that the Service\nLine had not been marked, and the required notification regarding the incomplete markout was\nnever made. Because the excavator was not notified of the incomplete markout, they proceeded\nwith work, resulting in a strike and damage to the Service Line.\nTherefore, the City failed to follow its manual of written procedures for conducting operations and\nmaintenance activities in accordance with section 192.605(a).\nResponse to this Notice\nThis Notice is issued in accordance with 49 CFR § 190.205. No reply to this Notice is required.\nWarning Items\nEastern Region has reviewed the facts and evidence and has decided not to propose a civil penalty\nor compliance order at this time. Eastern Region advises the Respondent to promptly correct these\nitems, if it 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 1-2026-040-WL.\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\nPage 3 of 3","truncated":false,"body_characters":8151}