{"operation":"document","citation":"CPF 12026041WL","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 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026041wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026041wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026041wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12026041WL","body":"Warning Letter involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulation as 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\n12026041WL_Warning Letter_03172026_(25-360133).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026041WL/12026041WL_Warning%20Letter_03172026_(25-360133).pdf\n\n12026041WL_Warning Letter_03172026_(25-360133)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026041WL/12026041WL_Warning%20Letter_03172026_(25-360133)_text.pdf\n\n12026041WL_Warning Letter_03172026_(25-360133)_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 1-2026-041-WL\nDear Mr. Rifenburgh:\nOn March 27, 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 Title 49 United States Code (U.S.C.), inspected the City of Richmond’s (the City or\nRespondent) pipeline near 4614 Leonard Parkway 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 one\nwarning item. The probable violation is:\n1. § 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.\n\n\n\nCPF 1-2026-041-WL\nThe City failed to follow for each pipeline, a manual of written procedures for conducting\noperations and maintenance activities and for emergency response, as required by section\n192.605(a). Specifically, the City failed to follow its Utility: Natural Gas Volume II Procedures\nManual, Chapter 2, Section II (11/27/2013) (NGPM) by excavating with mechanized equipment\nwithin two feet of an exposed gas service line.\nThe NGPM required all work in close proximity to underground utility lines to be performed by\nhand digging. However, a VA SCC inspector observed a City contractor crew using mechanized\nequipment within two feet of an exposed gas service line.\nTherefore, the City failed to follow for each pipeline, a manual of written procedures for\nconducting operations and maintenance activities and for emergency response, as required by\nsection 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 Item\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 this\nitem, 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 1-2026-041-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 2 of 2","truncated":false,"body_characters":4532}