{"operation":"document","citation":"CPF 12026048WL","title":"RICHMOND, CITY OF — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2026-05-26","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026048wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026048wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026048wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12026048WL","body":"Warning Letter involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2026-05-26 and is reported as closed as of 2026-05-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12026048WL_Warning Letter_05262026_(26-367941).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026048WL/12026048WL_Warning%20Letter_05262026_(26-367941).pdf\n\n12026048WL_Warning Letter_05262026_(26-367941)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026048WL/12026048WL_Warning%20Letter_05262026_(26-367941)_text.pdf\n\n12026048WL_Warning Letter_05262026_(26-367941)_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\nWARNING LETTER\nVIA EMAIL TO: daniel.rifenburgh@rva.gov\nMay 26, 2026\nDaniel Rifenburgh\nDirector\nCity of Richmond\n400 Richmond Highway\nRichmond, Virginia 23224\nCPF 1-2026-048-WL\nDear Mr. Rifenburgh:\nOn January 22, 2026, 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) procedures for gas pipeline Operator Qualification (OQ) in Richmond, Virginia.\nAs a result of the inspection, Eastern Region alleges that the City has committed probable\nviolations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR) Part\n192. The item inspected and the probable violation :\n1. § 192.605 Procedures 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\noperations and maintenance activities and for emergency\nresponse. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual\nmust be reviewed and updated by the operator at intervals not\n\n\n\nCPF 1-2026-048-WL\nexceeding 15 months, but at least once each calendar year. This\nmanual must be prepared before operations of a pipeline\nsystem commence. Appropriate parts of the manual must be\nkept at locations where operations and maintenance activities\nare 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\nfollow its operations and maintenance procedures manual, UTILITY: Natural Gas, Volume II,\nChapter/Section 2/IV, Topic: Prevention of Accidental Ignition (01/19/2026) (O&M Procedure),\nby failing to ground a cutting tool being used on a plastic pipe containing gas.\nSection C in the City’s O&M Procedure required tools and equipment that come into contact with\nRichmond Gas Works’s active natural gas facilities during operations where static electricity is\nlikely to be generated to be grounded if the procedure was expected to create or take place in a\npotentially combustible atmosphere. Section C of the City’s O&M procedure also requires the\ngrounding of plastic pipe via use of rags soaked in an electrically conductive material, wetted\nconductive tape, or liquid anti-static solution.\nDuring the inspection, the VA SCC inspector observed as a City contractor worked to abandon a\nlow-pressure, two-inch gas service line to a single-family home. The contractor squeezed off the\nservice line downstream of the tapping tee to facilitate the abandonment. The VA SCC inspector\nobserved as the contractor prepared to cut into the live plastic gas service line with a cutting tool\nthat had not been grounded. The VA SCC inspector also observed that no anti-static spray had\nbeen applied to the cutting area. Before the contractor cut into the live gas service line, the VA\nSCC inspector intervened and noted that the cutting tool needed to be grounded before cutting into\nthe live gas service line, as required by the City’s O&M Procedure. Had the VA SCC inspector\nnot intervened, the use of a non-grounded cutting tool on a plastic pipeline in close proximity to a\nsqueezed-off location could have caused an accidental ignition of gas sparked by a release of static\nelectricity.\nThe contractor proceeded to ground the cutting tool, sprayed anti-static spray on the cutting area,\nand cut the gas service line. An audible release of gas occurred when the gas service line was cut.\nThe contractor then completed the service line abandonment process.\nTherefore, the City failed to follow its manual of written procedures for conducting operations and\nmaintenance activities in accordance with section 192.605(a).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a related\nseries of violations. For violations occurring on or after December 28, 2023 and before December\n30, 2024, the maximum penalty may not exceed $266,015 per violation per day the violation\npersists, up to a maximum of $2,660,135 for a related series of violations. For violations occurring\nPage 2 of 3\n\n\n\nCPF 1-2026-048-WL\non or after January 6, 2023 and before December 28, 2023, the maximum penalty may not exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related\nseries of violations. For violations occurring on or after March 21, 2022 and before January 6,\n2023, the maximum penalty may not exceed $239,142 per violation per day the violation persists,\nup to a maximum of $2,391,142 for a related series of violations. For violations occurring on or\nafter May 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134\nper violation per day the violation persists, up to a maximum of $2,251,334 for a related series of\nviolations. For violations occurring on or after January 11, 2021 and before May 3, 2021, the\nmaximum penalty may not exceed $222,504 per violation per day the violation persists, up to a\nmaximum of $2,225,034 for a related series of violations. For violations occurring on or after July\n31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations.\nWe have reviewed the circumstances and supporting documents involved in this case and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so may result in the\nCity of Richmond being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2026-048-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\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\nJarod Cath, Engineer, City of Richmond, Jarrod.Cath@rva.gov\nPage 3 of 3","truncated":false,"body_characters":7831}