{"operation":"document","citation":"CPF 12026056WL","title":"RICHMOND, CITY OF — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2026-06-30","effective_on":null,"summary":"CLOSED warning letter citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026056wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026056wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026056wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12026056WL","body":"Warning Letter involving RICHMOND, CITY OF. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2026-06-30 and is reported as closed as of 2026-06-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12026056WL_Warning Letter_06302026_(26-373633).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026056WL/12026056WL_Warning%20Letter_06302026_(26-373633).pdf\n\n12026056WL_Warning Letter_06302026_(26-373633)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026056WL/12026056WL_Warning%20Letter_06302026_(26-373633)_text.pdf\n\n12026056WL_Warning Letter_06302026_(26-373633)_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 ELECTRONIC MAIL TO: daniel.rifenburgh@rva.gov\nJune 30, 2026\nDaniel Rifenburgh\nDirector\nCity of Richmond\n400 Richmond Highway\nRichmond, Virginia 23224\nCPF 1-2026-056-WL\nDear Mr. Rifenburgh:\nOn March 30, 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), pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nCity of Richmond’s (City) procedures for gas pipeline Operator Qualification (OQ) and Operations\nand Maintenance (O&M) at 4113 Hanover Avenue, Richmond, Virginia.\nAs a result of the inspection, it is alleged that the City has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\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 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 procedure for conducting operations and\nmaintenance activities in accordance with section 192.605(a). Specifically, the City failed to\n\n\n\nCPF 1-2026-056-WL\nfollow its operations and maintenance procedures manual, UTILITY: Natural Gas (vol. II, chap.\n2), Sections IV (rev. 1/9/26) and V (rev. 11/15/13) (“Procedures”) by failing to control the flow of\nblowing gas from a service line through the use of a squeeze-off or a valve closure.\nThe Procedures, Section IV, Paragraph VII.C.1.a, state: “Whenever practical, squeeze-offs and\nvalve closures to stop an uncontrolled release of natural gas should be performed far enough from\nthe point of release to ensure the safety of the personnel performing them in the event of an\naccidental ignition.”\nThe Procedures, Section IV, Paragraph III.A, state: “Where practical, [the City] will avoid the\nrelease of natural gas to the atmosphere and, especially, the uncontrolled formation of combustible\ngas mixtures.”\nThe Procedures, Section V, Paragraph III.A, define “blowing gas” as, in part: “a release of natural\ngas in outside, non-confined space locations that can be heard, seen or felt.”\nThe Procedures, Section V, Paragraph V.A.1, state: “The ideal method for protecting a worker is\nto eliminate hazards. For a blowing gas situation, this could include shutting off the gas at a valve\nor with a squeeze-off device at a location away from the flammable atmosphere.”\nUpon arrival, the VA SCC inspector smelled a strong odor of gas and heard an audible release of\ngas coming from an excavation around which the City’s contractor crew was performing work.\nThe VA SCC inspector discovered that the contractor crew had cut a live, low-pressure gas service\nline as part of the service change over work and had placed putty in the pipe end in an attempt to\nstop the flow of gas. The contractor crew stated it had opted to cut the service line while it was\nunder pressure because the curb valve was inaccessible. The contractor crew also stated that it was\nallowing the gas to continue blowing while it waited for materials to be delivered to install an end\ncap on the cut service line.\nFollowing this initial discussion, the VA SCC inspector suggested the contractor crew place gas\nmonitoring equipment in the excavation, which provided a sustained reading of 0.5 percent gas in\nair. The VA SCC inspector asked the contractor crew how it planned to control the flow of blowing\ngas, given that no flow control equipment was currently in place. The contractor crew ultimately\nworked to expose more of the service line upstream of the cut to facilitate a squeeze-off. The VA\nSCC inspector observed as the contractor crew squeezed off the service line, stopping the release\nof blowing gas. Later, the contractor crew proceeded to install an end cap on 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).\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 violation 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 violation occurring\non or after January 6, 2023 and before December 28, 2023, the maximum penalty may not exceed\nPage 2 of 3\n\n\n\nCPF 1-2026-056-WL\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 violation occurring on or after March 21, 2022 and before January 6, 2023,\nthe maximum penalty may not exceed $239,142 per violation per day the violation persists, up to\na maximum of $2,391,142 for a related series of violations. For violation occurring on or after\nMay 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134 per\nviolation per day the violation persists, up to a maximum of $2,251,334 for a related series of\nviolations. For violation 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 violation 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 City\nof 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 1-2026-056-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\nJarrod Cath, Engineer, City of Richmond, Jarrod.Cath@rva.gov\nPage 3 of 3","truncated":false,"body_characters":8402}