# SPIRE STL PIPELINE LLC — Notice of Probable Violation

**Citation:** CPF 32025003NOPV  
**Type / status:** enforcement / current  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2025-01-16

OPEN notice of probable violation citing 192.473(a), 192.605(a), 192.615(b)(2), 192.706(a), 192.907(a), 192.947(b).

## Document text

Notice of Probable Violation involving SPIRE STL PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 192.473(a),  192.605(a),  192.615(b)(2),  192.706(a),  192.907(a),  192.947(b). The case was opened on 2025-01-16 and is reported as open. Proposed civil penalty: $50,200. Assessed civil penalty: $50,200. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

32025003NOPV_Final Order_08052025_(23-264381)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025003NOPV/32025003NOPV_Final%20Order_08052025_(23-264381)_text.pdf

32025003NOPV_Final Order_08052025_(23-264381).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025003NOPV/32025003NOPV_Final%20Order_08052025_(23-264381).pdf

32025003NOPV_Operator Response to Notice_03142025_(23-264381).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025003NOPV/32025003NOPV_Operator%20Response%20to%20Notice_03142025_(23-264381).pdf

32025003NOPV_PCP PCO_01162025_(23-264381).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025003NOPV/32025003NOPV_PCP%20PCO_01162025_(23-264381).pdf

32025003NOPV_PCP PCO_01162025_(23-264381)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025003NOPV/32025003NOPV_PCP%20PCO_01162025_(23-264381)_text.pdf

32025003NOPV_Final Order_08052025_(23-264381)_text.pdf

August 5, 2025
VIA ELECTRONIC MAIL TO: scott.smith@spireenergy.com
Scott Smith
President
Spire STL Pipeline, LLC
3773 Richmond Avenue
Houston, Texas 77046
Re: CPF No. 3-2025-003-NOPV
Dear Mr. Smith:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $50,200, and specifies actions that need to be taken to
comply with the pipeline safety regulations. When the civil penalty has been paid and the terms
of the compliance order are completed, as determined by the Acting Director, Central Region,
this enforcement action will be closed. Service of the Final Order by e-mail is effective upon the
date of transmission and acknowledgement of receipt as provided under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosures (Final Order and NOPV)
cc: David Barrett, Acting Director, Central Region, Office of Pipeline Safety
Randy Wilson, Director, Pipeline and System Integrity, Spire Inc.



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Spire STL Pipeline, LLC, ) CPF No. 3-2025-003-NOPV
a subsidiary of Spire Inc., )
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
On January 16, 2025,
1 pursuant to 49 CFR § 190.207, the Director, Central Region, Office of
Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Spire STL Pipeline,
LLC (Respondent). The Notice proposed finding that Respondent had violated the pipeline
safety regulations in 49 CFR Part 192 and proposed a civil penalty of $50,200. Effective May
20, 2025, PHMSA revised its proposed civil penalty calculation policy to use the version of the
Civil Penalty Worksheet in effect when the alleged violation occurred.2 The new policy did not
change the proposed civil penalty in this case. The Notice also proposed certain measures to
correct the violations. Respondent did not contest the allegations of violation, the proposed civil
penalty, or corrective measures, but included in its Response an explanation regarding the
location of records related to Item 1 of the Notice.
Based upon a review of all of the evidence, pursuant to section 190.213, I find Respondent
violated the pipeline safety regulations listed below, as more fully described in the enclosed
Notice, which is incorporated by reference:
49 CFR § 192.473(a) (Item 1) ─ Respondent failed to have a continuing program
to minimize the detrimental effects of stray currents that could interfere with its
cathodic protection system.
49 CFR § 192.615(b)(2) (Item 3) ─ Respondent failed conduct annual refresher
training of its emergency response personnel in order to assure they were
knowledgeable of its emergency procedures and to verify that the training was
effective.
1 The Notice contains a typographical error regarding the year of issuance.
2 Central Region informed Respondent of the new penalty policy and case file policy via letters dated June 18, 2025,
and June 20, 2025, respectively.



49 CFR § 192.706(a) (Item 4) ─ Respondent failed to conduct leakage surveys at
the required intervals at one Class 1 location (Mississippi River HDD) and two
Class 3 locations (Highway 367 HDD and Spanish Lake HDD).
49 CFR § 192.907(a) (Item 5) ─ Respondent failed to follow its written integrity
management program for selecting and performing preventative and mitigative
measures.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent. In accordance with 49 CFR § 190.223, I assess Respondent a
total civil penalty of $50,200.
Payment of the civil penalty must be made within 20 days of service. Federal regulations (49
CFR § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMK-325), Federal Aviation Administration, Mike
Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169.
The Financial Operations Division telephone number is (405) 954-8845.
Failure to pay the $50,200 civil penalty will result in accrual of interest at the current annual rate
in accordance with 31 U.S.C. § 3717, 31 CFR § 901.9 and 49 CFR § 89.23. Pursuant to those
same authorities, a late penalty charge of six percent (6%) per annum will be charged if payment
is not made within 110 days of service. Furthermore, failure to pay the civil penalty may result
in referral of the matter to the Attorney General for appropriate action in a district court of the
United States.
Compliance Actions
Pursuant to 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the
actions proposed in the enclosed Notice to correct the violations. In its Response, Respondent
provided additional information regarding its commitment to complying with the pipeline safety
regulations and the steps it was taking towards completing the proposed corrective measures.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension. Upon completion of the ordered actions, Respondent may request that the Director
close the case. Failure to comply with this Order may result in the assessment of civil penalties
under 49 CFR § 190.223 or in referral to the Attorney General for appropriate relief in a district
court of the United States.
Warning Items
With respect to Items 2 and 6, the Notice alleged probable violations of 49 CFR §§ 192.605(a)
and 192.947(b), respectively, but did not propose a civil penalty or compliance order for these
Items. Therefore, these are considered to be warning items. If OPS finds a violation of any of
these Items in a subsequent inspection, Respondent may be subject to future enforcement action.



The terms and conditions of this order are effective upon service in accordance with 49 CFR
§ 190.5.
___________________________________ _________________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety



NOTICE OF PROBABLE VIOLATION
and
PROPOSED COMPLIANCE ORDER
VIA ELECTRONIC MAIL TO: scott.smith@spireenergy.com;
randy.wilson@spireenergy.com; nicole.christianer@spireenergy.com
January 16, 2024
Scott Smith
President
Spire STL Pipeline, LLC
3773 Richmond Ave
Houston, TX 77046
CPF 3-2025-003-NOPV
Dear Mr. Smith:
From August 1, 2023 to November 29, 2024, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter
601 of 49 United States Code (U.S.C.), inspected Spire STL Pipeline, LLC’s (Spire) natural gas
transmission pipeline from St. Louis, Missouri, to Alsey, Illinois.
As a result of the inspection, it is alleged that Spire has committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violations are:
1. § 192.473 External corrosion control: Interference currents.
(a) Each operator whose pipeline system is subjected to stray currents shall have in
effect a continuing program to minimize the detrimental effects of such currents.
Spire failed to have a continuing program to minimize the detrimental effects of stray currents, per
the requirements of § 192.473(a). The “Spire STL Pipeline Operations & Maintenance Manual,”
(Spire’s O&M Manual) section 7.2.1 merely stated, "[i]f subject to stray currents carry out
continuing program. Corrosion tech performs stray current testing. Refer to [Spire’s O&M
Manual] Sections 6.5.1 CP Design and 7.4.11.1 External Corrosion Control." From PHMSA’s
review of Spire’s procedures and records, PHMSA found that Spire’s procedures did not further
define how to carry out a continuing program to address stray current (e.g. how to detect, monitor,
analyze, and minimize such currents). In response to PHMSA’s exit briefing report, Spire stated:
Spire monitors the CP readings near foreign lines for indications, such as a very
high on or off readings, that may indicate there is an adverse effect on the pipeline
from a foreign line crossing. The Manager, Corrosion Control would direct CIS



readings to be taken in the area of the foreign line crossing to determine if stray
current was interfering with the cathodic protection system. If such a condition
was found, Spire would begin monitoring the stray current and/or install a bond.
However, to date Spire has not observed readings that would indicate stray
current interference.
In order to measure the protective electrical gradient at any specific location, monitoring should
be conducted directly at the location otherwise excessive resistance (IR) and inaccuracy is
introduced into the recorded readings. Spire’s own description of its process demonstrates that it
is necessary to take readings “in the area of the foreign line crossing” in order “to determine if
stray current was interfering with the cathodic protection system.” By failing to have a program
in place aligning with this description, Spire’s program for addressing stray current failed to
comply with § 192.473(a).3
PHMSA found from a review of Spire’s cathodic protection records that the following foreign
pipeline crossing sites were located a significant distance away from the test station: (1) the
Buckeye Partners, LP, and St. Louis Pipeline Operating, LLC, crossing is approximately 1,950
feet from the nearest test station (TS-112); (2) the Marathon Pipeline, LLC, crossing is
approximately 541 feet from the nearest test station (TS-99); (3) Express Holdings (USA), LLC
and TC Oil Pipeline Operations, Inc.’s two line crossings are approximately 1005 feet from the
nearest test station (TS-88). Consequently, Spire was not continually monitoring these line
crossings, which posed a risk of stray current or interference, in such a way as to minimize the
detrimental effects of such currents. Therefore, Spire failed to follow the requirements of
§ 192.473(a).
Additionally, when asked by PHMSA during the inspection for records of inspection and
monitoring of alternating current (AC) mitigation devices installed to mitigate AC interference,
Spire did not provide any records in response. Spire’s corrosion personnel stated it did not have a
process requiring the technician to get AC readings during annual surveys, unless directed by the
manager. Furthermore, Spire's system of recording4 cathodic protection surveys did not have a
location to capture and record an AC reading. Absent this information, the effectiveness of Spire’s
AC interference monitoring program cannot be gauged. By failing to monitor its foreign pipeline
crossings for stray currents and by failing to monitor the effectiveness of AC interference
mitigation devices, Spire failed to have a continuing program to minimize the detrimental effects
of interference current, per the requirements of § 192.473(a).
2. § 192.605 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
3 While not incorporated by reference under 49 C.F.R. § 192.7, NACE TM0497, Measurement Techniques Related to
Criteria for Cathodic Protection on Underground or Submerged Metallic Piping Systems (2022) demonstrates that
corrosion control experts recommend monitoring directly at the location. See sections 5.7, 6.1.2, and 9.6.3. Spire’s
program does not align with this industry recommend methodology.
4 Spire’s work order system of record, MAXIMO.



updated by the operator at intervals not exceeding 15 months, but at least once each
calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
Spire failed to conduct an adequate review and update of its manual of written procedures for
conducting operations and maintenance activities and for emergency response, in accordance
with § 192.605(a). Specifically, Spire’s O&M Manual did not include or reference many of the
Standard Operating Procedures (SOPs) that Spire’s personnel used for conducting operations and
maintenance activities and for emergency response. Spire provided 15 SOPs on January 12,
2023, that were used by personnel but were not included or referenced within Spire’s O&M
Manual. Spire’s O&M revision log showed that Spire updated its O&M Manual once each
calendar year yet, failed to identify and address these omissions. Thus, Spire failed to comply
with the requirement of § 192.605(a) to conduct an adequate and thorough review and update of
its manual of written procedures for conducting operations and maintenance activities and for
emergency response.
3. § 192.615 Emergency plans.
(a) . . . .
(b) Each operator shall:
(1) . . . .
(2) Train the appropriate operating personnel to assure that they are knowledgeable
of the emergency procedures and verify that the training is effective.
Spire failed to train the appropriate operating personnel to assure that they were knowledgeable
of the emergency procedures and verify that the training was effective, per the requirements of §
192.615(b)(2). Specifically, Spire did not conduct annual refresher training for its emergency
response personnel, from calendar year 2019 through 2022, as required by Spire’s “Spire STL
Pipeline Emergency Plan and Procedures” (Spire’s Emergency Response Procedures), section
17.3. During this time frame only 3 out of 18 qualified individuals received any refresher
training. Spire’s Emergency Response Procedures, section 17.3 stated:
All employees who will be involved in emergency response will receive prior
training to the degree necessary to perform their duties...Employees who are
trained in accordance with this section shall receive annual refresher training of
sufficient content to maintain their competencies, or shall demonstrate
competency in those areas at least annually, at intervals not to exceed 15 months.
When initial or refresher training is provided, the documentation shall be
maintained in the Spire STL Pipeline Energy WorldNet system. At a minimum,
the training record shall contain the following information:
• The location and date of the training session.
• A description of the subject matter.
• A list of all persons attending the training.
• The name of the instructor(s).



By failing to conduct refresher training for all appropriate personnel, Spire did not assure that its
personnel were knowledgeable, nor verify that the training was effective, per the requirements of
§ 192.615(b)(2).
4. § 192.706 Transmission lines: Leakage Surveys.
Leakage surveys of a transmission line must be conducted at intervals not exceeding
15 months, but at least once each calendar year. However, in the case of a
transmission line which transports gas in conformity with § 192.625 without an odor
or odorant, leakage surveys using leak detector equipment must be conducted—
(a) In Class 3 locations, at intervals not exceeding 71⁄2 months, but at least twice each
calendar year;
Spire failed to conduct leakage surveys of a transmission line at intervals not exceeding 15
months, but at least once each calendar year, per the requirements of § 192.706(a). Specifically,
Spire failed to perform leakage surveys by a method appropriate for identifying leaks at three
locations.
PHMSA inspected Spire’s records of monthly aerial patrols, which were performed to look for
indications of leaks affecting surface vegetation on Spire’s right-of-way (ROW). PHMSA found
that tree canopy over the ROW had prohibited observation of the surface conditions from the air.
Based on a review of historical Google Earth imagery, PHMSA found that the ROW was
obstructed by tree canopy overgrowth beginning in 2020. Due to the dense tree canopy Spire
could not observe indications of leaks affecting surface vegetation over-the-line in its growth
cycle during the aerial patrols. Spire did not conduct another means of patrol such as by ground
patrol. In the field, PHMSA confirmed the ROW conditions with those viewed in the records.
In response to PHMSA’s findings, during the inspection, Spire stated, "Leak surveys for the
years 2020-2023 were not conducted in wooded areas between HDD entry and exit points due to
FERC’s requirement to not clear ROW areas within HDD segments.” This includes the
following locations:
Location Starting Point Ending Point Distance Class Odorant
Mississippi River
HDD
38.948453°
,
90.378981°
-
38.942572°
90.382897° ,
-
1915 ft 1 No
Highway 367 HDD 38.819331°
,
90.233597°
-
38.815431°
90.224403° ,
-
1545 ft 3 Yes
Spanish Lake HDD 38.801217°
,
90.197081°
-
38.800567°
-
,
90.1955° 465 ft 3 Yes
Thus, at these locations, Spire failed to perform leakage patrols at the appropriate intervals for
one Class 1 and two Class 3 areas, per the requirements of § 192.706(a).



5. § 192.907 What must an operator do to implement this subpart?
(a) General. No later than December 17, 2004, an operator of a covered pipeline
segment must develop and follow a written integrity management program that
contains all the elements described in § 192.911 and that addresses the risks on each
covered transmission pipeline segment. The initial integrity management program
must consist, at a minimum, of a framework that describes the process for
implementing each program element, how relevant decisions will be made and by
whom, a time line for completing the work to implement the program element, and
how information gained from experience will be continuously incorporated into the
program. The framework will evolve into a more detailed and comprehensive
program. An operator must make continual improvements to the program.
Spire failed to follow its written integrity management program, per the requirements of
§ 192.907(a). Specifically, Spire failed to follow its procedures for selecting and performing
preventive and mitigative measures (PMM) per section 12 of its Integrity Management Plan.
Section 12.4.2 of the Integrity Management Plan stated, “If any recommendations are rejected
during Management Review, the justification for the rejection should be documented. All
approved recommendations should be added to a master P&M recommendation list.” During a
review of records, PHMSA found that Spire had not formally documented its evaluation process,
selection, or implementation of PMM. Thus, the operator had no record of selecting and
performing preventive and mitigative measures required per § 192.935, from 2019-2022, and
therefore failed to follow its integrity management program as required by § 192.907(a).
6. § 192.947 What records must an operator keep?
An operator must maintain, for the useful life of the pipeline, records that
demonstrate compliance with the requirements of this subpart. At minimum, an
operator must maintain the following records for review during an inspection.
(a) . . . .
(b) Documents supporting the threat identification and risk assessment in
accordance with § 192.917;
Spire failed to maintain documents that support its identification and risk assessment of the threat
of equipment failure, as required by § 192.947(b). Spire’s Integrity Management Plan, section
4.9.4, “Equipment Threats,” refers to Appendix D Table 4-3 for documentation of the threat
assessment. Subsequent to PHMSA’s request during the inspection, on August 15, 2023, Spire
provided a completed Table 4-3, dated August 23, 2023. Spire personnel stated this was
completed after PHMSA requested one be provided, as Spire could not locate a previous version.
Spire also stated that its risk model did not have equipment listed as a threat in any other section.
Therefore, Spire failed to keep records supporting the threat identification of equipment failure,
per the requirements of § 192.947(b).
Proposed Civil Penalty
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a
related series of violations. For violation occurring on or after January 6, 2023 and before



December 28, 2023, the maximum penalty may not exceed $257,664 per violation per day the
violation persists, up to a maximum of $2,576,627 for a related series of violations. For violation
occurring on or after March 21, 2022 and before January 6, 2023, the maximum penalty may not
exceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,412 for
a related series of violations. For violation occurring on or after May 3, 2021 and before March
21, 2022, the maximum penalty may not exceed $225, 134 per violation per day the violation
persists, up to a maximum of $2,251,334 for a related series of violations. For violation
occurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not
exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for
a related series of violations. For violation occurring on or after July 31, 2019 and before January
11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation
persists, up to a maximum of $2,186,465 for a related series of violations. For violation
occurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may
not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679.
We have reviewed the circumstances and supporting documentation involved for the above
probable violations and recommend that you be preliminarily assessed a civil penalty of $50,200
as follows:
Item number
PENALTY
3
$50,200
Proposed Compliance Order
With respect to Items 1, 4, and 5 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous
Materials Safety Administration proposes to issue a Compliance Order to Spire. Please refer to
the Proposed Compliance Order, which is enclosed and made a part of this Notice.
Warning Item
With respect to Items 2 and 6, we have reviewed the circumstances and supporting documents
involved in this case and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to promptly correct these items. Failure to do
so may result in additional enforcement action.
Response to this Notice
This Notice is issued in accordance with 49 C.F.R. § 190.207(c). Any response you may have
submitted to the original Notice is no longer applicable. You must respond as set forth below.
Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators
in Enforcement Proceedings. Please refer to this document and note the response options. All
material you submit in response to this enforcement action may be made publicly available. If
you believe that any portion of your responsive material qualifies for confidential treatment



under 5 U.S.C. § 552(b), along with the complete original document you must provide a second
copy of the document with the portions you believe qualify for confidential treatment redacted
and an explanation of why you believe the redacted information qualifies for confidential
treatment under 5 U.S.C. § 552(b).
Following your receipt of this Notice, you have 30 days to respond as described in the enclosed
Response Options. If you do not respond within 30 days of receipt of this Notice, this constitutes
a waiver of your right to contest the allegations in this Notice and authorizes the Associate
Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to
you and to issue a Final Order. If you are responding to this Notice, we propose that you submit
your correspondence to my office within 30 days from receipt of this Notice. The Region
Director may extend the period for responding upon a written request timely submitted
demonstrating good cause for an extension.
In your correspondence on this matter, please refer to CPF 3-2025-003-NOPV and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Randy Wilson, Director, Pipeline & System Integrity, Spire STL Pipeline, LLC,
randy.wilson@spireenergy.com
Nicole Christianer, Manager, Transmission Integrity, Spire STL Pipeline, LLC,
nicole.christianer@spireenergy.com
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Enforcement Proceedings



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Spire a Compliance Order incorporating the
following remedial requirements to ensure the compliance of with the pipeline safety regulations:
A. B. C. D. In regard to Item 1 of the Notice, pertaining to Spire’s failure to have a continuing
program to minimize the detrimental effects of stray currents, Spire must:
a. Develop and provide a detailed continuing program per § 192.473 to the
Central Region Director for review and approval within 30 days of receipt of
the Final Order.
b. Implement the continuing program and provide initial survey results from
monitoring, including any recommendations from findings, to the Central
Region Director within 180 days of receipt of the Final Order.
1. The implementation shall include (1) performing training; (2) identifying
all foreign line crossings and sources of stray AC current; (3) monitoring
each location at the location of the pipeline crossing; and (4) reporting
findings and any remedial actions.
In regard to Item 4 of the Notice, pertaining to the failure to patrol its right-of-way
(ROW) using an appropriate means Spire must:
a. Provide to the Central Region Director record of leakage surveys conducted at
the referenced locations using an appropriate method for the conditions (e.g.,
time of year, weather conditions, ground visibility, soil conditions, location of
the pipeline, etc.) within 60 days of receipt of the Final Order.
In regard to Item 5 of the Notice, pertaining to the failure to follow procedures for
selecting and performing preventive and mitigative measures, Spire must:
a. Provide records supporting the evaluation and selection of preventive and
mitigative measures to the Central Region Director within 30 days of receipt
of the Final Order for review and approval.
b. Provide records supporting the implementation and periodic evaluation of the
preventive and mitigative measures to the Central Region Director within 365
days of receipt of the Final Order.
It is requested (not mandated) that Spire STL Pipeline, LLC maintain
documentation of the safety improvement costs associated with fulfilling this
Compliance Order and submit the total to Gregory A. Ochs, Director, Central
Region, Pipeline and Hazardous Materials Safety Administration. It is requested
that these costs be reported in two categories: (1) total cost associated with
preparation/revision of plans, procedures, studies and analyses, and (2) total cost
associated with replacements, additions and other changes to pipeline
infrastructure.

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/32025003NOPV>
- Source ID: `phmsa-enforcement`
- SHA-256: `1be2b15191aa0b71fcd798b9eb8d0e1657c579415235af9444613ee116fcc14a`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-23T03:24:43.582Z
- Document slug: `phmsa-enforcement-32025003nopv`

### Source metadata

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  "operator": "SPIRE STL PIPELINE LLC",
  "region": "Central",
  "pipelineType": "INTERSTATE GAS TRANSMISSION",
  "caseStatus": "OPEN",
  "citedSections": [
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    "192.605(a)",
    "192.615(b)(2)",
    "192.706(a)",
    "192.907(a)",
    "192.947(b)"
  ],
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  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
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}
```