{"operation":"document","citation":"CPF 120190010M","title":"SPIRE MISSOURI INC. EAST — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-05-30","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120190010m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120190010m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120190010m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120190010M","body":"Notice of Amendment involving SPIRE MISSOURI INC. EAST. PHMSA's enforcement data identifies the cited regulation as 192.12(e). The case was opened on 2019-05-30 and is reported as closed as of 2019-12-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120190010M_Closure Letter_12192019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120190010M/120190010M_Closure%20Letter_12192019.pdf\n\n120190010M_Closure Letter_12192019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120190010M/120190010M_Closure%20Letter_12192019_text.pdf\n\n120190010M_Notice of Amendment_05302019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120190010M/120190010M_Notice%20of%20Amendment_05302019.pdf\n\n120190010M_Notice of Amendment_05302019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120190010M/120190010M_Notice%20of%20Amendment_05302019_text.pdf\n\n120190010M_Operator Response to Notice_06282019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120190010M/120190010M_Operator%20Response%20to%20Notice_06282019.pdf\n\n120190010M_Closure Letter_12192019_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nDecember 19, 2019\nMr. Craig R. Hoeferlin\nVice President, Operations Services\nSpire Missouri Inc. East\n700 Market Street\nSt. Louis, MO 63101\nCPF 1-2019-0010M\nDear Mr. Hoeferlin:\nFrom November 6-8, 2018, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Spire\nMissouri Inc. East’s (Spire) procedures for Functional Integrity of Underground Natural Gas\nStorage in St. Louis, Missouri. As a result of the inspection, Spire was issued a Notice of\nAmendment on May 30, 2019, which proposed amendment of your procedures.\nSpire submitted its amended procedures on or about August 1, 2019. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120190010M_Notice of Amendment_05302019_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nMay 30, 2019\nMr. Craig R. Hoeferlin\nVice President, Operations Services\nSpire Missouri Inc. East\n700 Market Street\nSt. Louis, MO 63101\nCPF 1-2019-0010M\nDear Mr. Hoeferlin:\nFrom November 6-8, 2018, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Spire\nMissouri Inc. East’s (Spire) procedures for Functional Integrity of Underground Natural Gas\nStorage in St. Louis, Missouri. Specifically, the Florissant Dome Storage field in Florissant,\nMissouri was inspected.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nSpire’s plans or procedures, as described below:\n1. § 192.12 Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nSpire’s written procedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1171 were inadequate. Specifically, Spire’s procedures for the functional\nintegrity of the reservoir and wells failed to describe the integrity work being performed.\n\n\n\nCPF 1-2019-0010M\nDuring the inspection, Spire presented 26 standards that cover various integrity activities, but did\nnot have prescriptive procedures associated with the standards.\n2. § 192.12 Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nSpire’s written procedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1171 were inadequate. Specifically, Spire’s written procedures for\nannular pressure thresholds did not specify what the thresholds were in accordance with API RP\n1171, Section 9.3.2 Well Integrity Monitoring.\nDuring the inspection, Spire informed PHMSA that annular pressures outside the normal range\nwould be further investigated. Clearly defined thresholds are necessary to know when/if further\nevaluations are necessary for annular pressures.\n3. § 192.12 Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nSpire’s written procedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1171 were inadequate. Specifically, Spire’s written procedures for the\nblowout contingency plan (BCP) were inadequate because the BCP had not been developed.\nOperators are required to develop and implement a BCP in accordance with API RP 1171, Section\n10.6.3 Blowout Contingency Plan.\n120190010M_NOA_05302019 (163626).docx Page 2 of 3\n\n\n\nCPF 1-2019-0010M\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 60 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Spire Missouri Inc. East maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF 1-2019-0010M and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120190010M_NOA_05302019 (163626).docx Page 3 of 3","truncated":false,"body_characters":8492}