{"operation":"document","citation":"CPF 32022068NOA","title":"SPIRE MISSOURI INC. EAST — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-12-14","effective_on":null,"summary":"CLOSED notice of amendment citing 195.505(b), 195.505(h).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32022068noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32022068noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32022068noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32022068NOA","body":"Notice of Amendment involving SPIRE MISSOURI INC. EAST. PHMSA's enforcement data identifies the cited regulations as 195.505(b),  195.505(h). The case was opened on 2022-12-14 and is reported as closed as of 2023-03-31. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32022068NOA_Closure Letter_03312023_(22-233904).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022068NOA/32022068NOA_Closure%20Letter_03312023_(22-233904).pdf\n\n32022068NOA_Closure Letter_03312023_(22-233904)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022068NOA/32022068NOA_Closure%20Letter_03312023_(22-233904)_text.pdf\n\n32022068NOA_Notice of Amendment_12142022_(22-233904).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022068NOA/32022068NOA_Notice%20of%20Amendment_12142022_(22-233904).pdf\n\n32022068NOA_Notice of Amendment_12142022_(22-233904)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022068NOA/32022068NOA_Notice%20of%20Amendment_12142022_(22-233904)_text.pdf\n\n32022068NOA_Closure Letter_03312023_(22-233904)_text.pdf\n\nVIA ELECTRONIC MAIL TO: scott.carter@spireenergy.com;\ncraig.hoeferlin@spireenergy.com; Bob.Gardner@spireenergy.com\nMarch 31, 2023\nMr. Scott Carter, President/CEO\nPresident/CEO\nSpire Missouri Inc. East\n700 Market Street\nSt. Louis, Missouri 63101\nRE: CPF No. 3-2022-068-NOA\nDear Mr. Carter:\nFrom March 15, 2022 through March 17, 2022, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\nperformed a specialized inspection of Spire Missouri, Inc. East’s (Spire) Highly Volatile Liquid (HVL)\npipeline system located in St. Louis, Missouri. As a result of the inspection, Spire was issued a Notice\nof Amendment on December 14, 2022, which proposed amendment of your procedures.\nSpire submitted its amended procedures on January 13, 2023. My staff has reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you for\nyour cooperation.\nSincerely,\nGregory A. Ochs\nDirector, Central\nPipeline and Hazardous Materials Safety Administration\ncc: Bob Gardner, Director Compliance and Pipeline Integrity (Bob.Gardner@spireenergy.com);\nCraig Hoeferlin, VP, Operations Services and SMS, (craig.hoeferlin@spireenergy.com)\n\n32022068NOA_Notice of Amendment_12142022_(22-233904)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: craig.hoeferlin@spireenergy.com;\nBob.Gardner@spireenergy.com\nDecember 14, 2022\nMr. Craig Hoeferlin\nVice President, Operations Services and SMS\nSpire Missouri Inc. East\n700 Market Street\nSt. Louis, Missouri 63101\nCPF 3-2022-068 NOA\nDear Mr. Hoeferlin:\nFrom March 15, 2022 through March 17, 2022, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\nperformed a specialized inspection of Spire Missouri, Inc. East’s (Spire) Highly Volatile Liquid (HVL)\npipeline system which contains propane and butane and is located in St. Louis, Missouri.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within Spire’s\nplans or procedures, as described below:\n1. § 195.505 Qualification Program\nEach operator shall have and follow a written qualification program. The program shall\ninclude provisions to:\n(a) . . .\n(b) Ensure through qualification that individuals performing covered tasks are qualified.\nSpire’s OQ program is inadequate because it does not ensure through qualification that\nindividuals performing covered tasks are qualified.\nSpecifically, the evaluation methods do not provide adequate information (e.g., O&M\nprocedure requirements, list of questions or specific step/procedure, checklist of items,\nidentification of equipment used) for evaluators to use to objectively verify knowledge, skills,\nand abilities during performance evaluations. During the inspection, PHMSA reviewed\nevaluators’ checklists for several covered tasks and it was noted that they did not provide\n\n\n\nadequate information. The evaluators’ checklist included generic language and did not specify\nsteps and/or procedures on how to perform the covered tasks.\nThe evaluators’ checklist should be revised to include specific steps and/or procedures to\nproperly evaluate an individual.\n2. § 195.505 Qualification Program\nEach operator shall have and follow a written qualification program. The program shall\ninclude provisions to:\n(a) . . .\n(h) After December 16, 2004, provide training, as appropriate, to ensure that individuals\nperforming covered tasks have the necessary knowledge and skills to perform the\ntasks in a manner that ensures the safe operation of pipeline facilities;\nSpire’s OQ program is inadequate because it did not include procedures for appropriate training\nto ensure individuals performing covered tasks have the necessary knowledge and skills to\nperform tasks in a manner that ensures the safe operation of pipeline facilities. Specifically,\nSpire’s training program (Lesson Plan for NGL Training) did not contain sufficient detail in\nknowledge and skills needed for safe operation because the procedures contained only an\noverview of propane characteristics, ignition sources and threats to the system.\nAdditionally, Spire’s OQ plan lacked a process for adequate documentation of training. The\nplan states that training will be provided, but it lacked a defined process for documenting the\ntraining performed for the covered tasks. Specifically, Spire’s OQ plan did not require adequate\ndocumentation for personnel trained to react to Abnormal Operating Conditions (AOC) to\nsafely startup, shutdown, operate, and monitor the HVL pipeline.\nThe Spire OQ plan must therefore be revised to include detailed training that includes the\nknowledge and skills for safe operation, including detailed documentation of the results of\ntraining as applicable to each task. The procedures must also be revised to include adequate\ndocumentation requirements showing that personnel are able to properly recognize AOCs on\nthe pipeline prior to startup, during operation, and when shut-in based on operational data such\nas pressure, flow rates, and volume changes.\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 part\nof this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you submit in\nresponse to this enforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along\nwith the complete original document you must provide a second copy of the document with the\nportions you believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\n\n\n\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 receipt\nof this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and\nauthorizes 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 procedures\nare found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures\nto correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose\nthat you submit your amended procedures to my office within 60 days of receipt of this Notice. This\nperiod may be extended by written request for good cause. Once the inadequacies identified herein\nhave been addressed in your amended procedures, this enforcement action will be closed.\nIt is requested that Spire maintain documentation of the safety improvement costs associated with\nfulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to\nGregory A. Ochs, Director, Central, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 3-2022-068 NOA and, for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\nGregory A. Ochs\nDirector, Central\nPipeline and Hazardous Materials Safety Administration\ncc: Craig Hoeferlin, VP, Operations Services and SMS, (craig.hoeferlin@spireenergy.com)\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":8891}