{"operation":"document","citation":"CPF 32024075NOA","title":"SPIRE STL PIPELINE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-12-20","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024075noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024075noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024075noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32024075NOA","body":"Notice of Amendment involving SPIRE STL PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 192.605(a). The case was opened on 2024-12-20 and is reported as closed as of 2025-12-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32024075NOA_Closure Letter_12172025_(23-264381).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024075NOA/32024075NOA_Closure%20Letter_12172025_(23-264381).pdf\n\n32024075NOA_Closure Letter_12172025_(23-264381)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024075NOA/32024075NOA_Closure%20Letter_12172025_(23-264381)_text.pdf\n\n32024075NOA_Notice of Amendment_12202024 (23-264381).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024075NOA/32024075NOA_Notice%20of%20Amendment_12202024%20(23-264381).pdf\n\n32024075NOA_Notice of Amendment_12202024 (23-264381)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024075NOA/32024075NOA_Notice%20of%20Amendment_12202024%20(23-264381)_text.pdf\n\n32024075NOA_Operator Response to Notice_01192025 (23-264381).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024075NOA/32024075NOA_Operator%20Response%20to%20Notice_01192025%20(23-264381).pdf\n\n32024075NOA_Notice of Amendment_12202024 (23-264381)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: scott.smith@spireenergy.com;\nrandy.wilson@spireenergy.com; nicole.christianer@spireenergy.com\nDecember 20, 2024\nScott Smith\nPresident\nSpire STL Pipeline, LLC\n3773 Richmond Ave\nHouston, TX 77046\nCPF 3-2024-075-NOA\nDear Mr. Smith:\nFrom February 2, 2023, to February 14, 2024, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected on-site Spire STL Pipeline, LLC’s (Spire) operations and maintenance\nprocedures for the Spire STL Pipeline, LLC in St. Louis, Missouri.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nSpire’s plans or procedures. The items inspected and the inadequacies are described below:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nSpire’s “Spire STL Pipeline Operations & Maintenance Manual” (O&M Manual) failed to have\nadequate procedures for determining whether its cathodic protection (CP) meets the requirements\n\n\n\nof CFR § 192.463(a).\n1 Specifically, Spire’s corrosion control procedures failed to adequately\naddress how to measure CP protective voltage in accordance with “Appendix D to Part 192:\nCriteria for Cathodic Protection and Determination of Measurements,” in areas where alternating\ncurrent (AC) mitigation devices influence voltage measurement.\nDuring the inspection, PHMSA found that Spire used the negative 0.85 volt criteria, as detailed\nin Appendix D, section I, and that Spire’s system contained AC mitigation devices (decouplers)\nthat discharged current during annual surveys, which affected the voltage shift (IR drop) and the\naccuracy of the results of annual survey measurements. PHMSA determined that Spire did not\nhave a process or procedure for considering the IR drop at locations of AC mitigation devices\nwhen interpreting survey results, as required by Section II of Appendix D.\nFrom a review of Spire’s records, PHMSA found that in 2020, Spire received a recommendation\nfrom a contracted third party specialist, Lake Superior Consulting, LLC, that during electrical\nsurveys, due to device capacitance, Spire should extend the interruption cycle of impressed\nprotective current from their rectifiers to 9 seconds “on” and 3 seconds “off,” to account for the\ngradual discharge of current from the decouplers. This recommendation was in-line with the\ndevice manufacturer’s recommendations. Spire did not revise its procedures in accordance with\nthese recommendations. To determine whether the cathodic protection meets the requirements of\n§ 192.463, Spire must amend its procedures to have a process to appropriately consider the IR\ndrop caused by the decouplers.\n2. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nSpire failed to have adequate procedures to inspect and evaluate each pipeline or portion of the\npipeline that is exposed to the atmosphere for evidence of atmospheric corrosion, per the\nrequirements of § 192.481. Specifically, Spire’s procedures failed to address how to evaluate and\ncategorize atmospheric corrosion found during inspections. The evaluation and categorization of\nthe corrosion affects how remediation is to be done, per § 192.481(c).2\n1 49 CFR 192.463(a) states: “Each cathodic protection system required by this subpart must provide a level of\ncathodic protection that complies with one or more of the applicable criteria contained in appendix D of this part. If\nnone of these criteria is applicable, the cathodic protection system must provide a level of cathodic protection at\nleast equal to that provided by compliance with one or more of these criteria.”\n2 49 CFR 192.481(c) states: “If atmospheric corrosion is found during an inspection, the operator must provide\nprotection against the corrosion as required by § 192.479.”\n\n\n\nSpire’s O&M manual, section 7.4.8.3, specified that atmospheric corrosion conditions are to be\nevaluated based on rust grade levels provided in ASTM D610-01. However, after interviewing\nSpire’s qualified individuals for atmospheric corrosion, PHMSA found that the O&M Manual\nwas out of date, and that Spire used Standard Operating Practice (SOP) 190.E.3 for evaluating\natmospheric corrosion conditions, rather than ASTM D610-01.\nSOP 190 E.3, section 2.1, stated, \"Atmospheric corrosion is defined as corrosion which causes\ndeterioration or pitting of the pipe surface resulting from a reaction with the atmospheric\nenvironment. Smooth surface rust shall not be considered atmospheric corrosion.\" PHMSA\nfound that Spire’s Asset Workforce Management System, MAXIMO, provided, four options for\ndocumenting the atmospheric corrosion condition: clean, localized, pitting, or scaling.\nHowever, neither SOP 190.E.3 nor the MAXIMO system defined or provided clear guidance for\ndetermining how to identify and select between the four options. Specifically, SOP 190.E.3\nfailed adequately define the conditions that are considered detrimental to safe operation and\nrequire repair to protect against the corrosion, per § 192.481(c).\nSpire must amend its procedures to clearly state how it will evaluate, categorize, and address an\natmospheric corrosion condition in accordance with the requirements of § 192.481 (c).\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\nEnforcement Proceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 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\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n30 days of receipt of this Notice. This period may be extended by written request for good cause.\nOnce the inadequacies identified herein have been addressed in your amended procedures, this\nenforcement action will be closed.\n\n\n\nIt is requested that Spire STL Pipeline, LLC maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Gregory A. Ochs, Director, Central Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 3-2024-075-NOA and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Randy Wilson, Director, Pipeline & System Integrity, Spire STL Pipeline, LLC,\nrandy.wilson@spireenergy.com\nNicole Christianer, Manager, Transmission Integrity, Spire STL Pipeline, LLC,\nnicole.christianer@spireenergy.com\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n\n32024075NOA_Closure Letter_12172025_(23-264381)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\n901 Locust Street, Suite 480\nKansas City, MO 64106\nVIA ELECTRONIC MAIL TO: scott.smith@spireenergy.com;\nrandy.wilson@spireenergy.com; nicole.christianer@spireenergy.com\nDecember 17, 2025\nMr. Scott Smith, President\nSpire STL Pipeline, LLC\n3773 Richmond Avenue\nHouston, TX 77046\nRE: CPF 3-2024-075-NOA\nDear Mr. Smith:\nFrom February 2, 2023, to February 14, 2024, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), conducted an inspection of Spire STL Pipeline, LLC’s (Spire) operations and\nmaintenance procedures for the Spire STL Pipeline, LLC in St. Louis, Missouri. On December\n20, 2024, pursuant to 49 CFR § 190.206, PHMSA issued a Notice of Amendment which proposed\namendment of Spire’s procedures.\nSpire submitted its amended procedures on January 19, 2025 and August 23, 2025. PHMSA has\nreviewed the amended procedures, and it appears that the inadequacies outlined in the Notice of\nAmendment have been corrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Randy Wilson, Director, Pipeline & System Integrity, Spire STL Pipeline, LLC,\nrandy.wilson@spireenergy.com\nNicole Christianer, Manager, Transmission Integrity, Spire STL Pipeline, LLC,\nnicole.christianer@spireenergy.com","truncated":false,"body_characters":12177}