{"operation":"document","citation":"CPF 32025002WL","title":"SPIRE MOGAS PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-05-19","effective_on":null,"summary":"CLOSED warning letter citing 192.631(a)(1), 192.631(c)(1), 192.631(c)(2), 192.631(c)(4), 192.631(h)(6).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025002wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025002wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025002wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32025002WL","body":"Warning Letter involving SPIRE MOGAS PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 192.631(a)(1),  192.631(c)(1),  192.631(c)(2),  192.631(c)(4),  192.631(h)(6). The case was opened on 2025-05-19 and is reported as closed as of 2025-05-19. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32025002WL_Warning Letter_05192024_(22-237906).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025002WL/32025002WL_Warning%20Letter_05192024_(22-237906).pdf\n\n32025002WL_Warning Letter_05192024_(22-237906)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025002WL/32025002WL_Warning%20Letter_05192024_(22-237906)_text.pdf\n\n32025002WL_Warning Letter_05192024_(22-237906)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO:\nscott.smith@spireenergy.com; mark.lowe@spireenergy.com;\nrandy.wilson@spireenergy.com; dave.feeman@spireenergy.com\nMay 19, 2025\nMr. Scott Smith\nPresident, Spire Midstream\nSpire MOGAS Pipeline LLC\n3773 Richmond Avenue, Suite 300\nHouston, TX 77002\nCPF 3-2025-002-WL\nDear Mr. Smith:\nFrom May 9 through May 13, 2022 and September 21, 2022, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant\nto Chapter 601 of 49 United States Code (U.S.C.), virtually inspected MoGAS Pipeline, LLC’s\n(MoGAS) procedures and records for Control Room Management (CRM) in Wentzville,\nMissouri. Following the inspection, MoGAS was acquired by Spire Missouri Inc. East in\nJanuary 2024.1\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection. . . .\n1 National Registry Notification B-20240423-52614 (April 23, 2024). A new OPID (OPID 40855) was requested\nand issued under the name Spire MoGAS Pipeline, LLC (SpireMoGAS).\n\n\n\n(a) . . . .\n(b) Provide adequate information. Each operator must provide its controllers with\nthe information, tools, processes and procedures necessary for the controllers to\ncarry out the roles and responsibilities the operator has defined by performing each\nof the following:\n(1) Implement sections 1, 4, 8, 9, 11.1, and 11.3 of API RP 1165 (incorporated\nby reference, see §192.7) whenever a SCADA system is added, expanded or\nreplaced, unless the operator demonstrates that certain provisions of sections 1,\n4, 8, 9, 11.1, and 11.3 of API RP 1165 are not practical for the SCADA system\nused;\nMoGAS failed to provide records that demonstrated that it implemented sections 1, 4, 8, 9, 11.1,\nand 11.3 of API RP 1165, as required by §§ 192.631(c)(1) and 192.631(j)(1). While MoGAS’\n“Control Room Manual,” (version 3.2, effective 2019) (CRM Plan), section 4.1 stated, “sections\n1, 4, 8, 9, 11.1, and 11.3 of API RP-1165 shall be implemented by MoGAS whenever the\nSCADA system is added, expanded or replaced after August 1, 2012,” MoGAS indicated to\nPHMSA that, to establish consistency in their SCADA screen design, it “[u]tilize[d] one of its\nexisting SCADA screens with similar layout to produce the basis layout for new station screens\nto maintain consistency with other station screens.” While this supported a level of consistency\nwhen designing and publishing screens, it was not adequate to demonstrate compliance with\n§§ 192.631(c)(1) and 192.631(j)(1) because there was no audit or review performed to verify the\nSCADA design manual was compliant with API RP 1165 and the screens were compliant with\nAPI RP 1165. Therefore, MoGAS failed to ensure API RP 1165 sections 1, 4, 8, 9, 11.1, and\n11.3 were implemented, as required by §§ 192. 631(c)(1) and 192.631(j)(1).\n2. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection . . . .\n(b) . . . .\n(c) Provide adequate information. Each operator must provide its controllers with\nthe information, tools, processes and procedures necessary for the controllers to\ncarry out the roles and responsibilities the operator has defined by performing each\nof the following:\n(1) . . . .\n(2) Conduct a point-to-point verification between SCADA displays and related\nfield equipment when field equipment is added or moved and when other\nchanges that affect pipeline safety are made to field equipment or SCADA\ndisplays;\nMoGAS failed to provide a record to demonstrate the completion of the initial point-to-point\nwhen the new SPIRE STL interconnect was added to the SCADA display, per the requirements\nof § 192.631(c)(2). The SPIRE STL facility became operational on December 11, 2020 and\n\n\n\npublished to the SCADA system for controllers to monitor and control that same day. Per\nMoGAS, a point-to-point (P2P) was completed prior to publishing to the production SCADA\nsystem. However, MoGAS was unable to provide a record of the P2P verification, as required\nby § 192.631(j)(1).\nIn addition, MoGAS’ CRM Plan, section 4.2, was inadequate to support a thorough P2P to\ndemonstrate compliance. MoGAS’ CRM Plan identified two forms—Form 4.2 Alarm Set Point\nand Verification and Form 6.2c, for safety related points—required to be used to document the\nP2P verification. MoGAS’ CRM Plan did not provide enough detail on what was required to be\ndocumented on each form. For example, subsections 2b and 2c stated, “Controllers will confirm\nthat the SCADA display is reflecting the same values being observed in the field and\ndocumented via Form 4.2 Alarm Set Points and Verification Log. If the point is a Safety Related\nPoint it will be verified on Form 6.2c. Information that must be verified:….(b) [d]ata value or\nstatus, and (c) any alarm settings.” The intent of a P2P is to verify field conditions and data\nmatch SCADA information being presented to the controller. Thus, P2P records need to\ndocument the comparison of values/status and not just that the comparison was observed.\nTherefore, the CRM Plan failed to include required documentation, such as documenting the\nfield value/status and SCADA value/status. For adequate documentation of alarms, the\ndocumentation must include verification that the alarms presented at the designated set points\nwith the correct priority and description. CRM Plan section 3 only required a “representative\nsampling of SCADA screens.” This is not adequate for new commissioned points into SCADA.\nAll screens must be verified and documented.\nFurthermore, the CRM Plan did not include documentation requirements for: (1) the name of the\nemployee verifying in the field and the name of the employee verifying SCADA, (2) the date of\nthe verification, (3) whether the point was verified live or through simulation, and (4) any\ncomments related to the verification and follow up items to correct and retest the point if\nrequired. Therefore, MoGAS’ procedures were deficient and caused MoGAS to be unable to\nprovide adequate records demonstrating the completion of the P2P when the new SPIRE STL\ninterconnect was added to the SCADA display, per the requirements of § 192.631(c)(2).\n3. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection . . . .\n(b) . . . .\n(c) Provide adequate information. Each operator must provide its controllers with\nthe information, tools, processes and procedures necessary for the controllers to\ncarry out the roles and responsibilities the operator has defined by performing each\nof the following:\n(1) . . . .\n(4) Test any backup SCADA systems at least once each calendar year, but at\nintervals not to exceed 15 months;\n\n\n\nMoGAS failed to adequately test its backup SCADA system and failed to provide a record of the\ntests for the backup SCADA system in 2019 and 2021, per the requirements of §§ 192.631(c)(4)\nand 192.631(j)(1). MoGAS also failed to follow its CRM Plan, section 4.4, which required\ntesting both control room backup systems, “[a]t least monthly, in periods not to exceed 15\nmonths.” Specifically, in 2019 and 2021, MoGAS only tested the functionality to transfer and\noperate on the backup SCADA servers and did not travel to the backup control room and operate\nfrom the facility. Backup SCADA systems include SCADA servers, HMIs, printers, IT business\nsystems, FAX machines, building access and anything related to the function of a control room.\nIn addition, MoGAS’ CRM Plan section 4.4 was inadequate to provide instructions to MoGAS’\ncontrollers on how to thoroughly conduct and document the test. The CRM Plan failed to\ncontain any instructions on (1) how the transfer was to be completed, (2) how controllers were to\nrelocate, (3) who and what are the qualifications to monitor the system during travel between\nfacilities, as the procedure stated, “[field] personnel [at the back up location] may monitor the\nsystem until [primary control room] gas controllers can travel to the [backup] location to take\nover,” and (4) how the system would be transferred back from the backup control room to\nprimary control room. While MoGAS’ CRM Plan contained a requirement to “confirm\nreception of good data,” it did not require the use of a check list, or other documentation tools, to\ndocument the testing of key SCADA functions or to document the operating server. Therefore,\nMoGAS failed to adequately test its backup SCADA system, per the requirements of\n§ 192.631(c)(4).\n4. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection. . . .\n(b) . . . .\n(h) Training. Each operator must establish a controller training program and\nreview the training program content to identify potential improvements at least\nonce each calendar year, but at intervals not to exceed 15 months. An operator's\nprogram must provide for training each controller to carry out the roles and\nresponsibilities defined by the operator. In addition, the training program must\ninclude the following elements:\n(1) . . . .\n(6) Control room team training and exercises that include both controllers and\nother individuals, defined by the operator, who would reasonably be expected to\noperationally collaborate with controllers (control room personnel) during\nnormal, abnormal or emergency situations. Operators must comply with the\nteam training requirements under this paragraph no later than January 23, 2018.\nMoGAS failed to have a procedure to address the requirements to conduct team training and\nfailed to conduct team training for 2019, 2020, 2021, as required by §§ 192.605(b)(12) and\n192.631(h)(6). When asked by PHMSA during the inspection, MoGAS failed to (1) provide a\n\n\n\nprocedure for the team training, or (2) conduct control room team training, and (3) identify\npersonnel that would operationally collaborate with controllers as required by the code.\nTherefore, MoGAS failed to follow the requirements of §§ 192.605(b)(12) and 192.631(h)(6).\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\nrelated series of violations. For violation occurring on or after December 28, 2023 and before\nDecember 30, 2024 the maximum penalty may not exceed $266,015 per violation per day the\nviolation persists, up to a maximum of $2,660,135 for a related series of violations. For violation\noccurring on or after January 6, 2023 and before December 28, 2023 the maximum penalty may\nnot exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627\nfor a related series of violations. For violation occurring on or after March 21, 2022 and before\nJanuary 6, 2023 the maximum penalty may not exceed $239,142 per violation per day the\nviolation persists, up to a maximum of $2,391,142 for a related series of violations. For violation\noccurring on or after May 3, 2021 and before March 21, 2022 the maximum penalty may not\nexceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for\na related series of violations. For violation occurring on or after January 11, 2021 and before\nMay 3, 2021 the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019 and before January 11, 2021 the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 3-2025-002-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\nthe redacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\nSincerely,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Mark Lowe, Senior VP- Eng, Gas Supply & Ops Services, Spire MOGAS Pipeline, LLC,\nmark.lowe@spireenergy.com\nRandy Wilson, Director Compliance, Spire MOGAS Pipeline, LLC,\nrandy.wilson@spireenergy.com\nDavid Feeman, Director, Spire MOGAS Pipeline, LLC, dave.feeman@spireenergy.com","truncated":false,"body_characters":14701}