{"operation":"document","citation":"CPF 32025003NOPV","title":"SPIRE STL PIPELINE LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2025-01-16","effective_on":null,"summary":"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).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025003nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025003nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025003nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32025003NOPV","body":"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.\n\nOfficial case documents:\n\n32025003NOPV_Final Order_08052025_(23-264381)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025003NOPV/32025003NOPV_Final%20Order_08052025_(23-264381)_text.pdf\n\n32025003NOPV_Final Order_08052025_(23-264381).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025003NOPV/32025003NOPV_Final%20Order_08052025_(23-264381).pdf\n\n32025003NOPV_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\n\n32025003NOPV_PCP PCO_01162025_(23-264381).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025003NOPV/32025003NOPV_PCP%20PCO_01162025_(23-264381).pdf\n\n32025003NOPV_PCP PCO_01162025_(23-264381)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025003NOPV/32025003NOPV_PCP%20PCO_01162025_(23-264381)_text.pdf\n\n32025003NOPV_Final Order_08052025_(23-264381)_text.pdf\n\nAugust 5, 2025\nVIA ELECTRONIC MAIL TO: scott.smith@spireenergy.com\nScott Smith\nPresident\nSpire STL Pipeline, LLC\n3773 Richmond Avenue\nHouston, Texas 77046\nRe: CPF No. 3-2025-003-NOPV\nDear Mr. Smith:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation, assesses a civil penalty of $50,200, and specifies actions that need to be taken to\ncomply with the pipeline safety regulations. When the civil penalty has been paid and the terms\nof the compliance order are completed, as determined by the Acting Director, Central Region,\nthis enforcement action will be closed. Service of the Final Order by e-mail is effective upon the\ndate of transmission and acknowledgement of receipt as provided under 49 CFR § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosures (Final Order and NOPV)\ncc: David Barrett, Acting Director, Central Region, Office of Pipeline Safety\nRandy Wilson, Director, Pipeline and System Integrity, Spire Inc.\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nSpire STL Pipeline, LLC, ) CPF No. 3-2025-003-NOPV\na subsidiary of Spire Inc., )\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn January 16, 2025,\n1 pursuant to 49 CFR § 190.207, the Director, Central Region, Office of\nPipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Spire STL Pipeline,\nLLC (Respondent). The Notice proposed finding that Respondent had violated the pipeline\nsafety regulations in 49 CFR Part 192 and proposed a civil penalty of $50,200. Effective May\n20, 2025, PHMSA revised its proposed civil penalty calculation policy to use the version of the\nCivil Penalty Worksheet in effect when the alleged violation occurred.2 The new policy did not\nchange the proposed civil penalty in this case. The Notice also proposed certain measures to\ncorrect the violations. Respondent did not contest the allegations of violation, the proposed civil\npenalty, or corrective measures, but included in its Response an explanation regarding the\nlocation of records related to Item 1 of the Notice.\nBased upon a review of all of the evidence, pursuant to section 190.213, I find Respondent\nviolated the pipeline safety regulations listed below, as more fully described in the enclosed\nNotice, which is incorporated by reference:\n49 CFR § 192.473(a) (Item 1) ─ Respondent failed to have a continuing program\nto minimize the detrimental effects of stray currents that could interfere with its\ncathodic protection system.\n49 CFR § 192.615(b)(2) (Item 3) ─ Respondent failed conduct annual refresher\ntraining of its emergency response personnel in order to assure they were\nknowledgeable of its emergency procedures and to verify that the training was\neffective.\n1 The Notice contains a typographical error regarding the year of issuance.\n2 Central Region informed Respondent of the new penalty policy and case file policy via letters dated June 18, 2025,\nand June 20, 2025, respectively.\n\n\n\n49 CFR § 192.706(a) (Item 4) ─ Respondent failed to conduct leakage surveys at\nthe required intervals at one Class 1 location (Mississippi River HDD) and two\nClass 3 locations (Highway 367 HDD and Spanish Lake HDD).\n49 CFR § 192.907(a) (Item 5) ─ Respondent failed to follow its written integrity\nmanagement program for selecting and performing preventative and mitigative\nmeasures.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent. In accordance with 49 CFR § 190.223, I assess Respondent a\ntotal civil penalty of $50,200.\nPayment of the civil penalty must be made within 20 days of service. Federal regulations (49\nCFR § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal\nReserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed\ninstructions are contained in the enclosure. Questions concerning wire transfers should be\ndirected to: Financial Operations Division (AMK-325), Federal Aviation Administration, Mike\nMonroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169.\nThe Financial Operations Division telephone number is (405) 954-8845.\nFailure to pay the $50,200 civil penalty will result in accrual of interest at the current annual rate\nin accordance with 31 U.S.C. § 3717, 31 CFR § 901.9 and 49 CFR § 89.23. Pursuant to those\nsame authorities, a late penalty charge of six percent (6%) per annum will be charged if payment\nis not made within 110 days of service. Furthermore, failure to pay the civil penalty may result\nin referral of the matter to the Attorney General for appropriate action in a district court of the\nUnited States.\nCompliance Actions\nPursuant to 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the\nactions proposed in the enclosed Notice to correct the violations. In its Response, Respondent\nprovided additional information regarding its commitment to complying with the pipeline safety\nregulations and the steps it was taking towards completing the proposed corrective measures.\nThe Director may grant an extension of time to comply with any of the required items upon a\nwritten request timely submitted by the Respondent and demonstrating good cause for an\nextension. Upon completion of the ordered actions, Respondent may request that the Director\nclose the case. Failure to comply with this Order may result in the assessment of civil penalties\nunder 49 CFR § 190.223 or in referral to the Attorney General for appropriate relief in a district\ncourt of the United States.\nWarning Items\nWith respect to Items 2 and 6, the Notice alleged probable violations of 49 CFR §§ 192.605(a)\nand 192.947(b), respectively, but did not propose a civil penalty or compliance order for these\nItems. Therefore, these are considered to be warning items. If OPS finds a violation of any of\nthese Items in a subsequent inspection, Respondent may be subject to future enforcement action.\n\n\n\nThe terms and conditions of this order are effective upon service in accordance with 49 CFR\n§ 190.5.\n___________________________________ _________________________\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety\n\n\n\nNOTICE OF PROBABLE VIOLATION\nand\nPROPOSED COMPLIANCE ORDER\nVIA ELECTRONIC MAIL TO: scott.smith@spireenergy.com;\nrandy.wilson@spireenergy.com; nicole.christianer@spireenergy.com\nJanuary 16, 2024\nScott Smith\nPresident\nSpire STL Pipeline, LLC\n3773 Richmond Ave\nHouston, TX 77046\nCPF 3-2025-003-NOPV\nDear Mr. Smith:\nFrom August 1, 2023 to November 29, 2024, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of 49 United States Code (U.S.C.), inspected Spire STL Pipeline, LLC’s (Spire) natural gas\ntransmission pipeline from St. Louis, Missouri, to Alsey, Illinois.\nAs a result of the inspection, it is alleged that Spire has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 192.473 External corrosion control: Interference currents.\n(a) Each operator whose pipeline system is subjected to stray currents shall have in\neffect a continuing program to minimize the detrimental effects of such currents.\nSpire failed to have a continuing program to minimize the detrimental effects of stray currents, per\nthe requirements of § 192.473(a). The “Spire STL Pipeline Operations & Maintenance Manual,”\n(Spire’s O&M Manual) section 7.2.1 merely stated, \"[i]f subject to stray currents carry out\ncontinuing program. Corrosion tech performs stray current testing. Refer to [Spire’s O&M\nManual] Sections 6.5.1 CP Design and 7.4.11.1 External Corrosion Control.\" From PHMSA’s\nreview of Spire’s procedures and records, PHMSA found that Spire’s procedures did not further\ndefine how to carry out a continuing program to address stray current (e.g. how to detect, monitor,\nanalyze, and minimize such currents). In response to PHMSA’s exit briefing report, Spire stated:\nSpire monitors the CP readings near foreign lines for indications, such as a very\nhigh on or off readings, that may indicate there is an adverse effect on the pipeline\nfrom a foreign line crossing. The Manager, Corrosion Control would direct CIS\n\n\n\nreadings to be taken in the area of the foreign line crossing to determine if stray\ncurrent was interfering with the cathodic protection system. If such a condition\nwas found, Spire would begin monitoring the stray current and/or install a bond.\nHowever, to date Spire has not observed readings that would indicate stray\ncurrent interference.\nIn order to measure the protective electrical gradient at any specific location, monitoring should\nbe conducted directly at the location otherwise excessive resistance (IR) and inaccuracy is\nintroduced into the recorded readings. Spire’s own description of its process demonstrates that it\nis necessary to take readings “in the area of the foreign line crossing” in order “to determine if\nstray current was interfering with the cathodic protection system.” By failing to have a program\nin place aligning with this description, Spire’s program for addressing stray current failed to\ncomply with § 192.473(a).3\nPHMSA found from a review of Spire’s cathodic protection records that the following foreign\npipeline crossing sites were located a significant distance away from the test station: (1) the\nBuckeye Partners, LP, and St. Louis Pipeline Operating, LLC, crossing is approximately 1,950\nfeet from the nearest test station (TS-112); (2) the Marathon Pipeline, LLC, crossing is\napproximately 541 feet from the nearest test station (TS-99); (3) Express Holdings (USA), LLC\nand TC Oil Pipeline Operations, Inc.’s two line crossings are approximately 1005 feet from the\nnearest test station (TS-88). Consequently, Spire was not continually monitoring these line\ncrossings, which posed a risk of stray current or interference, in such a way as to minimize the\ndetrimental effects of such currents. Therefore, Spire failed to follow the requirements of\n§ 192.473(a).\nAdditionally, when asked by PHMSA during the inspection for records of inspection and\nmonitoring of alternating current (AC) mitigation devices installed to mitigate AC interference,\nSpire did not provide any records in response. Spire’s corrosion personnel stated it did not have a\nprocess requiring the technician to get AC readings during annual surveys, unless directed by the\nmanager. Furthermore, Spire's system of recording4 cathodic protection surveys did not have a\nlocation to capture and record an AC reading. Absent this information, the effectiveness of Spire’s\nAC interference monitoring program cannot be gauged. By failing to monitor its foreign pipeline\ncrossings for stray currents and by failing to monitor the effectiveness of AC interference\nmitigation devices, Spire failed to have a continuing program to minimize the detrimental effects\nof interference current, per the requirements of § 192.473(a).\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\n3 While not incorporated by reference under 49 C.F.R. § 192.7, NACE TM0497, Measurement Techniques Related to\nCriteria for Cathodic Protection on Underground or Submerged Metallic Piping Systems (2022) demonstrates that\ncorrosion control experts recommend monitoring directly at the location. See sections 5.7, 6.1.2, and 9.6.3. Spire’s\nprogram does not align with this industry recommend methodology.\n4 Spire’s work order system of record, MAXIMO.\n\n\n\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 conduct an adequate review and update of its manual of written procedures for\nconducting operations and maintenance activities and for emergency response, in accordance\nwith § 192.605(a). Specifically, Spire’s O&M Manual did not include or reference many of the\nStandard Operating Procedures (SOPs) that Spire’s personnel used for conducting operations and\nmaintenance activities and for emergency response. Spire provided 15 SOPs on January 12,\n2023, that were used by personnel but were not included or referenced within Spire’s O&M\nManual. Spire’s O&M revision log showed that Spire updated its O&M Manual once each\ncalendar year yet, failed to identify and address these omissions. Thus, Spire failed to comply\nwith the requirement of § 192.605(a) to conduct an adequate and thorough review and update of\nits manual of written procedures for conducting operations and maintenance activities and for\nemergency response.\n3. § 192.615 Emergency plans.\n(a) . . . .\n(b) Each operator shall:\n(1) . . . .\n(2) Train the appropriate operating personnel to assure that they are knowledgeable\nof the emergency procedures and verify that the training is effective.\nSpire failed to train the appropriate operating personnel to assure that they were knowledgeable\nof the emergency procedures and verify that the training was effective, per the requirements of §\n192.615(b)(2). Specifically, Spire did not conduct annual refresher training for its emergency\nresponse personnel, from calendar year 2019 through 2022, as required by Spire’s “Spire STL\nPipeline Emergency Plan and Procedures” (Spire’s Emergency Response Procedures), section\n17.3. During this time frame only 3 out of 18 qualified individuals received any refresher\ntraining. Spire’s Emergency Response Procedures, section 17.3 stated:\nAll employees who will be involved in emergency response will receive prior\ntraining to the degree necessary to perform their duties...Employees who are\ntrained in accordance with this section shall receive annual refresher training of\nsufficient content to maintain their competencies, or shall demonstrate\ncompetency in those areas at least annually, at intervals not to exceed 15 months.\nWhen initial or refresher training is provided, the documentation shall be\nmaintained in the Spire STL Pipeline Energy WorldNet system. At a minimum,\nthe training record shall contain the following information:\n• The location and date of the training session.\n• A description of the subject matter.\n• A list of all persons attending the training.\n• The name of the instructor(s).\n\n\n\nBy failing to conduct refresher training for all appropriate personnel, Spire did not assure that its\npersonnel were knowledgeable, nor verify that the training was effective, per the requirements of\n§ 192.615(b)(2).\n4. § 192.706 Transmission lines: Leakage Surveys.\nLeakage surveys of a transmission line must be conducted at intervals not exceeding\n15 months, but at least once each calendar year. However, in the case of a\ntransmission line which transports gas in conformity with § 192.625 without an odor\nor odorant, leakage surveys using leak detector equipment must be conducted—\n(a) In Class 3 locations, at intervals not exceeding 71⁄2 months, but at least twice each\ncalendar year;\nSpire failed to conduct leakage surveys of a transmission line at intervals not exceeding 15\nmonths, but at least once each calendar year, per the requirements of § 192.706(a). Specifically,\nSpire failed to perform leakage surveys by a method appropriate for identifying leaks at three\nlocations.\nPHMSA inspected Spire’s records of monthly aerial patrols, which were performed to look for\nindications of leaks affecting surface vegetation on Spire’s right-of-way (ROW). PHMSA found\nthat tree canopy over the ROW had prohibited observation of the surface conditions from the air.\nBased on a review of historical Google Earth imagery, PHMSA found that the ROW was\nobstructed by tree canopy overgrowth beginning in 2020. Due to the dense tree canopy Spire\ncould not observe indications of leaks affecting surface vegetation over-the-line in its growth\ncycle during the aerial patrols. Spire did not conduct another means of patrol such as by ground\npatrol. In the field, PHMSA confirmed the ROW conditions with those viewed in the records.\nIn response to PHMSA’s findings, during the inspection, Spire stated, \"Leak surveys for the\nyears 2020-2023 were not conducted in wooded areas between HDD entry and exit points due to\nFERC’s requirement to not clear ROW areas within HDD segments.” This includes the\nfollowing locations:\nLocation Starting Point Ending Point Distance Class Odorant\nMississippi River\nHDD\n38.948453°\n,\n90.378981°\n-\n38.942572°\n90.382897° ,\n-\n1915 ft 1 No\nHighway 367 HDD 38.819331°\n,\n90.233597°\n-\n38.815431°\n90.224403° ,\n-\n1545 ft 3 Yes\nSpanish Lake HDD 38.801217°\n,\n90.197081°\n-\n38.800567°\n-\n,\n90.1955° 465 ft 3 Yes\nThus, at these locations, Spire failed to perform leakage patrols at the appropriate intervals for\none Class 1 and two Class 3 areas, per the requirements of § 192.706(a).\n\n\n\n5. § 192.907 What must an operator do to implement this subpart?\n(a) General. No later than December 17, 2004, an operator of a covered pipeline\nsegment must develop and follow a written integrity management program that\ncontains all the elements described in § 192.911 and that addresses the risks on each\ncovered transmission pipeline segment. The initial integrity management program\nmust consist, at a minimum, of a framework that describes the process for\nimplementing each program element, how relevant decisions will be made and by\nwhom, a time line for completing the work to implement the program element, and\nhow information gained from experience will be continuously incorporated into the\nprogram. The framework will evolve into a more detailed and comprehensive\nprogram. An operator must make continual improvements to the program.\nSpire failed to follow its written integrity management program, per the requirements of\n§ 192.907(a). Specifically, Spire failed to follow its procedures for selecting and performing\npreventive and mitigative measures (PMM) per section 12 of its Integrity Management Plan.\nSection 12.4.2 of the Integrity Management Plan stated, “If any recommendations are rejected\nduring Management Review, the justification for the rejection should be documented. All\napproved recommendations should be added to a master P&M recommendation list.” During a\nreview of records, PHMSA found that Spire had not formally documented its evaluation process,\nselection, or implementation of PMM. Thus, the operator had no record of selecting and\nperforming preventive and mitigative measures required per § 192.935, from 2019-2022, and\ntherefore failed to follow its integrity management program as required by § 192.907(a).\n6. § 192.947 What records must an operator keep?\nAn operator must maintain, for the useful life of the pipeline, records that\ndemonstrate compliance with the requirements of this subpart. At minimum, an\noperator must maintain the following records for review during an inspection.\n(a) . . . .\n(b) Documents supporting the threat identification and risk assessment in\naccordance with § 192.917;\nSpire failed to maintain documents that support its identification and risk assessment of the threat\nof equipment failure, as required by § 192.947(b). Spire’s Integrity Management Plan, section\n4.9.4, “Equipment Threats,” refers to Appendix D Table 4-3 for documentation of the threat\nassessment. Subsequent to PHMSA’s request during the inspection, on August 15, 2023, Spire\nprovided a completed Table 4-3, dated August 23, 2023. Spire personnel stated this was\ncompleted after PHMSA requested one be provided, as Spire could not locate a previous version.\nSpire also stated that its risk model did not have equipment listed as a threat in any other section.\nTherefore, Spire failed to keep records supporting the threat identification of equipment failure,\nper the requirements of § 192.947(b).\nProposed Civil Penalty\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a\nrelated series of violations. For violation occurring on or after January 6, 2023 and before\n\n\n\nDecember 28, 2023, the maximum penalty may not exceed $257,664 per violation per day the\nviolation persists, up to a maximum of $2,576,627 for a related series of violations. For violation\noccurring on or after March 21, 2022 and before January 6, 2023, the maximum penalty may not\nexceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,412 for\na related series of violations. For violation occurring on or after May 3, 2021 and before March\n21, 2022, the maximum penalty may not exceed $225, 134 per violation per day the violation\npersists, up to a maximum of $2,251,334 for a related series of violations. For violation\noccurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not\nexceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for\na related series of violations. For violation occurring on or after July 31, 2019 and before January\n11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation\npersists, up to a maximum of $2,186,465 for a related series of violations. For violation\noccurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may\nnot exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679.\nWe have reviewed the circumstances and supporting documentation involved for the above\nprobable violations and recommend that you be preliminarily assessed a civil penalty of $50,200\nas follows:\nItem number\nPENALTY\n3\n$50,200\nProposed Compliance Order\nWith respect to Items 1, 4, and 5 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous\nMaterials Safety Administration proposes to issue a Compliance Order to Spire. Please refer to\nthe Proposed Compliance Order, which is enclosed and made a part of this Notice.\nWarning Item\nWith respect to Items 2 and 6, we have reviewed the circumstances and supporting documents\ninvolved in this case and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to promptly correct these items. Failure to do\nso may result in additional enforcement action.\nResponse to this Notice\nThis Notice is issued in accordance with 49 C.F.R. § 190.207(c). Any response you may have\nsubmitted to the original Notice is no longer applicable. You must respond as set forth below.\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators\nin Enforcement Proceedings. Please refer to this document and note the response options. All\nmaterial you submit in response to this enforcement action may be made publicly available. If\nyou believe that any portion of your responsive material qualifies for confidential treatment\n\n\n\nunder 5 U.S.C. § 552(b), along with the complete original document you must provide a second\ncopy of the document with the portions you believe qualify for confidential treatment redacted\nand an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. § 552(b).\nFollowing your receipt of this Notice, you have 30 days to respond as described in the enclosed\nResponse Options. If you do not respond within 30 days of receipt of this Notice, this constitutes\na waiver of your right to contest the allegations in this Notice and authorizes the Associate\nAdministrator for Pipeline Safety to find facts as alleged in this Notice without further notice to\nyou and to issue a Final Order. If you are responding to this Notice, we propose that you submit\nyour correspondence to my office within 30 days from receipt of this Notice. The Region\nDirector may extend the period for responding upon a written request timely submitted\ndemonstrating good cause for an extension.\nIn your correspondence on this matter, please refer to CPF 3-2025-003-NOPV and, for each\ndocument you submit, please provide a copy in electronic 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\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Enforcement Proceedings\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to Spire a Compliance Order incorporating the\nfollowing remedial requirements to ensure the compliance of with the pipeline safety regulations:\nA. B. C. D. In regard to Item 1 of the Notice, pertaining to Spire’s failure to have a continuing\nprogram to minimize the detrimental effects of stray currents, Spire must:\na. Develop and provide a detailed continuing program per § 192.473 to the\nCentral Region Director for review and approval within 30 days of receipt of\nthe Final Order.\nb. Implement the continuing program and provide initial survey results from\nmonitoring, including any recommendations from findings, to the Central\nRegion Director within 180 days of receipt of the Final Order.\n1. The implementation shall include (1) performing training; (2) identifying\nall foreign line crossings and sources of stray AC current; (3) monitoring\neach location at the location of the pipeline crossing; and (4) reporting\nfindings and any remedial actions.\nIn regard to Item 4 of the Notice, pertaining to the failure to patrol its right-of-way\n(ROW) using an appropriate means Spire must:\na. Provide to the Central Region Director record of leakage surveys conducted at\nthe referenced locations using an appropriate method for the conditions (e.g.,\ntime of year, weather conditions, ground visibility, soil conditions, location of\nthe pipeline, etc.) within 60 days of receipt of the Final Order.\nIn regard to Item 5 of the Notice, pertaining to the failure to follow procedures for\nselecting and performing preventive and mitigative measures, Spire must:\na. Provide records supporting the evaluation and selection of preventive and\nmitigative measures to the Central Region Director within 30 days of receipt\nof the Final Order for review and approval.\nb. Provide records supporting the implementation and periodic evaluation of the\npreventive and mitigative measures to the Central Region Director within 365\ndays of receipt of the Final Order.\nIt is requested (not mandated) that Spire STL Pipeline, LLC maintain\ndocumentation of the safety improvement costs associated with fulfilling this\nCompliance Order and submit the total to Gregory A. Ochs, Director, Central\nRegion, Pipeline and Hazardous Materials Safety Administration. It is requested\nthat these costs be reported in two categories: (1) total cost associated with\npreparation/revision of plans, procedures, studies and analyses, and (2) total cost\nassociated with replacements, additions and other changes to pipeline\ninfrastructure.","truncated":false,"body_characters":29184}