{"operation":"document","citation":"CPF 32025019WL","title":"SPIRE MISSOURI INC. EAST — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-10-14","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a), 195.452(l)(1)(ii).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025019wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025019wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025019wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32025019WL","body":"Warning Letter involving SPIRE MISSOURI INC. EAST. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.452(l)(1)(ii). The case was opened on 2025-10-14 and is reported as closed as of 2025-10-14. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32025019WL_Warning Letter_10142025_(24-297354).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025019WL/32025019WL_Warning%20Letter_10142025_(24-297354).pdf\n\n32025019WL_Warning Letter_10142025_(24-297354)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025019WL/32025019WL_Warning%20Letter_10142025_(24-297354)_text.pdf\n\n32025019WL_Warning Letter_10142025_(24-297354)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: scott.smith@spireenergy.com,\nrandy.wilson@spireenergy.com\nOctober 14, 2025\nMr. Scott R. Smith\nPresident\nSpire Midstream\n3773 Richmond Avenue, Suite 300\nHouston, TX 77046\nCPF 3-2025-019-WL\nDear Mr. Smith:\nFrom October 16 to October 24, 2024, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\nconducted an inspection of Spire Midstream’s (Spire) highly volatile liquid (“HVL”) Laclede /\nChouteau Island pipeline in Saint Louis, Missouri.\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. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a manual\nof written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall\nbe reviewed at intervals not exceeding 15 months, but at least once each calendar\nyear, and appropriate changes made as necessary to insure that the manual is\neffective. This manual shall be prepared before initial operations of a pipeline\nsystem commence, and appropriate parts shall be kept at locations where\noperations and maintenance activities are conducted.\n\n\n\nSpire failed to keep its manual of written procedures at locations where operations and\nmaintenance activities are conducted. During the field portion of the inspection, a PHMSA\ninspector requested Spire’s field operations personnel to demonstrate that they could access the\nelectronic version of the emergency plan. These personnel were unable to do so. Hard copies of\nthe manual of written procedures were not present at the field location where this request was\nmade. Because operations personnel could not access the emergency procedures, Spire did not\ncomply with § 195.402(a). The regulation requires that operations personnel can access these\nprocedures at the locations where operations and maintenance activities are conducted, either by\nproviding electronic access or by distributing and maintaining up-to-date hard copies at those\nlocations.\n2. § 195.452 Pipeline integrity management in high consequence areas.\n(a) . . . .\n(l) What records must an operator keep to demonstrate compliance?\n(1) An operator must maintain, for the useful life of the pipeline, records that\ndemonstrate compliance with the requirements of this subpart. At a\nminimum, an operator must maintain the following records for review during\nan inspection:\n(i) . . . .\n(ii) Documents to support the decisions and analyses, including any\nmodifications, justifications, deviations and determinations made,\nvariances, and actions taken, to implement and evaluate each element of\nthe integrity management program listed in paragraph (f) of this section.\nSpire failed to maintain records documenting its decisions and analyses regarding the selection of\nthe preventive and mitigative measures (PMMs) required by §§ 195.452(f)(6) and 195.452(i).\nDuring the inspection, Spire representatives were able to enumerate specific PMMs that Spire\nimplemented, but upon PHMSA’s request, Spire could not provide documentation to support its\nPMM analysis and decision making, to include who made the PMM determinations, when they\nwere made, or the basis of the decision making. Therefore, Spire failed to comply with\n§ 195.452(l)(1)(ii). The regulations require the PMM selection process to be sufficiently\ndocumented. It should be noted that this recordkeeping requirement is applicable to all elements\nof integrity management that fall under § 195.452(f), such as changes to assessment methods or\nfrequency.\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 related\nseries of violations. For violation occurring on or after December 28, 2023 and before December\n30, 2024 the maximum penalty may not exceed $266,015 per violation per day the violation\npersists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring\non or after January 6, 2023 and before December 28, 2023 the maximum penalty may not exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related\nseries of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023\nthe maximum penalty may not exceed $239,142 per violation per day the violation persists, up to\n\n\n\na maximum of $2,391,142 for a related series of violations. For violation occurring on or after\nMay 3, 2021 and before March 21, 2022 the maximum penalty may not exceed $225,134 per\nviolation per day the violation persists, up to a maximum of $2,251,334 for a related series of\nviolations. For violation occurring on or after January 11, 2021 and before May 3, 2021 the\nmaximum penalty may not exceed $222,504 per violation per day the violation persists, up to a\nmaximum of $2,225,034 for a related series of violations. For violation occurring on or after July\n31, 2019 and before January 11, 2021 the maximum penalty may not exceed $218,647 per violation\nper day the violation persists, up to a maximum of $2,186,465 for a related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so will result in Spire\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 3-2025-019-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 the\nredacted 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: Randy Wilson, Director, Pipeline & System Integrity, Spire Midstream\nrandy.wilson@spireenergy.com","truncated":false,"body_characters":7447}