{"operation":"document","citation":"CPF 32025020NOA","title":"ST LOUIS PIPELINE OPERATING LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-05-29","effective_on":null,"summary":"CLOSED notice of amendment citing 195.254(b), 195.260(a), 195.260(b), 195.260(c), 195.260(f), 195.406(a), 195.418(a), 195.422(a), 195.452(f)(3), 195.577(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025020noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025020noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025020noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32025020NOA","body":"Notice of Amendment involving ST LOUIS PIPELINE OPERATING LLC. PHMSA's enforcement data identifies the cited regulations as 195.254(b),  195.260(a),  195.260(b),  195.260(c),  195.260(f),  195.406(a),  195.418(a),  195.422(a),  195.452(f)(3),  195.577(a). The case was opened on 2025-05-29 and is reported as closed as of 2026-02-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32025020NOA_Closure Letter_02262026_(24-297350).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025020NOA/32025020NOA_Closure%20Letter_02262026_(24-297350).pdf\n\n32025020NOA_Closure Letter_02262026_(24-297350)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025020NOA/32025020NOA_Closure%20Letter_02262026_(24-297350)_text.pdf\n\n32025020NOA_Notice of Amendment_05292025_(24-297350).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025020NOA/32025020NOA_Notice%20of%20Amendment_05292025_(24-297350).pdf\n\n32025020NOA_Notice of Amendment_05292025_(24-297350)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025020NOA/32025020NOA_Notice%20of%20Amendment_05292025_(24-297350)_text.pdf\n\n32025020NOA_Order Directing Amendment_10152025_(24-297350).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025020NOA/32025020NOA_Order%20Directing%20Amendment_10152025_(24-297350).pdf\n\n32025020NOA_Order Directing Amendment_10152025_(24-297350)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025020NOA/32025020NOA_Order%20Directing%20Amendment_10152025_(24-297350)_text.pdf\n\n32025020NOA_Order Directing Amendment_10152025_(24-297350)_text.pdf\n\nOctober 15, 2025\nVIA CERTIFIED MAIL AND EMAIL TO: tampapc@outlook.com;\nstlouispipelinegm@outlook.com\nRobert Rose\nPresident & CEO\nSt. Louis Pipeline Operating, LLC\n4120 Higel Street\nSarasota, FL 34242\nRe: CPF No. 3-2025-020-NOA\nDear Mr. Rose:\nEnclosed please find the Order Directing Amendment issued in the above-referenced case. It\nmakes findings of inadequate procedures and requires certain amendments to ensure safe\noperation. When the amendment of procedures has been completed, as determined by the\nDirector, Central Region, this enforcement action will be closed. Service of the Final Order by\ncertified mail is effective upon the date of mailing 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 (Order Directing Amendment and Notice of Amendment)\ncc: David Barrett, Acting Director, Central Region, Office of Pipeline Safety, PHMSA\nBerry Croft, General Manager, St Louis Pipeline Operating LLC,\nberry.croft@panamericanpipelines.com\nEdric Kidd, National Pipeline Manager, St Louis Pipeline Operating LLC,\nedric.kidd@panamericanpipelines.com\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\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 )\nSt. Louis Pipeline Operating, LLC, ) CPF No. 3-2025-020-NOA\n)\n)\n)\nRespondent. )\n____________________________________)\nORDER DIRECTING AMENDMENT\nOn May 29, 2025, pursuant to 49 CFR § 190.206, the Acting Director, Central Region, Office of\nPipeline Safety (OPS), issued a Notice of Amendment (Notice) to St. Louis Pipeline Operating,\nLLC (Respondent). The Notice proposed finding that Respondent’s written procedures were\ninadequate to ensure safe operation of a pipeline facility and proposed certain amendments to\naddress the inadequacies. On July 15, 2025, Respondent requested additional time to respond to\nthe Notice. Central Region granted the request, extending the response deadline to August 27,\n2025. Respondent did not submit written comments, revised procedures, or a request for a\nhearing by August 27, 2025, it has therefore waived its right to contest the allegations in the\nNotice.\nPursuant to 49 CFR § 190.206, I find Respondent’s procedures were inadequate with respect to\nthe issues listed below, as more fully described in the enclosed Notice, which is incorporated by\nreference:\n49 CFR § 195.254(b) (Item 1) ─ Respondent’s procedures failed to specify how newly\ninstalled above ground components would be protected from the forces exerted by\nanticipated loads.\n49 CFR § 195.260 (Item 2) ─ Respondent’s procedures failed to specify the locations\nwhere valves must be installed.\n49 CFR § 195.406 (Item 3) ─ Respondent’s procedures failed to require that the\nmaximum operating pressure not exceed any of the limitations in 49 CFR §\n195.406(a)(1)-(5).\n49 CFR § 195.418(a) (Item 4) ─ Respondent’s procedures failed to include the\ninstallation requirements for rupture mitigation valves.\n\n\n\n49 CFR § 195.422(a) (Item 5) ─ Respondent’s procedures failed to specify how repairs\nare to be made in a safe manner so as to prevent damage to persons or property in\nexcavated trenches and during cutting or welding.\n49 CFR § 195.452(f)(3) (Item 6) ─ Respondent’s procedures failed to include an\nanalysis that integrates all available information about the integrity of the entire pipeline\nand the consequences of a failure.\n49 CFR § 195.577(a) (Item 7) ─ Respondent’s procedures failed to specify how it would\nidentify, test for, and minimize the detrimental effects of stray currents.\nPursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206, Respondent is ordered to take the\nactions proposed in the enclosed Notice to correct the inadequacies. The Director may grant an\nextension of time to comply with any of the required items upon a written request timely\nsubmitted by the Respondent and demonstrating good cause for an extension. Upon completion\nof the ordered actions, Respondent may request that the Director close the case. Failure to\ncomply with this Order may result in the assessment of civil penalties under 49 CFR § 190.223\nor in referral to the Attorney General for appropriate relief in a district court of the United States.\nThe terms and conditions of this order are effective upon service in accordance with 49 CFR §\n190.5.\n___________________________________ __________________________\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety\n\n\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: tampapc@outlook.com; stlouispipelinegm@outlook.com;\nEdric.kidd@panamericanpipelines.com\nMay 29, 2025\nRobert Rose\nPresident & CEO\nSt. Louis Pipeline Operating, LLC\n4120 Higel Street\nSarasota, FL 34242\nCPF 3-2025-020-NOA\nDear Mr. Rose:\nFrom May 20, 2024 through October 18, 2024, representatives 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 St. Louis Pipeline Operating, LLC’s (SLPCO)\nprocedures for operations, maintenance, and integrity management in Madison County, Illinois,\nand St. Louis County, Missouri.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nSLPCO’s plans or procedures. The items inspected and the alleged inadequacies and proposed\nrevisions are described below.\n1. § 195.254 Above ground components.\n(a) . . . .\n(b) Each component covered by this section must be protected from the forces\nexerted by the anticipated loads.\nSection 195.422(b) of Subpart F prohibits use of any pipe, valve, or fitting, for replacement in\nrepairing pipeline facilities, unless designed and constructed per Part 195. Section 195.254(b) of\nSubpart D, Construction, states, “[e]ach component covered by this section must be protected\nfrom the forces exerted by the anticipated loads.” Per § 195.402(c), an operator’s manual for\nmaintenance and normal operations must include procedures for operating, maintaining, and\n\n\n\nrepairing the pipeline system in accordance with Subpart F, among other provisions. SLPCO’s\nOperations and Maintenance Procedure Manual, section 4.17, “New Pipeline Construction,”\nfailed to include or reference how components, installed above ground in the situations described\nin § 195.254(a),1 would be protected from the forces exerted by anticipated loads on above-\nground components, per the requirements of § 195.254(b). To ensure that components used in\nnew, replaced or otherwise changed portions of the St. Louis Pipeline are protected from the\nforces exerted by the anticipated loads, SLPCO must revise its written procedures for design and\nconstruction to address § 195.254(b).\n2. § 195.260 Valves: Location\nA valve must be installed at each of the following locations:\n(a) On the suction end and the discharge end of a pump station in a manner that\npermits isolation of the pump station equipment in the event of an emergency.\n(b) On each pipeline entering or leaving a breakout storage tank area in a manner\nthat permits isolation of the tank from other facilities.\n(c) On each pipeline at locations along the pipeline system that will minimize or\nprevent safety risks, property damage, or environmental harm from accidental\nhazardous liquid or carbon dioxide discharges, as appropriate for onshore areas,\noffshore areas, and high-consequence areas (HCA). For newly constructed or\nentirely replaced onshore hazardous liquid or carbon dioxide pipeline segments, as\nthat term is defined at § 195.2, that are installed after April 10, 2023.\n(d) . . . .\n(f) On each side of a reservoir holding water for human consumption.\nPursuant to § 195.202, “[e]ach pipeline system must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with the requirements of\nthis part.” SLPCO’s Operations and Maintenance Procedure Manual, section 4.17, “New\nPipeline Construction,” did not adequately describe where valves would be required consistent\nwith § 195.260. Section 195.260’s requirements became effective October 5, 2022,2 and should\nhave been addressed in SLPCO’s manual(s) at the time of PHMSA’s 2024 inspection.\nTherefore, SLPCO must amend its procedures to adequately address the requirements of\n§ 195.260.\n3. § 195.406 Maximum operating pressure.\n(a) Except for surge pressures and other variations from normal operations, no\noperator may operate a pipeline at a pressure that exceeds any of the following:\n(1) The internal design pressure of the pipe determined in accordance with §\n195.106….3\n1 i.e., (1) overhead crossings of highways, railroads, or a body of water; (2) spans over ditches and gullies; (3)\nscraper traps or block valves; (4) areas under the direct control of the operator; and (5) in any area inaccessible to the\npublic.\n2 Pipeline Safety: Requirement of Valve Installation and Minimum Rupture Detection Standards, 87 Fed. Reg.\n20940 (April 8, 2022).\n3 § 195.406(a)(1) contains an exception to the requirement for steel pipe in pipelines being converted under § 195.5,\n\n\n\n(2) The design pressure of any other component of the pipeline.\n(3) Eighty percent of the test pressure for any part of the pipeline which has been\npressure tested under subpart E of this part.\n(4) Eighty percent of the factory test pressure or of the prototype test pressure for\nany individually installed component which is excepted from testing under §\n195.305.\n(5) For pipelines under §§ 195.302(b)(1) and (b)(2)(i) that have not been pressure\ntested under subpart E of this part, 80 percent of the pressure or highest operating\npressure to which the pipeline was subjected for 4 or more continuous hours that\ncan be demonstrated by recording charts or logs made at the time the test or\noperations were conducted.\nPursuant to § 195.402(c)(3), an operator’s manual for maintenance and normal operations must\nhave procedures for operating, maintaining, and repairing the pipeline system in accordance with\nSubpart F, among other provisions. Section 195.406 is found within Subpart F. SLPCO’s\nOperations and Maintenance Procedure Manual, section 4.24, “Establishing Maximum Operating\nPressures (MOP),” failed to include all factors in § 195.406(a). Specifically, the procedure\nmanual did not include the requirement that the established MOP may not exceed any of the five\nfactors under § 195.406(a). Therefore, SLPCO must amend its procedures related to § 195.406\nfor maximum operating pressure.\n4. § 195.418 Valves: Onshore valve shut-off for rupture mitigation.\n(a) Applicability. For newly constructed and entirely replaced onshore hazardous\nliquid or carbon dioxide pipeline segments, as defined at § 195.2, with diameters of 6\ninches or greater that could affect high-consequence areas or are located in high\nconsequence areas (HCA), and that have been installed after April 10, 2023, an\noperator must install or use existing rupture-mitigation valves (RMV), as defined at\n§ 195.2, or alternative equivalent technologies according to the requirements of this\nsection and § 195.419. RMVs and alternative equivalent technologies must be\noperational within 14 days of placing the new or replaced pipeline segment in\nservice. An operator may request an extension of this 14-day operation requirement\nif it can demonstrate to PHMSA, in accordance with the notification procedures in\n§ 195.18, that application of that requirement would be economically, technically, or\noperationally infeasible. The requirements of this section apply to all applicable\npipe replacements, even those that do not otherwise directly involve the addition or\nreplacement of a valve.\nPer § 195.402(c)(3), an operator’s manual for maintenance and normal operations must include\nprocedures for operating, maintaining, and repairing the pipeline system in accordance with\nSubpart F, among other provisions. Section 195.418 is a part of Subpart F. SLPCO’s Operations\nand Maintenance Procedure Manual, section 4.17, “New Pipeline Construction,” failed to\ninclude or reference other SLPCO documents for the installation of rupture mitigation valves\n(RMV) or alternative equivalent technology, pursuant to § 195.418. The procedural manual also\ndid not address the capabilities of RMVs, and alternative equivalent technology as described by\n______________________________\nwhich is not applicable for SLPCO’s pipeline system.\n\n\n\n§ 195.419 (cross-referenced with § 195.418). Requirements for RMVs and alternative\nequivalent technology became effective October 5, 20223 and should have been addressed in\nSLPCO’s manual(s) at the time of PHMSA’s 2024 inspection. Therefore, SLPCO must amend\nits procedures to adequately address the requirements of § 195.418.\n5. § 195.422 Pipeline repairs.\n(a) Each operator shall, in repairing its pipeline systems, insure that the repairs are\nmade in a safe manner and are made so as to prevent damage to persons or\nproperty.\nPursuant to § 195.402(c)(3), an operator’s manual for maintenance and normal operations must\nhave procedures for operating, maintaining, and repairing the pipeline system in accordance with\nSubpart F, among other provisions. Section 195.422 is found within Subpart F. SLPCO’s\nOperations and Maintenance Procedure Manual, section 4.12, “Pipeline Repair,” addressed how\nSPLCO would make repairs in a safe manner to prevent damage to persons and property. Within\nthe procedure manual, SPLCO did not describe the precautions that it would need to take in\nexcavated trenches to protect personnel from the hazards of unsafe accumulations of vapor or\ngas, which is specifically required by § 192.402 to ensure safe maintenance and normal\noperations. See § 195.402(c)(14)). In addition, section 8.2.2 of the SPLCO’s Integrity\nManagement Plan listed safety precautions required during pressure testing, however, it did not\ncover repairs that would involve cutting or welding where measures would be needed to prevent\nfires or explosions. Therefore, SLPCO must amend its procedures to address how repairs are to\nbe made in a safe manner so as to prevent damage to persons or property in excavated trenches\nand during cutting or welding.\n6. § 195.452 Pipeline integrity management in high consequence areas.\n(a) . . . .\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(1) . . . .\n(3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this section);\nSLPCO’s “Pipeline Integrity Management Plan” (IMP) for risk and information analysis did not\ninclude an analysis that integrates all available information about the integrity of the entire\npipeline and the consequences of a failure, as required by § 195.452(f)(3). The IMP, section 6,\n“Risk Analysis” and the “Risk Index (Appendix B),” did not include every attribute described in\n4 Pipeline Safety: Requirement of Valve Installation and Minimum Rupture Detection Standards, 87 Fed. Reg.\n20940 (April 8, 2022).\n\n\n\n§ 195.452(g). Specifically, they did not include § 195.452(g)(1)(iii) and §§ 195.452 (g)(1)(v)\nthrough (g)(1)(xxi). While the IMP Glossary for “Discovery of Condition” mentioned\nintegrating additional information from other inspections, it did not specifically include what\ndata elements would be integrated. Also, SLPCO’s IMP did not specify how spatial\nrelationships among anomalous information would be identified, pursuant to § 195.452(g)(4). In\naddition, Section 6.5 of SLPCO’s IMP referred to the initial risk index in Appendix B, but it did\nnot appear to be changed to reflect operating experience, as required by§ 195.452(f). All\nattributes listed in § 195.452(g) required to be included in the written integrity management\nprogram pursuant to § 195.452(f)(3) were to be integrated by October 1, 2022, and should have\nbeen included in SLPCO’s IMP at the time of PHMSA’s 2024 inspection. Therefore, SLPCO\nmust amend its procedures related to integrating all available information about the integrity of\nthe entire pipeline and the consequences of failure, per § 195.452(f)(3).\n7. § 195.577 What must I do to alleviate interference currents?\n(a) For pipelines exposed to stray currents, you must have a program to identify,\ntest for, and minimize the detrimental effects of such currents.\nSLPCO’s Operations and Maintenance Procedure Manual, section 4.9.1, “A. Annual Protection\nSurvey,” did not describe how SLPCO’s corrosion control program would actively identify, test\nfor, and minimize the detrimental effects of stray currents. SPLPCO’s procedures required an\nannual test point survey, but did include when a close-interval survey, required by\n§ 195.573(a)(2), is necessary and required by SLPCO to address interference. According to\nSLPCO’s Emergency Response Manual, Appendix E, there are multiple other pipelines that\neither share rights-of-way or cross SLPCO’s pipeline, which can expose it to stray currents;\ntherefore, SLPCO must amend its procedures to include a program for identifying and alleviating\ninterference currents, per § 195.577(a).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 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\n5 U.S.C. § 552(b), along with the complete original document you must provide a second copy\nof the 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\n\n\n\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 CFR § 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\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that St Louis Pipeline Operating, LLC maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Gregory Ochs, Director,\nCentral Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 3-2025-020-NOA and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nDavid Barrett\nActing Director, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\ncc: Barry Croft, Facility Supervisor, St Louis Pipeline Operating LLC,\nstlouispipelinegm@outlook.com\nEdric Kidd, National Pipeline Manager, St Louis Pipeline Operating LLC,\nEdric.kidd@panamericanpipelines.com\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n\n32025020NOA_Notice of Amendment_05292025_(24-297350)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: tampapc@outlook.com; stlouispipelinegm@outlook.com;\nEdric.kidd@panamericanpipelines.com\nMay 29, 2025\nRobert Rose\nPresident & CEO\nSt. Louis Pipeline Operating, LLC\n4120 Higel Street\nSarasota, FL 34242\nCPF 3-2025-020-NOA\nDear Mr. Rose:\nFrom May 20, 2024 through October 18, 2024, representatives 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 St. Louis Pipeline Operating, LLC’s (SLPCO)\nprocedures for operations, maintenance, and integrity management in Madison County, Illinois,\nand St. Louis County, Missouri.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nSLPCO’s plans or procedures. The items inspected and the alleged inadequacies and proposed\nrevisions are described below.\n1. § 195.254 Above ground components.\n(a) . . . .\n(b) Each component covered by this section must be protected from the forces\nexerted by the anticipated loads.\nSection 195.422(b) of Subpart F prohibits use of any pipe, valve, or fitting, for replacement in\nrepairing pipeline facilities, unless designed and constructed per Part 195. Section 195.254(b) of\nSubpart D, Construction, states, “[e]ach component covered by this section must be protected\nfrom the forces exerted by the anticipated loads.” Per § 195.402(c), an operator’s manual for\nmaintenance and normal operations must include procedures for operating, maintaining, and\n\n\n\nrepairing the pipeline system in accordance with Subpart F, among other provisions. SLPCO’s\nOperations and Maintenance Procedure Manual, section 4.17, “New Pipeline Construction,”\nfailed to include or reference how components, installed above ground in the situations described\nin § 195.254(a),1 would be protected from the forces exerted by anticipated loads on above-\nground components, per the requirements of § 195.254(b). To ensure that components used in\nnew, replaced or otherwise changed portions of the St. Louis Pipeline are protected from the\nforces exerted by the anticipated loads, SLPCO must revise its written procedures for design and\nconstruction to address § 195.254(b).\n2. § 195.260 Valves: Location\nA valve must be installed at each of the following locations:\n(a) On the suction end and the discharge end of a pump station in a manner that\npermits isolation of the pump station equipment in the event of an emergency.\n(b) On each pipeline entering or leaving a breakout storage tank area in a manner\nthat permits isolation of the tank from other facilities.\n(c) On each pipeline at locations along the pipeline system that will minimize or\nprevent safety risks, property damage, or environmental harm from accidental\nhazardous liquid or carbon dioxide discharges, as appropriate for onshore areas,\noffshore areas, and high-consequence areas (HCA). For newly constructed or\nentirely replaced onshore hazardous liquid or carbon dioxide pipeline segments, as\nthat term is defined at § 195.2, that are installed after April 10, 2023.\n(d) . . . .\n(f) On each side of a reservoir holding water for human consumption.\nPursuant to § 195.202, “[e]ach pipeline system must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with the requirements of\nthis part.” SLPCO’s Operations and Maintenance Procedure Manual, section 4.17, “New\nPipeline Construction,” did not adequately describe where valves would be required consistent\nwith § 195.260. Section 195.260’s requirements became effective October 5, 2022,2 and should\nhave been addressed in SLPCO’s manual(s) at the time of PHMSA’s 2024 inspection.\nTherefore, SLPCO must amend its procedures to adequately address the requirements of\n§ 195.260.\n3. § 195.406 Maximum operating pressure.\n(a) Except for surge pressures and other variations from normal operations, no\noperator may operate a pipeline at a pressure that exceeds any of the following:\n(1) The internal design pressure of the pipe determined in accordance with §\n195.106….3\n1 i.e., (1) overhead crossings of highways, railroads, or a body of water; (2) spans over ditches and gullies; (3)\nscraper traps or block valves; (4) areas under the direct control of the operator; and (5) in any area inaccessible to the\npublic.\n2 Pipeline Safety: Requirement of Valve Installation and Minimum Rupture Detection Standards, 87 Fed. Reg.\n20940 (April 8, 2022).\n3 § 195.406(a)(1) contains an exception to the requirement for steel pipe in pipelines being converted under § 195.5,\n\n\n\n(2) The design pressure of any other component of the pipeline.\n(3) Eighty percent of the test pressure for any part of the pipeline which has been\npressure tested under subpart E of this part.\n(4) Eighty percent of the factory test pressure or of the prototype test pressure for\nany individually installed component which is excepted from testing under §\n195.305.\n(5) For pipelines under §§ 195.302(b)(1) and (b)(2)(i) that have not been pressure\ntested under subpart E of this part, 80 percent of the pressure or highest operating\npressure to which the pipeline was subjected for 4 or more continuous hours that\ncan be demonstrated by recording charts or logs made at the time the test or\noperations were conducted.\nPursuant to § 195.402(c)(3), an operator’s manual for maintenance and normal operations must\nhave procedures for operating, maintaining, and repairing the pipeline system in accordance with\nSubpart F, among other provisions. Section 195.406 is found within Subpart F. SLPCO’s\nOperations and Maintenance Procedure Manual, section 4.24, “Establishing Maximum Operating\nPressures (MOP),” failed to include all factors in § 195.406(a). Specifically, the procedure\nmanual did not include the requirement that the established MOP may not exceed any of the five\nfactors under § 195.406(a). Therefore, SLPCO must amend its procedures related to § 195.406\nfor maximum operating pressure.\n4. § 195.418 Valves: Onshore valve shut-off for rupture mitigation.\n(a) Applicability. For newly constructed and entirely replaced onshore hazardous\nliquid or carbon dioxide pipeline segments, as defined at § 195.2, with diameters of 6\ninches or greater that could affect high-consequence areas or are located in high\nconsequence areas (HCA), and that have been installed after April 10, 2023, an\noperator must install or use existing rupture-mitigation valves (RMV), as defined at\n§ 195.2, or alternative equivalent technologies according to the requirements of this\nsection and § 195.419. RMVs and alternative equivalent technologies must be\noperational within 14 days of placing the new or replaced pipeline segment in\nservice. An operator may request an extension of this 14-day operation requirement\nif it can demonstrate to PHMSA, in accordance with the notification procedures in\n§ 195.18, that application of that requirement would be economically, technically, or\noperationally infeasible. The requirements of this section apply to all applicable\npipe replacements, even those that do not otherwise directly involve the addition or\nreplacement of a valve.\nPer § 195.402(c)(3), an operator’s manual for maintenance and normal operations must include\nprocedures for operating, maintaining, and repairing the pipeline system in accordance with\nSubpart F, among other provisions. Section 195.418 is a part of Subpart F. SLPCO’s Operations\nand Maintenance Procedure Manual, section 4.17, “New Pipeline Construction,” failed to\ninclude or reference other SLPCO documents for the installation of rupture mitigation valves\n(RMV) or alternative equivalent technology, pursuant to § 195.418. The procedural manual also\ndid not address the capabilities of RMVs, and alternative equivalent technology as described by\nwhich is not applicable for SLPCO’s pipeline system.\n\n\n\n§ 195.419 (cross-referenced with § 195.418). Requirements for RMVs and alternative\nequivalent technology became effective October 5, 20224 and should have been addressed in\nSLPCO’s manual(s) at the time of PHMSA’s 2024 inspection. Therefore, SLPCO must amend\nits procedures to adequately address the requirements of § 195.418.\n5. § 195.422 Pipeline repairs.\n(a) Each operator shall, in repairing its pipeline systems, insure that the repairs are\nmade in a safe manner and are made so as to prevent damage to persons or\nproperty.\nPursuant to § 195.402(c)(3), an operator’s manual for maintenance and normal operations must\nhave procedures for operating, maintaining, and repairing the pipeline system in accordance with\nSubpart F, among other provisions. Section 195.422 is found within Subpart F. SLPCO’s\nOperations and Maintenance Procedure Manual, section 4.12, “Pipeline Repair,” addressed how\nSPLCO would make repairs in a safe manner to prevent damage to persons and property. Within\nthe procedure manual, SPLCO did not describe the precautions that it would need to take in\nexcavated trenches to protect personnel from the hazards of unsafe accumulations of vapor or\ngas, which is specifically required by § 192.402 to ensure safe maintenance and normal\noperations. See § 195.402(c)(14)). In addition, section 8.2.2 of the SPLCO’s Integrity\nManagement Plan listed safety precautions required during pressure testing, however, it did not\ncover repairs that would involve cutting or welding where measures would be needed to prevent\nfires or explosions. Therefore, SLPCO must amend its procedures to address how repairs are to\nbe made in a safe manner so as to prevent damage to persons or property in excavated trenches\nand during cutting or welding.\n6. § 195.452 Pipeline integrity management in high consequence areas.\n(a) . . . .\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(1) . . . .\n(3) An analysis that integrates all available information about the integrity of the\nentire pipeline and the consequences of a failure (see paragraph (g) of this section);\nSLPCO’s “Pipeline Integrity Management Plan” (IMP) for risk and information analysis did not\ninclude an analysis that integrates all available information about the integrity of the entire\npipeline and the consequences of a failure, as required by § 195.452(f)(3). The IMP, section 6,\n“Risk Analysis” and the “Risk Index (Appendix B),” did not include every attribute described in\n4 Pipeline Safety: Requirement of Valve Installation and Minimum Rupture Detection Standards, 87 Fed. Reg.\n20940 (April 8, 2022).\n\n\n\n§ 195.452(g). Specifically, they did not include § 195.452(g)(1)(iii) and §§ 195.452 (g)(1)(v)\nthrough (g)(1)(xxi). While the IMP Glossary for “Discovery of Condition” mentioned\nintegrating additional information from other inspections, it did not specifically include what\ndata elements would be integrated. Also, SLPCO’s IMP did not specify how spatial\nrelationships among anomalous information would be identified, pursuant to § 195.452(g)(4). In\naddition, Section 6.5 of SLPCO’s IMP referred to the initial risk index in Appendix B, but it did\nnot appear to be changed to reflect operating experience, as required by§ 195.452(f). All\nattributes listed in § 195.452(g) required to be included in the written integrity management\nprogram pursuant to § 195.452(f)(3) were to be integrated by October 1, 2022, and should have\nbeen included in SLPCO’s IMP at the time of PHMSA’s 2024 inspection. Therefore, SLPCO\nmust amend its procedures related to integrating all available information about the integrity of\nthe entire pipeline and the consequences of failure, per § 195.452(f)(3).\n7. § 195.577 What must I do to alleviate interference currents?\n(a) For pipelines exposed to stray currents, you must have a program to identify,\ntest for, and minimize the detrimental effects of such currents.\nSLPCO’s Operations and Maintenance Procedure Manual, section 4.9.1, “A. Annual Protection\nSurvey,” did not describe how SLPCO’s corrosion control program would actively identify, test\nfor, and minimize the detrimental effects of stray currents. SPLPCO’s procedures required an\nannual test point survey, but did include when a close-interval survey, required by\n§ 195.573(a)(2), is necessary and required by SLPCO to address interference. According to\nSLPCO’s Emergency Response Manual, Appendix E, there are multiple other pipelines that\neither share rights-of-way or cross SLPCO’s pipeline, which can expose it to stray currents;\ntherefore, SLPCO must amend its procedures to include a program for identifying and alleviating\ninterference currents, per § 195.577(a).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 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\n5 U.S.C. § 552(b), along with the complete original document you must provide a second copy\nof the 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\n\n\n\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 CFR § 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\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that St Louis Pipeline Operating, LLC maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Gregory Ochs, Director,\nCentral Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 3-2025-020-NOA and, for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nSincerely,\nDavid Barrett\nActing Director, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\ncc: Barry Croft, Facility Supervisor, St Louis Pipeline Operating LLC,\nstlouispipelinegm@outlook.com\nEdric Kidd, National Pipeline Manager, St Louis Pipeline Operating LLC,\nEdric.kidd@panamericanpipelines.com\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n\n32025020NOA_Closure Letter_02262026_(24-297350)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety Administration\n1100 Main Street\nKansas City, MO 64105\nVIA ELECTRONIC MAIL TO: tampapc@outlook.com; stlouispipelinegm@outlook.com;\nberry.croft@panamericanpipelines.com; greg.lipscomb@panamericanpipelines.com\nFebruary 26, 2026\nMr. Robert Rose, President\nSt. Louis Pipeline Operating, LLC\n4120 Higel Street\nSarasota, FL 34242\nRE: CPF 3-2025-020-NOA\nDear Mr. Rose:\nOn October 15, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to St. Louis Pipeline Operating, LLC’s (SLPCO) an Order Directing Amendment in the\nabove-referenced case. This Order included a requirement to amend your procedures. Based on\nour review of the documentation provided, it has been determined that SLPCO has complied with\nthe terms of this Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nDavid Barrett\nActing Director, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\ncc: Berry Croft, Facility Supervisor, berry.croft@panamericanpipelines.com;\nstlouispipelinegm@outlook.com\nGreg Lipscomb, National Pipeline Manager, greg.lipscomb@panamericanpipelines.com","truncated":false,"body_characters":39040}