{"operation":"document","citation":"CPF 32025023NOA","title":"SPIRE MISSOURI INC. EAST — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-10-14","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(c)(5), 195.402(e)(9), 195.422(a), 195.452(l)(1)(ii).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025023noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025023noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025023noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32025023NOA","body":"Notice of Amendment involving SPIRE MISSOURI INC. EAST. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(5),  195.402(e)(9),  195.422(a),  195.452(l)(1)(ii). The case was opened on 2025-10-14 and is reported as closed as of 2026-01-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32025023NOA_Closure Letter_01222026_(24-297354).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025023NOA/32025023NOA_Closure%20Letter_01222026_(24-297354).pdf\n\n32025023NOA_Closure Letter_01222026_(24-297354)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025023NOA/32025023NOA_Closure%20Letter_01222026_(24-297354)_text.pdf\n\n32025023NOA_Notice of Amendment_10142025_(24-297354).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025023NOA/32025023NOA_Notice%20of%20Amendment_10142025_(24-297354).pdf\n\n32025023NOA_Notice of Amendment_10142025_(24-297354)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025023NOA/32025023NOA_Notice%20of%20Amendment_10142025_(24-297354)_text.pdf\n\n32025023NOA_Operator Response to Notice_11132025_(24-297354).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025023NOA/32025023NOA_Operator%20Response%20to%20Notice_11132025_(24-297354).pdf\n\n32025023NOA_Closure Letter_01222026_(24-297354)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\n901 Locust Street, Suite 480\nKansas City, MO 64106\nVIA ELECTRONIC MAIL TO: mark.lowe@spireenergy.com;\nscott.smith@spireenergy.com, randy.wilson@spireenergy.com\nJanuary 22, 2026\nMr. Mark Lowe\nSenior Vice President, Engineering, Gas Supply and Operation\nSpire Missouri Inc. East\n700 Market Street\nSt. Louis, MO 63101\nRE: CPF 3-2025-023-NOA\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) procedures for the highly volatile liquid\n(“HVL”) Laclede / Chouteau Island pipeline in Saint Louis, Missouri. On October 14, 2025,\npursuant to 49 CFR § 190.206, PHMSA issued a Notice of Amendment (Notice) which proposed\namendment of Spire’s procedures.\nSpire submitted its amended procedures on November 13, 2025. PHMSA has reviewed the\namended procedures, and it appears that the inadequacies outlined in the Notice for Items 1 and 3\nhave been corrected. With respect to Item 2, Spire provided its Notification of Sale of the NGL\nPipeline to Phillips 66 Pipeline, LLC, effective January 1, 2026; therefore, amended procedures\nper Item 2 are no longer required to be submitted. Accordingly, this letter is to inform you that\nPHMSA hereby withdraws Item 2 of the Notice. The other Items are now closed.\nSincerely,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Mr. Scott Smith, President, Spire Midstream\nMr. Randy Wilson, Director, Pipeline & System Integrity, Spire Missouri Inc. East\n\n32025023NOA_Notice of Amendment_10142025_(24-297354)_text.pdf\n\nNOTICE OF AMENDMENT\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 3-2025-023-NOA\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) procedures for the highly volatile liquid\n(“HVL”) Laclede / Chouteau Island pipeline in Saint Louis, Missouri.\nAs a result of the inspection, PHMSA has identified the apparent alleged inadequacies found\nwithin Spire’s plans or procedures. The items inspected and the alleged inadequacies are described\nbelow:\n1. § 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 minimum,\nan operator must maintain the following records for review during an\ninspection:\n(i) . . . .\n(ii) Documents to support the decisions and analyses, including any\nmodifications, justifications, deviations and determinations made,\n\n\n\nvariances, and actions taken, to implement and evaluate each element of\nthe integrity management program listed in paragraph (f) of this section.\nSpire’s written Integrity Management Program (“IMP”) was inadequate because it did not\nspecifically require maintaining for the useful life of the pipeline documents to support the\ndecisions and analyses to implement and evaluate each element of the integrity management\nprogram listed in paragraph (f) of § 195.452. Specifically, while the IMP had the general language\nof § 195.452(l)(1) in Section 15.3, the procedures did not specifically require documentation of\ndecision-making in regard to the individual elements required by § 195.452(f). In particular,\nSpire’s IMP did not direct documentation of the identification and selection of preventive and\nmitigative measures (“PMMs”), required by § 195.452(f)(6).\nDuring the inspection, Spire representatives enumerated specific PMMs that Spire implemented,\nbut when requested by PHMSA, Spire was unable to provide documentation to support its PMM\nanalysis and decision making, to include who made the PMM determinations, when they were\nmade, or the basis of the decision making.\nSpire must amend its procedures to ensure that documents to support the decisions and analyses\nfor selecting PMMs are recorded and maintained in a written record for the useful life of the\npipeline, to include the reasoning for the determinations, what hazards the measures are intended\nto address, the personnel making the decisions, and the dates that they were made and\nimplemented.\n2. § 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.\nSpire’s procedures pertaining to welding and other “hot work” activities were inadequate to ensure\nthat repairs are made in a safe manner and performed in a way that prevents damage to persons or\nproperty. Specifically, Spire’s procedures were inconsistent regarding the need to purge product\nor take other steps to reduce the particular hazards associated with working on an active HVL\npipeline. Operating Procedures Manual (OPM) Appendix D, Spire Standard NGL-10701J Purging\nof Highly Volatile Liquid (HVL) Mains for Repair or Abandonment stated: “Before HVL lines\ncan be repaired or abandoned, all product must first be removed from the pipeline. See NGL\nOperations Procedure 3020.” Procedure 3020 described purging of the HVL lines. In addition,\nOPM section 403 stated that maintenance personnel shall be trained “to safely repair pipeline\nfacilities using special precautions such as isolation and purging where HVL is involved.”\nHowever, other portions of Spire’s procedures discussed hot work without any reference to\npurging or other special precautions. Welding specification W-100.G “In Service Welding\nProcedure” stated that it is applicable to Spire NGL, Inc., implying that welding may be performed\non the HVL line while it is pressurized and/or conveying product. Welding specification W-100.1\nand procedure NGL-10500L both discussed hot tapping, and W-100.1 also stated “Low hydrogen\nelectrodes (E7018) shall be used on pressurized (\"in-service\") mains, static or flowing.”\n\n\n\nCadwelding procedures also failed to address whether any special precautions were needed when\nworking on HVL pipelines.\nSpire must amend its procedures to clearly and consistently identify under what conditions in-\nservice welding, such as installation of repair sleeves, cadwelding of cathodic test leads, or other\napplicable activities, may be performed on the HVL lines.\n3. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies…\n(b) . . . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1) . . . .\n(5) Investigating and analyzing pipeline accidents and failures, including sending\nthe failed pipe, component, or equipment for laboratory testing or\nexamination where appropriate, to determine the cause(s) and contributing\nfactors of the failure and to minimize the possibility of a recurrence.\n(d) . . . .\n(e) Emergencies. The manual required by paragraph (a) of this section must include\nprocedures for the following to provide safety when an emergency condition\noccurs:\n(1) . . . .\n(9) Providing for a post accident review of employee activities to determine\nwhether the procedures were effective in each emergency and taking\ncorrective action where deficiencies are found.\nSpire’s procedures regarding the post-accident investigation process were inadequate because they\nlacked sufficient detail to comply with § 195.402(e)(9). During the inspection, the operator\nreported that there is a Safety Management Systems (SMS) group which is intended to carry out\nroot cause analysis for accidents. PHMSA reviewed a draft document referred to as “SOP Element\n5” addressing this process. However, the draft SOP at the time of inspection only referenced\nnatural gas procedures and requirements. Spire’s OPM at the time of inspection did not mention\nthe SMS group’s responsibilities. The operator reported that Spire’s Claims Department would be\nresponsible for preserving and submitting specimens needed for laboratory analysis, such as\nmetallurgical examination of failed pipe fragments, but the OPM did not address this.\nSpire must amend its procedures to clearly and consistently define which parties are responsible\nfor each component of the accident investigation and the post-accident review of emergency\nprocedure effectiveness, ensure that relevant documents are appropriately cross-referenced, and\nincorporate hazardous liquid procedures and requirements into the SMS process where applicable.\nResponse to this Notice\n\n\n\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part\nof this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you submit\nin response to this enforcement action is subject to being made publicly available. If you believe\nthat any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. §\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 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 Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting this Notice,\nwe propose that you submit your amended procedures to my office within thirty (30) days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Spire maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to the Director, Central Region, Pipeline and Hazardous Materials Safety\nAdministration. In correspondence concerning this matter, please refer to CPF 3-2025-023-NOA\nand, for each document you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Randy Wilson, Director, Pipeline & System Integrity\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":13111}