{"operation":"document","citation":"CPF 32025029NOPV","title":"ST LOUIS PIPELINE OPERATING LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-08-15","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.266, 195.406(a), 195.505(h).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025029nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025029nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025029nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32025029NOPV","body":"Notice of Probable Violation involving ST LOUIS PIPELINE OPERATING LLC. PHMSA's enforcement data identifies the cited regulations as 195.266,  195.406(a),  195.505(h). The case was opened on 2025-08-15 and is reported as closed as of 2026-01-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32025029NOPV_Closure Letter_01272026_(24-297350).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025029NOPV/32025029NOPV_Closure%20Letter_01272026_(24-297350).pdf\n\n32025029NOPV_Closure Letter_01272026_(24-297350)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025029NOPV/32025029NOPV_Closure%20Letter_01272026_(24-297350)_text.pdf\n\n32025029NOPV_Final Order_11102025_(24-297350).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025029NOPV/32025029NOPV_Final%20Order_11102025_(24-297350).pdf\n\n32025029NOPV_Final Order_11102025_(24-297350)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025029NOPV/32025029NOPV_Final%20Order_11102025_(24-297350)_text.pdf\n\n32025029NOPV_PCO_08152025_(24-297350).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025029NOPV/32025029NOPV_PCO_08152025_(24-297350).pdf\n\n32025029NOPV_PCO_08152025_(24-297350)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025029NOPV/32025029NOPV_PCO_08152025_(24-297350)_text.pdf\n\n32025029NOPV_Closure Letter_01272026_(24-297350)_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: tampapc@outlook.com;\nberry.croft@panamericanpipelines.com; stlouispipelinegm@outlook.com\nJanuary 27, 2026\nRobert Rose, President\nSt. Louis Pipeline Operating, LLC\n4120 Higel Street\nSarasota, FL 34242\nRE: CPF 3-2025-029-NOPV\nDear Mr. Rose:\nOn November 10, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to St. Louis Pipeline Operating, LLC’s (SLPCO) a Final Order, pursuant to 49 CFR\n§ 190.213. This Order included a Compliance Order. Based on a review of the documentation\nprovided and PHMSA’s observations during a site visit in November 2025, it has been determined\nthat the Order should be closed. Accordingly, this case is now closed.\nSincerely,\nDavid Barrett\nActing Director, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\ncc: Berry Croft, Facility Supervisor, St Louis Pipeline Operating LLC,\nberry.croft@panamericanpipelines.com; stlouispipelinegm@outlook.com\n\n32025029NOPV_Final Order_11102025_(24-297350)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nNovember 10, 2025\nVIA ELECTRONIC MAIL TO: tampapc@outlook.com\nRobert Rose, President\nSt. Louis Pipeline Operating, LLC\n4120 Higel Street\nSarasota, FL 34242\nRe: CPF No. 3-2025-029-NOPV\nDear Mr. Rose:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation and specifies actions that need to be taken to comply with the pipeline safety\nregulations. When the terms of the compliance order are completed, as determined by the\nDirector, Central Region, this enforcement action will be closed. Service of the Final Order by e-\nmail is effective upon the date of transmission and acknowledgement of receipt as provided\nunder 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, PHMSA\nGreg Lipscomb, St. Louis Pipeline Operating, LLC,\ngreg.lipscomb@panamericanpipelines.com\nBerry Croft, General Manager, St Louis Pipeline Operating LLC,\nberry.croft@panamericanpipelines.com, stlouispipelinegm@outlook.com\n\n\n\nEdric Kidd, National Pipeline Manager, St Louis Pipeline Operating LLC,\nedric.kidd@panamericanpipelines.com\nCONFIRMATION OF 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. 3-2025-029-NOPV\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn August 15, 2025, pursuant to 49 CFR § 190.207, the Acting Director, Central Region, Office\nof Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to St. Louis Pipeline\nOperating, LLC (Respondent). The Notice proposed finding that Respondent had violated the\npipeline safety regulations in 49 CFR Part 195. The Notice also proposed certain measures to\ncorrect the violations. Respondent did not contest the allegations of violation or corrective\nmeasures.\nPursuant to 49 CFR § 190.213, I find Respondent violated the pipeline safety regulations listed\nbelow, as more fully described in the enclosed Notice, which is incorporated by reference:\n49 CFR § 195.266 (Item 1) ─ Respondent failed to maintain complete records\nthat show 1) the total number of girth welds and the number nondestructively\ntested, including the number of rejects and the disposition of each rejected weld;\n2) the amount, location, and cover of each size of pipe installed; and 3) the\nlocation of each valve for the Lambert Airport Project.\n49 CFR § 195.406(a)(2) (Item 2) ─ Respondent failed to provide maximum\noperating pressure records regarding the design pressure of the components on the\nLambert Airport Project.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\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. The Director may grant an\nextension of time to comply with any of the required items upon a written request timely\n\n\n\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. Respondent\npreviously submitted evidence to show appropriate actions have been taken to correct the\nviolations. This evidence is currently under review by the Director. Failure to comply with this\nOrder may result in the assessment of civil penalties under 49 CFR § 190.223 or in referral to the\nAttorney General for appropriate relief in a district court of the United States.\nWarning Item\nWith respect to Item 3, the Notice alleged a probable violation of 49 CFR § 195.505(h), but did\nnot propose a civil penalty or compliance order for this item. Therefore, this is considered to be a\nwarning item. If OPS finds a violation of this provision in a subsequent inspection, Respondent\nmay be subject to future enforcement action.\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\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\n901 Locust Street, Suite 480\nKansas City, MO 64106\nNOTICE OF PROBABLE VIOLATION\nand\nPROPOSED COMPLIANCE ORDER\nVIA ELECTRONIC MAIL TO: tampapc@outlook.com; stlouispipelinegm@outlook.com;\nEdric.kidd@panamericanpipelines.com\nAugust 15, 2025\nRobert Rose, President\nSt. Louis Pipeline Operating, LLC\n4120 Higel Street\nSarasota, FL 34242\nCPF 3-2025-029-NOPV\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.), conducted an inspection of St. Louis Pipeline Operating,\nLLC’s (SLPCO) records and facilities in Madison County, Illinois and St. Louis County,\nMissouri.\nAs a result of the inspection, it is alleged that SLPCO 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. § 195.266 Construction records.\nA complete record that shows the following must be maintained by the operator\ninvolved for the life of each pipeline facility:\n(a) The total number of girth welds and the number nondestructively tested,\nincluding the number rejected and the disposition of each rejected weld.\n(b) The amount, location; and cover of each size of pipe installed.\n(c) The location of each crossing of another pipeline.\n(d) The location of each buried utility crossing.\n\n\n\n(e) The location of each overhead crossing.\n(f) The location of each valve and corrosion test station.\nSLPCO failed to demonstrate that it maintained complete records that show the total number of\ngirth welds and the number of nondestructive tested, including the number of rejects and the\ndisposition of each rejected weld, as required by § 195.266(a). In addition, SLPCO failed to\ndemonstrate that it maintained records of the amount, location; and cover of each size of pipe\ninstalled, as required by § 195.266(b). Furthermore, SLPCO failed to demonstrate that it\nmaintained records for the location of each valve, as required by § 195.266(f).\nPHMSA inspectors requested during the on-site inspection the Lambert Airport Project records\nfor weld reports, facility drawings, construction drawings, as-built drawings, and Non-\nDestructive Testing (NDT) reports, which would show the information required by\n§§ 195.266(a), (b), and (f). SLPCO did not produce records during the on-site inspection.\nPHMSA issued a Request for Specific Information (RFSI) to SLPCO on October 7, 2024,\nrequesting these records. SLPCO representatives verbally confirmed receipt of the RFSI.\nHowever, SLPCO did not provide responsive documents to PHMSA, Central Region. Thus,\nSLPCO failed to demonstrate that it maintained records complaint with §§ 195.266 (a), (b), and\n(f). These records are critical to future decision making as it relates to, §§ 195.452(e) and (g)\ndetermining risk factors for assessment scheduling and information analysis.\n2. § 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\n§ 195.106. However, for steel pipe in pipelines being converted under § 195.5,\nif one or more factors of the design formula (§ 195.106) are unknown, one of\nthe following pressures is to be used as design pressure:\n(i) Eighty percent of the first test pressure that produces yield under section\nN5.0 of Appendix N of ASME B31.8 (incorporated by reference, see\n§ 195.3), reduced by the appropriate factors in §§ 195.106(a) and (e); or\n(ii) If the pipe is 323.8 mm (12¾ in) or less outside diameter and is not tested\nto yield under this paragraph, 200 p.s.i. (1379 kPa) gage.\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\nbeen pressure tested under Subpart E of this part.\n(4) Eighty percent of the factory test pressure or of the prototype test pressure\nfor any individually installed component which is excepted from testing\nunder § 195.305.\n(5) For pipelines under §§ 195.302(b)(1) and (b)(2)(i), that have not been\npressure tested under Subpart E of this part, 80 percent of the test pressure\nor highest operating pressure to which the pipeline was subjected for 4 or\nmore continuous hours that can be demonstrated by recording charts or logs\nmade at the time the test or operations were conducted.\n2\n\n\n\nSLPCO failed to ensure its Lambert Airport Project did not operate at a pressure that exceeded\nthe design pressure of all pipeline components pursuant to § 195.406(a)(2). Specifically,\nPHMSA requested records supporting the design pressure of the components of the SLPCO\npipelines. SLPCO provided the of Maximum Operating Pressure Record, but did not provide\nadequate documentation related to the design pressures of the components in the pipeline system.\nAs a follow-up, PHMSA sent a Request for Specific Information to SLPCO on October 7, 2024,\nwhich was verbally confirmed as received by its National Pipeline Manager. However, PHMSA\ndid not receive responsive documents. Absent documentation of the design pressure of the\ncomponents of the pipeline, SLPCO could not ensure its Lambert Airport Project did not operate\nat a pressure that exceeded the design pressure of any other component of the pipeline, pursuant\nto § 195.406(a)(2).\n3. § 195.505 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n(a) . . . .\n(h) After December 16, 2004, provide training, as appropriate, to ensure that\nindividuals performing covered tasks have the necessary knowledge and skills to\nperform the tasks in a manner that ensures the safe operation of pipeline\nfacilities;\nSLPCO failed to follow its written qualification program by not providing training, as\nappropriate, to ensure that an individual performing a covered task had the necessary knowledge\nand skills to perform the covered task in a safe manner, as required by § 195.505(h). During the\nPHMSA inspection on October 17, 2024, a PHMSA inspector asked a SLPCO employee to take\nreadings from a rectifier. SLPCO records indicated the employee was qualified to perform the\nOQ Task Code 003.0, “Obtain a Voltage and Current Output Reading from a Rectifier to Verify\nProper Performance (1:1),” but the employee did not demonstrate adequate knowledge of how to\nperform the task safely and correctly. The employee acknowledged his lack of experience with\nthe task and indicated that he did not feel comfortable performing it, so the PHMSA inspector\nwithdrew the request. Additionally, when preparing to enter a deep vault to demonstrate valve\noperation as covered in Task Code 063.4, “Locally Operate Valves on a Liquid Pipeline System\n(1:1),” the PHMSA inspector stopped the SLPCO employee from proceeding due to a lack of\nConfined Entry Permit and proper equipment to enter. SLPCO submitted a Confined Space\nTraining Review Form dated July 24, 2023 to PHMSA afterwards, but during the in-field\ninspection of the pipeline, the employee did not know the requirements for entering a confined\nspace.\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$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a\nrelated series of violations. For violation occurring on or after December 28, 2023 and before\nDecember 30, 2024, the maximum penalty may not exceed $266,015 per violation per day the\nviolation persists, up to a maximum of $2,660,135 for a related series of violations. For violation\n3\n\n\n\noccurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may\nnot exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627\nfor a related series of violations. For violation occurring on or after March 21, 2022 and before\nJanuary 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the\nviolation persists, up to a maximum of $2,391,412 for a related series of violations. For violation\noccurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not\nexceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for\na related series of violations. For violation occurring on or after January 11, 2021 and before\nMay 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to propose a civil penalty assessment at this time.\nProposed Compliance Order\nWith respect to Items 1 and 2 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials\nSafety Administration proposes to issue a Compliance Order to St. Louis Pipeline Operating, LLC.\nPlease refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice.\nWarning Item\nWith respect to Item 3, we have reviewed the circumstances and supporting documents involved\nin this case and have decided not to conduct additional enforcement action or penalty assessment\nproceedings at this time. We advise you to promptly correct these items. Failure to do so may\nresult in additional enforcement action.\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\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\n4\n\n\n\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 3-2025-029-NOPV and, for each\ndocument you submit, 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\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Enforcement Proceedings\n5\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 St. Louis Pipeline Operating, LLC, a Compliance\nOrder incorporating the following remedial requirements to ensure the compliance of St. Louis\nPipeline Operating, LLC, with the pipeline safety regulations:\nA. In regard to Item number 1 of the Notice pertaining to failure to maintain construction\nrecords, St. Louis Pipeline Operating, LLC must submit within 90 days of receipt of the\nFinal Order to the Director, PHMSA Central Region, Office of Pipeline Safety, complete\nweld records, to include: the total number of girth welds, welds nondestructively tested,\nwelds rejected and the disposition of each rejected weld; the amount, location, and depth\nof cover of each size of pipe installed; and the location of each valve and corrosion test\nstation. For any of the aforementioned information that SPLCO does not have or cannot\nsubmit, SLPCO must provide a written plan within 90 days of receipt of the Final Order\nto the Director, PHMSA Central Region, Office of Pipeline Safety, to supply the\ninformation that would have been recorded in the required records.\nB. In regard to Item number 2 of the Notice pertaining to failure to ensure it did not operate\nat a pressure that exceeded the design pressure of any other component of the pipeline,\nSt. Louis Pipeline Operating, LLC, must submit within 90 days of receipt of the Final\nOrder to the Director, PHMSA Central Region, Office of Pipeline Safety, records to\nsupport the established maximum operating pressure (MOP) such as the internal design\npressure of the pipe, the design pressure of any other component of the pipeline, and the\ntest pressure of the pipe and any component. In addition, any other records that show the\ncurrent maximum operating pressure. For any of the aforementioned information that\nSPLCO does not have or cannot submit, SLPCO must provide a written plan within 90\ndays of receipt of the Final Order to the Director, PHMSA Central Region, Office of\nPipeline Safety, to demonstrate the pipeline components are commensurate with the\nMOP.\nC. It is requested (not mandated) that St. Louis Pipeline Operating, LLC, maintain\ndocumentation of the safety improvement costs associated with fulfilling this Compliance\nOrder and submit the total the Director, PHMSA Central Region, Office of Pipeline\nSafety. It is requested that these costs be reported in two categories: 1) total cost\nassociated with preparation/revision of plans, procedures, studies and analyses, and 2)\ntotal cost associated with replacements, additions and other changes to pipeline\ninfrastructure.\n6","truncated":false,"body_characters":21620}