SPIRE MOGAS PIPELINE LLC — Notice of Probable Violation

party submissionOfficial PDF32026004NOPV_Operator Response to Notice_03052026_(25-330822).pdf#

case documentOfficial PDF32026004NOPV_PCO_02032026_(25-330822).pdf#

case documentOfficial PDF32026004NOPV_PCO_02032026_(25-330822)_text.pdf#

32026004NOPV_Final Order_03192026_(25-330822)_text.pdf, page 1Official PDFU.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 March 19, 2026 VIA ELECTRONIC MAIL TO: scott.smith@spireenergy.com Scott Smith President Spire STL Pipeline, LLC 3773 Richmond Ave Houston, TX 77046 Re: CPF No. 3-2026-004-NOPV Dear Mr. Smith: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violation and specifies actions that need to be taken to comply with the pipeline safety regulations. When the terms of the compliance order are completed, as determined by the Director, Central Region, this enforcement action will be closed. Service of the Final Order by e- mail is effective upon the date of transmission and acknowledgement of receipt as provided under 49 CFR § 190.5. Thank you for your cooperation in this matter. Sincerely, Linda Daugherty Acting Associate Administrator for Pipeline Safety Enclosures (Final Order and NOPV) cc: David Barrett, Acting Director, Central Region, Office of Pipeline Safety, PHMSA Randy Wilson, Director, Pipeline & System Integrity, Spire STL Pipeline, LLC, randy.wilson@spireenergy.com Nicole Christianer, Manager, Transmission Integrity, Spire STL Pipeline, LLC, nicole.christianer@spireenergy.com CONFIRMATION OF RECEIPT REQUESTED#

32026004NOPV_Final Order_03192026_(25-330822)_text.pdf, page 22 U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ In the Matter of ) Spire, Inc., ) CPF No. 3-2026-004-NOPV ) ) ) Respondent. ) ____________________________________) FINAL ORDER On February 3, 2026, pursuant to 49 CFR § 190.207, the Acting Director, Central Region, Office of Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Spire STL Pipeline, LLC, Spire MoGas Pipeline, LLC, and Spire Storage West, LLC, all of which are subsidiaries of Spire, Inc. (Respondent). The Notice proposed finding that Respondent had violated the pipeline safety regulations in 49 CFR Part 192. The Notice also proposed certain measures to correct the violations. Respondent, without admission, did not contest the allegations of violation or corrective measures. Having failed to contest the allegations, pursuant to section 190.213, I find Respondent violated the pipeline safety regulations listed below, as more fully described in the enclosed Notice, which is incorporated by reference: 49 CFR § 192.5(d) (Item 1) ─ Respondent failed to provide records that demonstrate it determined each current class location. 49 CFR § 192.605(a) (Item 2) ─ Respondent failed to follow its manual of written procedures. These findings of violation will be considered prior offenses in any subsequent enforcement action taken against Respondent. Compliance Actions Pursuant to 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the actions proposed in the enclosed Notice to correct the violations. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. Upon completion of the ordered actions, Respondent may request that the Director close the case. Failure to#

32026004NOPV_Final Order_03192026_(25-330822)_text.pdf, page 33 comply with this Order may result in the assessment of civil penalties under 49 CFR § 190.223 or in referral to the Attorney General for appropriate relief in a district court of the United States. The terms and conditions of this order are effective upon service in accordance with 49 CFR § 190.5. ___________________________________ _________________________ Linda Daugherty Date Issued Acting Associate Administrator for Pipeline Safety#

32026004NOPV_Final Order_03192026_(25-330822)_text.pdf, page 4U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 901 Locust Street, Suite 480 Kansas City, MO 64106 NOTICE OF PROBABLE VIOLATION AND PROPOSED COMPLIANCE ORDER VIA ELECTRONIC MAIL TO: scott.smith@spireenergy.com; randy.wilson@spireenergy.com; nicole.christianer@spireenergy.com February 3, 2026 Scott Smith President Spire STL Pipeline, LLC 3773 Richmond Ave Houston, TX 77046 CPF 3-2026-004-NOPV Dear Mr. Smith: From July 9, 2025 to December 11, 2025, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected the procedures and records of Spire STL Pipeline, LLC, Spire MoGas Pipeline, LLC, and Spire Storage West, LLC, for the gas rule in St. Louis, MO. Spire STL Pipeline, LLC, Spire MoGas Pipeline, LLC, and Spire Storage West, LLC are all subsidiaries of Spire, Inc. (Spire). As a result of the inspection, it is alleged that Spire has committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable violations are: 1. § 192.5 Class locations. (a) . . . . (b) Except as provided in paragraph (c) of this section, pipeline locations are classified as follows: (1) . . . . (3) A Class 3 location is: (i) Any class location unit that has 46 or more buildings intended for human occupancy;#

32026004NOPV_Final Order_03192026_(25-330822)_text.pdf, page 5(ii) …. (d) An operator must have records that document the current class location of each gas transmission pipeline segment and that demonstrate how the operator determined each current class location in accordance with this section. Spire failed to provide records that demonstrate it determined each current class location in accordance with § 192.5(b), per the requirement of § 192.5(d). Specifically, Spire failed to properly identify several locations where a class location unit had 46 or more buildings intended for human occupancy. PHMSA discovered the following misidentified class locations during a review of Spire’s “MoGas Master MOP and Class Locations” record and Keyhole Markup Language Zipped (KMZ) data: Pipeline Segment Approximate Latitude Longitude Approx. Length of Misidentified Start End Class 3 (feet) Salem 37.975865°, -91.729682° 37.963269° -91.731907° 5,280 South Point to Sullivan 38.361790°, -90.993143° 38.356016° -91.009336° 5,280 OM to South Point 38.787890°, -90.830739° 38.786824° -90.831731° 3,400 OM to South Point 38.777301° -90.834703° 38.765340°, -90.839160° 500 Curryville to OM 39.018230°, -90.853062° 38.997920°, -90.837059° 7,000 Spire’s MoGas Operations and Maintenance Manual (MoGas O&M), Section 3.01, required Spire to determine the class locations of its pipelines and keep records of these determinations. Despite the requirements of § 192.5 and MoGas O&M procedures, Spire misidentified multiple sites, resulting in the current class location not being in accordance with § 192.5(b). Therefore, Spire violated § 192.5(d). 2. § 192.605 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline, a manual of written procedures for conducting operations and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. Spire failed to follow its manual of written procedures in accordance with § 192.605(a). Specifically, Spire failed to follow its MoGas O&M, Section 8.01, “HCA and MCA Identification,” which required Spire to identify Moderate Consequence Areas (MCAs) and determine the length of the MCAs based on: The length of the moderate consequence area extends axially along the length of the pipeline from the outermost edge of the first potential impact circle containing either 5 or more buildings intended for human occupancy; or any portion of the 2#

32026004NOPV_Final Order_03192026_(25-330822)_text.pdf, page 6paved surface, including shoulders, of any designated interstate, freeway, or expressway, as well as any other principal arterial roadway with 4 or more lanes, to the outermost edge of the last contiguous potential impact circle that contains either 5 or more buildings intended for human occupancy, or any portion of the paved surface, including shoulders, of any designated interstate, freeway, or expressway, as well as any other principal arterial roadway with 4 or more lanes.1 From a review of Spire’s pipeline system KMZ data of MCAs, PHMSA determined that Spire failed to identify the following MCA locations containing 5 or more buildings intended for human occupancy or a roadway with 4 or more lanes: Approximate Latitude Longitude Approx. Length Pipeline Segment of Unidentifed Start End MCA (feet) Curryville to OM 39.124838°, -90.965988° 39.120801°, -90.959220° 1,300 Curryville to OM 39.012526°, -90.848279° 39.010268°, -90.846771° 900 Curryville to OM 39.006092°, -90.843932° 39.004519°, -90.842822° 645 West Alton to Wood River 38.871205°, -90.206415° 38.870769°, -90.205256° 370 West Alton to Wood River 38.859303°, -90.111434° 38.859507°, -90.109019° 700 OM to South Point 38.818413°, -90.809458° 38.813139°, -90.810452° 1,850 OM to South Point 38.529058°, -90.972973° 38.528012°, -90.976338° 1,200 South Point to Sullivan 38.528186°, -90.977330° 38.527608°, -90.977987° 350 Salem 37.978157°, -91.725231° 37.977542°, -91.726879° 600 Salem 37.948599°, -91.734195° 37.947419°, -91.734301° 430 Proposed Civil Penalty Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a related series of violations. For violation occurring on or after December 28, 2023 and before December 30, 2024, the maximum penalty may not exceed $266,015 per violation per day the aviolation persists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may not exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related series of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,412 for a related series of violations. For violation occurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related series of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related series of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series of violations. 1 This language mirrors the regulatory definition of moderate consequence area found at 49 CFR § 192.3. 3#

32026004NOPV_Final Order_03192026_(25-330822)_text.pdf, page 7We have reviewed the circumstances and supporting documents involved in this case, and have decided not to propose a civil penalty assessment at this time. Proposed Compliance Order With respect to items 1 and 2 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Spire. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice. Response to this Notice Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement Proceedings. Please refer to this document and note the response options. All material you submit in response to this enforcement action may be made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. § 552(b). Following your receipt of this Notice, you have 30 days to respond as described in the enclosed Response Options. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Final Order. If you are responding to this Notice, we propose that you submit your correspondence to my office within 30 days from receipt of this Notice. The Region Director may extend the period for responding upon a written request timely submitted demonstrating good cause for an extension. In your correspondence on this matter, please refer to CPF 3-2026-004-NOPV and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, David Barrett Acting Director, Central Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Enforcement Proceedings cc: Randy Wilson, Director, Pipeline & System Integrity, Spire STL Pipeline, LLC, randy.wilson@spireenergy.com Nicole Christianer, Manager, Transmission Integrity, Spire STL Pipeline, LLC, nicole.christianer@spireenergy.com 4#

32026004NOPV_Final Order_03192026_(25-330822)_text.pdf, page 8PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Spire a Compliance Order incorporating the following remedial requirements to ensure the compliance of Spire with the pipeline safety regulations: A. In regard to Item 1 the Notice pertaining to misidentified class locations, Spire must submit to PHMSA, for review and approval, a plan which includes timeframes, to determine the current class location of the segments listed in the Notice within 30 days and complete the approved plan within 180 days of receipt of the Final Order. B. In regard to Item 2 of the Notice pertaining to unidentified MCAs, Spire must submit to PHMSA, for review and approval, a plan which includes timeframes, to identify the extent of the MCAs for the segments listed in the Notice within 30 days and complete the approved plan within 180 days of receipt of the Final Order. C. It is requested (not mandated) that Spire maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Director, Central Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses, and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. 5#