{"operation":"document","citation":"CPF 32026004NOPV","title":"SPIRE MOGAS PIPELINE LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2026-02-03","effective_on":null,"summary":"OPEN notice of probable violation citing 192.5(b)(3)(i), 192.5(d), 192.605(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32026004nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32026004nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32026004nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32026004NOPV","body":"Notice of Probable Violation involving SPIRE MOGAS PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 192.5(b)(3)(i),  192.5(d),  192.605(a). The case was opened on 2026-02-03 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32026004NOPV_Final Order_03192026_(25-330822).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32026004NOPV/32026004NOPV_Final%20Order_03192026_(25-330822).pdf\n\n32026004NOPV_Final Order_03192026_(25-330822)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32026004NOPV/32026004NOPV_Final%20Order_03192026_(25-330822)_text.pdf\n\n32026004NOPV_Operator Response to Notice_03052026_(25-330822).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32026004NOPV/32026004NOPV_Operator%20Response%20to%20Notice_03052026_(25-330822).pdf\n\n32026004NOPV_PCO_02032026_(25-330822).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32026004NOPV/32026004NOPV_PCO_02032026_(25-330822).pdf\n\n32026004NOPV_PCO_02032026_(25-330822)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32026004NOPV/32026004NOPV_PCO_02032026_(25-330822)_text.pdf\n\n32026004NOPV_Final Order_03192026_(25-330822)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMarch 19, 2026\nVIA ELECTRONIC MAIL TO: scott.smith@spireenergy.com\nScott Smith\nPresident\nSpire STL Pipeline, LLC\n3773 Richmond Ave\nHouston, TX 77046\nRe: CPF No. 3-2026-004-NOPV\nDear Mr. Smith:\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\nRandy Wilson, Director, Pipeline & System Integrity, Spire STL Pipeline, LLC,\nrandy.wilson@spireenergy.com\nNicole Christianer, Manager, Transmission Integrity, Spire STL Pipeline, LLC,\nnicole.christianer@spireenergy.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\n2\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nSpire, Inc., ) CPF No. 3-2026-004-NOPV\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn February 3, 2026, pursuant to 49 CFR § 190.207, the Acting Director, Central Region, Office\nof Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Spire STL Pipeline,\nLLC, Spire MoGas Pipeline, LLC, and Spire Storage West, LLC, all of which are subsidiaries of\nSpire, Inc. (Respondent). The Notice proposed finding that Respondent had violated the pipeline\nsafety regulations in 49 CFR Part 192. The Notice also proposed certain measures to correct the\nviolations. Respondent, without admission, did not contest the allegations of violation or\ncorrective measures.\nHaving failed to contest the allegations, pursuant to section 190.213, I find Respondent violated\nthe pipeline safety regulations listed below, as more fully described in the enclosed Notice,\nwhich is incorporated by reference:\n49 CFR § 192.5(d) (Item 1) ─ Respondent failed to provide records that\ndemonstrate it determined each current class location.\n49 CFR § 192.605(a) (Item 2) ─ Respondent failed to follow its manual of\nwritten procedures.\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\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\n\n\n\n3\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\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 Administration\n901 Locust Street, Suite 480\nKansas City, MO 64106\nNOTICE OF PROBABLE VIOLATION\nAND\nPROPOSED COMPLIANCE ORDER\nVIA ELECTRONIC MAIL TO: scott.smith@spireenergy.com;\nrandy.wilson@spireenergy.com; nicole.christianer@spireenergy.com\nFebruary 3, 2026\nScott Smith\nPresident\nSpire STL Pipeline, LLC\n3773 Richmond Ave\nHouston, TX 77046\nCPF 3-2026-004-NOPV\nDear Mr. Smith:\nFrom July 9, 2025 to December 11, 2025, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.) inspected the procedures and records of Spire STL Pipeline, LLC,\nSpire MoGas Pipeline, LLC, and Spire Storage West, LLC, for the gas rule in St. Louis, MO. Spire\nSTL Pipeline, LLC, Spire MoGas Pipeline, LLC, and Spire Storage West, LLC are all subsidiaries\nof Spire, Inc. (Spire).\nAs a result of the inspection, it is alleged that Spire has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 192.5 Class locations.\n(a) . . . .\n(b) Except as provided in paragraph (c) of this section, pipeline locations are classified\nas follows:\n(1) . . . .\n(3) A Class 3 location is:\n(i) Any class location unit that has 46 or more buildings intended for human\noccupancy;\n\n\n\n(ii) ….\n(d) An operator must have records that document the current class location of each\ngas transmission pipeline segment and that demonstrate how the operator determined\neach current class location in accordance with this section.\nSpire failed to provide records that demonstrate it determined each current class location in\naccordance with § 192.5(b), per the requirement of § 192.5(d). Specifically, Spire failed to properly\nidentify several locations where a class location unit had 46 or more buildings intended for human\noccupancy. PHMSA discovered the following misidentified class locations during a review of\nSpire’s “MoGas Master MOP and Class Locations” record and Keyhole Markup Language Zipped\n(KMZ) data:\nPipeline Segment\nApproximate\nLatitude Longitude\nApprox. Length of\nMisidentified\nStart End\nClass 3 (feet)\nSalem 37.975865°, -91.729682° 37.963269° -91.731907° 5,280\nSouth Point to Sullivan 38.361790°, -90.993143° 38.356016° -91.009336° 5,280\nOM to South Point 38.787890°, -90.830739° 38.786824° -90.831731° 3,400\nOM to South Point 38.777301° -90.834703° 38.765340°, -90.839160° 500\nCurryville to OM 39.018230°, -90.853062° 38.997920°, -90.837059° 7,000\nSpire’s MoGas Operations and Maintenance Manual (MoGas O&M), Section 3.01, required Spire\nto determine the class locations of its pipelines and keep records of these determinations. Despite\nthe requirements of § 192.5 and MoGas O&M procedures, Spire misidentified multiple sites,\nresulting in the current class location not being in accordance with § 192.5(b). Therefore, Spire\nviolated § 192.5(d).\n2. § 192.605 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include procedures\nfor handling abnormal operations. This manual must be reviewed and updated by the\noperator at intervals not exceeding 15 months, but at least once each calendar year.\nThis manual must be prepared before operations of a pipeline system commence.\nAppropriate parts of the manual must be kept at locations where operations and\nmaintenance activities are conducted.\nSpire failed to follow its manual of written procedures in accordance with § 192.605(a).\nSpecifically, Spire failed to follow its MoGas O&M, Section 8.01, “HCA and MCA\nIdentification,” which required Spire to identify Moderate Consequence Areas (MCAs) and\ndetermine the length of the MCAs based on:\nThe length of the moderate consequence area extends axially along the length of\nthe pipeline from the outermost edge of the first potential impact circle containing\neither 5 or more buildings intended for human occupancy; or any portion of the\n2\n\n\n\npaved surface, including shoulders, of any designated interstate, freeway, or\nexpressway, as well as any other principal arterial roadway with 4 or more lanes,\nto the outermost edge of the last contiguous potential impact circle that contains\neither 5 or more buildings intended for human occupancy, or any portion of the\npaved surface, including shoulders, of any designated interstate, freeway, or\nexpressway, as well as any other principal arterial roadway with 4 or more lanes.1\nFrom a review of Spire’s pipeline system KMZ data of MCAs, PHMSA determined that Spire\nfailed to identify the following MCA locations containing 5 or more buildings intended for human\noccupancy or a roadway with 4 or more lanes:\nApproximate\nLatitude Longitude\nApprox. Length\nPipeline Segment\nof Unidentifed\nStart End\nMCA (feet)\nCurryville to OM 39.124838°, -90.965988° 39.120801°, -90.959220° 1,300\nCurryville to OM 39.012526°, -90.848279° 39.010268°, -90.846771° 900\nCurryville to OM 39.006092°, -90.843932° 39.004519°, -90.842822° 645\nWest Alton to Wood River 38.871205°, -90.206415° 38.870769°, -90.205256° 370\nWest Alton to Wood River 38.859303°, -90.111434° 38.859507°, -90.109019° 700\nOM to South Point 38.818413°, -90.809458° 38.813139°, -90.810452° 1,850\nOM to South Point 38.529058°, -90.972973° 38.528012°, -90.976338° 1,200\nSouth Point to Sullivan 38.528186°, -90.977330° 38.527608°, -90.977987° 350\nSalem 37.978157°, -91.725231° 37.977542°, -91.726879° 600\nSalem 37.948599°, -91.734195° 37.947419°, -91.734301° 430\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 related\nseries of violations. For violation occurring on or after December 28, 2023 and before December\n30, 2024, the maximum penalty may not exceed $266,015 per violation per day the aviolation\npersists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring\non or after January 6, 2023 and before December 28, 2023, the maximum penalty may not exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related\nseries of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023,\nthe maximum penalty may not exceed $239,142 per violation per day the violation persists, up to\na maximum of $2,391,412 for a related series of violations. For violation occurring on or after\nMay 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134 per\nviolation per day the violation persists, up to a maximum of $2,251,334 for a related series of\nviolations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the\nmaximum penalty may not exceed $222,504 per violation per day the violation persists, up to a\nmaximum of $2,225,034 for a related series of violations. For violation occurring on or after July\n31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations.\n1 This language mirrors the regulatory definition of moderate consequence area found at 49 CFR § 192.3.\n3\n\n\n\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 Spire. Please refer to the Proposed\nCompliance Order, which is enclosed and made a part of this Notice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement 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 you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe 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 under\n5 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\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 Director\nmay extend the period for responding upon a written request timely submitted demonstrating good\ncause for an extension.\nIn your correspondence on this matter, please refer to CPF 3-2026-004-NOPV and, for each\ndocument 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\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Enforcement Proceedings\ncc: Randy Wilson, Director, Pipeline & System Integrity, Spire STL Pipeline, LLC,\nrandy.wilson@spireenergy.com\nNicole Christianer, Manager, Transmission Integrity, Spire STL Pipeline, LLC,\nnicole.christianer@spireenergy.com\n4\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 Spire a Compliance Order incorporating the\nfollowing remedial requirements to ensure the compliance of Spire with the pipeline safety\nregulations:\nA. In regard to Item 1 the Notice pertaining to misidentified class locations, Spire must\nsubmit to PHMSA, for review and approval, a plan which includes timeframes, to\ndetermine the current class location of the segments listed in the Notice within 30 days\nand complete the approved plan within 180 days of receipt of the Final Order.\nB. In regard to Item 2 of the Notice pertaining to unidentified MCAs, Spire must submit\nto PHMSA, for review and approval, a plan which includes timeframes, to identify the\nextent of the MCAs for the segments listed in the Notice within 30 days and complete\nthe approved plan within 180 days of receipt of the Final Order.\nC. It is requested (not mandated) that Spire maintain documentation of the safety\nimprovement costs associated with fulfilling this Compliance Order and submit the\ntotal to Director, Central Region, Pipeline and Hazardous Materials Safety\nAdministration. It is requested that these costs be reported in two categories: 1) total\ncost associated with preparation/revision of plans, procedures, studies and analyses,\nand 2) total cost associated with replacements, additions and other changes to pipeline\ninfrastructure.\n5","truncated":false,"body_characters":16470}