Date: January 12, 2024

Attention: All Intrastate Pipeline Operators of Minnesota
 

Subject: 2024 Pipeline Operators RSI

The Pipeline and Hazardous Materials Safety Administration (PHMSA) requires the Minnesota Office of Pipeline Safety (OPS) to verify and track specific items with pipeline operators. This RSI is being submitted pursuant to Minnesota Statute 299F.63 Subdivision (b) and Minnesota Administrative Rules 7530.0400, Subpart 1. This request is specific to only intrastate pipeline operators, operators who have pipelines residing entirely within Minnesota’s border. Please review the sections of questions below to determine the requested information based on your operator type.

Please respond to this RSI by filling out the Request for Specific Information form by Feb. 23, 2024. Operators with multiple operator identifications (OPID) need to complete only one form but must list all OPIDs on that form in the space provided. Your assigned OPS lead inspector can assist with completing this RSI by selecting that option at the beginning of the form.

All Intrastate Operators in Minnesota

All intrastate operators must submit the following information via the online form. The information is detailed below so operators know what specific items are being requested and can prepare answers before filling out the form.

Submittal of Operator Plans and Procedures

Has your company provided OPS with the most up-to-date plans and procedures? If not, please work with your lead inspector to provide an electronic copy to OPS.

PHMSA Bulletins

Please acknowledge your company has reviewed the following PHMSA Advisory bulletins:

• Pipeline Safety: Statutory Mandate To Update Inspection and Maintenance Plans To Address Elimination Hazardous Leaks and Minimizing Releases of Natural Gas From Pipeline Facilities
• Pipeline Safety: Inside Meters and Regulators
• Pipeline Safety: Overpressure Protection on Low-Pressure Natural Gas Distribution Systems
• Pipeline Safety: Potential for Damage to Pipeline Facilities Caused by Earth Movement and Other Geological Hazards
• Pipeline Safety: Potential for Damage to Pipeline Facilities Caused by Flooding, River Scour, and River Channel Migration

OPS Alert Notices

Please acknowledge your company has reviewed all OPS Alert Notices:

• 03-2022 Pipeline Safety: 49 CFR Parts 199 & 40 Amendments, DOT Drug Testing Clarification, and Recreational Cannabis
• 02-2022 Pipeline Safety: New Cybersecurity Requirements for Minnesota Pipeline Operators issued by Executive Order 22-20
• 01-2022 Pipeline Safety: Provide clarification and guidance for all Minnesota damage prevention stakeholders regarding the use and requirements of “meet” notifications
• 01-2021 Pipeline Safety: Gas Pipeline Regulatory Reform: Final Rule; withdrawal of enforcement discretion
• 03-2020 MS216D Related Compliance Information and Investigation / Enforcement Processes
• 02-2020 Guidance and recommendations for intrastate Minnesota gas pipeline operators on designing and operating their pipeline systems with specific reference to inside meter sets, low-pressure distribution systems and engineering management
• 01-2020 Operating Pipelines within MAOP Thresholds: Over-pressure Protection and Operating Pressures
• 01-2018 Regulatory Requirements for Maintenance and Abandonment
• 01-2017 Pipeline Safety: Accident and Incident Notification
• 02-2016 Interpretation of §192.739 – Pressure Limiting and Regulating Stations: Inspection and Testing
• 01-2016 Expanding the Use of Excess Flow Valves in Gas Distribution Systems
• 02-2010 Barricading above-ground gas pipelines
• 01-2010 Preventing gas/sewer cross-bores

Pipeline Abandonment

Does your company have procedures for pipeline abandonment? If so, please cite the procedure name(s) and manual section(s) that apply.

Pipeline Safety Management Systems

• Does your company implement Pipeline Safety Management Systems (PSMS), or API RP 1173?
  • https://pipelinesms.org/
  • API RP 1173
• What level of maturity is the PSMS? PSMS Maturity Model

Control Rooms

• Do any pipelines your company operates have a control room as defined per 192.3 or 195.2? A control room means an operations center staffed by personnel charged with the responsibility for remotely monitoring and controlling a pipeline facility.

Bare Steel Pipe Replacement

• Does your company have in-service bare steel piping?
• How many miles of in-service bare steel are in your system(s)?
• How many miles of in-service bare steel does your company plan to replace in 2024?
• How many years until all in-service bare steel piping will be replaced in your system?

Directional Drilling/Boring Procedures

• Does your company have procedures for the installation of pipe by directional drilling or boring? If so, please cite the procedure name(s) and manual section(s) that apply.
• Does the procedure(s) include actions to protect facilities from the dangers imposed by drilling and other trenchless technologies?

Locating Procedures and Qualifications

• Does your company require all locators, whether in-house or contracted, to be qualified?
• If a locator is having performance deficiencies at some point does the company require the locator to be requalified?
• Does your company require all locators, whether in-house or contracted, to follow a written locating and or damage prevention procedure(s)? If so, please cite the procedure name(s) and manual section(s) that apply.

Mapping Procedures

• Does your company have procedures to correct mapping errors when found? If so, please cite the procedure name(s) and manual section(s) that apply.
• In what time frame must the error be corrected once found?

Watch-and-Protect Procedures

• Does your company have a watch-and-protect or “watchdog” procedure when excavations take place near pipeline facilities considered high-profile, high-pressure, critical, crucial, or otherwise similar? If so, please cite the procedure name(s) and manual section(s) that apply.

Hazardous Liquid Operators

The requested information below is only specific to intrastate hazardous liquid operators. Intrastate hazardous liquid operators must also respond to the All Intrastate Operators information requested above.

Application of New Valve to Part 195.402

• Have your procedures been updated to reflect the recent changes to 195.402 of which certain portions apply to all hazardous liquid pipeline operators? If so, please cite the procedure name(s) and manual section(s) that apply.

Environmentally Sensitive Areas

• Please provide a list of environmentally sensitive areas traversed by or adjacent to your company's hazardous liquid pipeline(s).

Natural Gas Distribution Operators

The requested information below is only specific to intrastate natural gas distribution operators. Intrastate natural gas distribution operators must also respond to the All Intrastate Operators information requested above and the combined gas distribution and transmission section below.

Low-Pressure Distribution

Per 192.3 a low-pressure distribution system means a distribution system in which the gas pressure in the main is substantially the same as the pressure provided to the customer. This would be a system where no pressure reduction is made at the meter set before delivery to the customer.

• How many systems or unique segments do you operate at low-pressure distribution?
• What are the total miles of main operating as low-pressure distribution?
• What is the total number of services operating as low-pressure distribution?
• Do you have any unique procedures for operating the low-pressure system(s)? If so, please cite the procedure name(s) and manual section(s) that apply.
• Is the threat of over-pressurization of a low-pressure distribution system listed in your Distribution Integrity Management Plan (DIMP)?
• Which type of risk mitigation actions are being used for the risk of over-pressurization (i.e. full capacity relief valves, “slam shut” or “safety shutoff” full closure devices, telemetered pressure recording devices, as-built drawings of sensing lines)?
• How many of the low-pressure systems will be replaced or uprated so they are no longer low-pressure systems within the next 5 years?
• Please acknowledge your company has reviewed NTSB recommendations for the Merrimack Valley incident, specifically P-19-14 and P-19-15. Please list any changes your company has made because of these recommendations.

Merrimack Valley Incident

PermaLock Mechanical Tapping Tee Assemblies

• Does your company utilize PermaLock Mechanical Tapping Tee assemblies? If so, please cite the procedure name(s) and manual section(s) that apply.
• Does your company utilize best practices recommended by the manufacturer in their operations and maintenance manuals and/or distribution integrity management programs, including using the specified tools and methods, to correctly install PermaLock mechanical tapping tee assemblies?

Inside Service Regulators

• Has your company reviewed NTSB recommendations P-19-001 and P-19-002?
• Does your system(s) have any service regulators located inside buildings?
• How many services have regulators inside buildings?
• Do procedures require that all new service regulators be installed outside occupied structures? If so, please cite the procedure name(s) and manual section(s) that apply.
• Do procedures require that all existing interior service regulators be relocated outside occupied structures whenever the gas service line, meter, or regulator is replaced? If so, please cite the procedure name(s) and manual section(s) that apply.
• Do the procedures prioritize multi-family structures over single-family dwellings? If so, please cite the procedure name(s) and manual section(s) that apply.

Master Meter Systems

• To help OPS identify jurisdictional master meter systems unknown to OPS, does your company supply natural gas to any customers who are not the end users of that gas? End users would be using the gas for energy needs such as heating, cooking, etc. This could be apartment buildings, malls, or hospital centers that resell the gas to the end users.

Natural Gas Distribution and Transmission Operators

The requested information below is specific to both intrastate natural gas distribution and transmission operators. Intrastate natural gas distribution and transmission operators must also respond to the All Intrastate Operators information requested above. Intrastate natural gas distribution operators must also respond to distribution specific information above.

Application of New Valve to Parts 192.615 and 192.617

• Have your procedures been updated to reflect the recent changes to 192.615 and 192.617 of which certain portions apply to all gas pipeline operators? If so, please cite the procedure name(s) and manual section(s) that apply.

Plastic Pipe & Components

• Has your company experienced any material-related plastic failures? If so, please list the material type and the problems associated with the material.
• Are these failures identified as a potential threat in your Distribution Integrity Management Plan (DIMP)?

Leaks Caused by Excavation

• Please acknowledge your company has reviewed NTSB recommendations P-00-20 and P-00-21.
• Do you have specific emergency response procedures for leaks caused by excavation damage near buildings? If so, please cite the procedure name(s) and manual section(s) that apply.
• Does the procedure address the possibility of multiple leaks and underground migration into nearby buildings?

Questions or concerns

OPS thanks operators for efforts made in completing this RSI. Please contact your lead inspector or our main office if you have any questions or concerns.