Date: Dec. 16, 2024

Attention: All Minnesota Intrastate Pipeline Operators

Subject: 2025 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 request for specific information (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 intrastate pipeline operators. Please review the questions below to determine the information you need to provide based on your operator type. 

Please fill out the RSI form online by Feb. 28, 2025. 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 items are being requested and can prepare their 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: Identification and Evaluation of Potential Hard Spots-In-Line Inspection Tools and Analysis
• 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:

• 02-2024 Pipeline Safety: Notice provides information regarding Quarterly Utility Performance Reporting
• 01-2024 Application of the New Valve Rule
• 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​​
• 01-2021 Pipeline Safety: Gas Pipeline Regulatory Reform: Final Rule; withdraw​a​l of enforcement discretion
• 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
• Safety Alert: Prevent snow, ice and water damage
• 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 
• Precise marking instructions
• 01-2010 Preventing gas/sewer cross-bores

Reportable event policy

Please acknowledge your company has reviewed and has processes for OPS’ reportable events.

2024 Regular session changes to Minnesota Statute 216D

Please acknowledge your company has reviewed the recent changes to Minnesota Statute 216D.

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.

NTSB recommendations

Please acknowledge your company has reviewed the NTSB investigation results and recommendations below as applicable.

• PIR-23-02 Marathon Pipe Line LLC Pipeline Rupture and Crude Oil Release, Edwardsville, IL (3/11/2022) 
• PIR-23-01 Kinder Morgan, Inc. Natural Gas-Fueled Explosion and Fire, Coolidge, AZ (8/15/2021)
• PIR-22-03 Atmos Energy Corporation Natural Gas–Fueled Explosion During Routine Maintenance, Farmersville, TX (6/28/2021)
• MAR-21-05 Hazardous Liquid Pipeline Strike and Subsequent Explosion and Fire aboard Dredging Vessel Waymon Boyd, Corpus Christi, TX (8/21/2020)
• PIR-22-02 Enbridge Inc. Natural Gas Transmission Pipeline Rupture and Fire, Danville, KY (8/1/2019)
• PIR-22-01 Enbridge Inc. Natural Gas Pipeline Rupture, Hillsboro, KY (5/4/2022)
• PAR-21-02 Pacific Gas & Electric Third-Party Line Strike and Fire, San Francisco, CA (2/6/2019)
• PAR-21-01​Atmos Energy Corporation Natural Gas-Fueled Explosion, Dallas, TX (2/23/2018)
• PAB-19-03 Natural Gas Explosion at Educational Facility, Minneapolis, MN (8/2/2017)
• PAB-20-01 Magellan Pipeline Anhydrous Ammonia Release, Tekamah, NE (10/17/2016)
• PAB-19-04 Colonial Pipeline Company Gasoline Transmission Pipeline Explosion/Fire, Helena, AL (10/31/2016)
• PAB-19-02 Natural Gas Explosion at Family Residence, Firestone, CO (4/17/2017)
• PAR-19-02 Overpressurization of Natural Gas Distribution System, Explosions, and Fires, Merrimack Valley, MA (9/13/2018)
• PAR-19-01 Building Explosion and Fire, Silver Spring, MD (8/10/2016)
• PAB-00-01 Natural Gas Service Line and Rupture and Subsequent Explosion and Fire, Bridgeport, AL (1/22/1999)

Pipeline abandonment

• Does your company have procedures for pipeline abandonment, including a collection of geospatial information pursuant to MN State Statute 216D.04 Subd 3(h)? If so, please cite the procedure name(s) and the applicable manual section(s).

Pipeline Safety Management Systems

• Does your company implement Pipeline Safety Management Systems (PSMS), or API RP 1173?
• What level of maturity is the PSMS? 

Control rooms

• Do any pipelines your company operates have a control room as defined in 49 CFR parts 192.3 or 195.2? A control room is an operations center staffed by personnel responsible for remotely monitoring and controlling a pipeline facility.
• Do any of these control rooms monitor 250,000-plus natural gas services or transmission facilities with a compressor station?
• Are any control rooms in your company managed by a contractor who oversees other operator control rooms simultaneously with yours?

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 2025?
• 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 the applicable manual section(s).
• 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 in-house or contracted locators to be qualified?
• If a locator has 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 the applicable manual section(s).

Mapping procedures

• Does your company have procedures to correct mapping errors when found? If so, please cite the procedure name(s) and the applicable manual section(s).
• 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 excavation occurs near pipeline facilities considered high-profile, high-pressure, critical, crucial, or otherwise similar? If so, please cite the procedure name(s) and the applicable manual section(s).

Thank you for completing this RSI. Please contact your lead inspector or our main office with any questions or concerns.

Office of Pipeline Safety
651-201-7230
dps.mnops.response@state.mn.us