2137-0627_Supporting StatementA_OQRule

2137-0627_Supporting StatementA_OQRule.doc

National Registry of Pipeline and LNG Operators

OMB: 2137-0627

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Department of Transportation

Office of the Chief Information Officer


Supporting Statement

National Registry of Pipeline and LNG Operators”

OMB Control No. 2137-0627

Docket No. PHMSA-2013-0163


INTRODUCTION

The Pipeline and Hazardous Materials Safety Administration (PHMSA) requests approval from the Office of Management and Budget (OMB) for an extension and amendment of a currently approved collection entitled “National Registry of Pipeline and LNG Operators” (OMB Control No. 2137-0627). The current expiration date for this information collection is December 31, 2014. The amendment of this information collection is necessary due to the following PHMSA action that will affect the current collection of information:


  • Docket No. PHMSA-2013-0163 - Pipeline Safety: Operator Qualification, Cost Recovery, Accident and Incident Notification, and Other Pipeline Safety Proposed Changes

  • Adds 10 responses and 10 annual burden hours for the reporting requirements associated with operator notifications.


Part A. Justification


  1. Circumstances that make the collection of information necessary.

PHMSA’s statutory authority to collect pipeline facility information from operators is found in 49 U.S.C. 60102. This authority allows for the collection of information such as pipeline location, description, transported products, and any other information pertaining to the safe operation of a pipeline facility under PHMSA jurisdiction.


Moreover, 49 CFR 191.22 and 195.64, require operators to notify PHMSA when they experience significant asset changes, including new construction, that affect PHMSA’s ability to accurately monitor and assess pipeline safety performance. Certain types of changes to, or within, an operator’s facilities or pipeline network represent potential safety-altering activities for which PHMSA may need to inspect, investigate, or otherwise oversee to ensure that any public safety concerns are adequately and proactively addressed. In these cases, timely notification will allow PHMSA to efficiently manage its inspection resources or notify one of its partner state pipeline safety agencies if needed.


The accurate and timely representation of the scope and make-up of the nation’s pipeline and LNG facility infrastructure is not only critical to PHMSA, but it is also critical to the various oversight bodies, Congress, the GAO, the DOT Inspector General, and the NTSB.


  1. How, by whom, and for what purpose the information is to be used.

PHMSA will use two forms to collect the applicable registration and notification information from operators for the Registry: the Operator Assignment Request Form (PHMSA F 1000.1) and the Operator Registry Notification Form (PHMSA F 1000.2). The Pipeline Safety: Operator Qualification, Cost Recovery, Accident and Incident Notification, and Other Pipeline Safety Proposed Changes NPRM will affect the collection of data using the Operator Registry Notification form. The purpose of this form is to provide PHMSA with notifications as required under §§ 191.22(c) and 195.64(c). PHMSA will use the information from this form to update the Registry and equip PHMSA and state regulatory staff with relevant and up-to-date information on the operators subject to applicable jurisdictions.


The Operator Registry is necessary to compile an integrated national pipeline inventory of operator contact and facility information that is current. The Registry will also enable PHMSA to distribute up-to-date pipeline safety information for various technology applications used in the performance of inspections, regulatory oversight, reporting, and other safety-based needs, and will provide the accurate and up-to-date compilation of operating entities and facilities that is a critical element of PHMSA’s pipeline safety mission.


  1. Extent of automated information collection.

Operators will be required submit the required forms (OPID Assignment Request and Operator Registry Notification) electronically. Operators unable to submit electronically can contact PHMSA for an alternate means of submission.


  1. Describe efforts to identify duplication.

To date, PHMSA is the only entity that compiles a national database of regulated pipeline operators


  1. Efforts to minimize the burden on small businesses.

PHMSA expects affected operators to be both large and small businesses. However, this information is necessary for safety and tracking purposes regardless of business size. There are currently no exceptions for small businesses.


6. Impact of less frequent collection of information.

The information collection is event driven and therefore cannot be conducted less frequently. PHMSA would be unable to appropriately and properly assess its regulated community. Less frequent information collection could compromise the safety and economic viability of the U.S. pipeline system.


7. Special Circumstances.

No special circumstances apply with this regulation.


8. Compliance with 5 CFR 1320.8(d).

PHMSA issued a Notice of Proposed Rulemaking (NPRM) on July 10, 2015 (80 FR 39916). The comment period ends on September 8, 2015.


9. Payments or gifts to respondents.

PHMSA will not provide payments or gifts to respondents.


10. Assurance of confidentiality.

PHMSA does not have the authority to assure confidentiality.

11. Justification for collection of sensitive information.

The requirements of this information collection do not involve questions of a sensitive nature.


12. Estimate of burden hours for information requested.

Currently approved: 630 Responses and 630 burden hours

Newly Added: 10 Responses and 10 burden hours


Currently, PHMSA estimates 210 new operators to apply for an OPID. PHMSA also estimates that it will receive 420 operator notifications for a combined 630 (210 OPID requests + 420 Operator Notifications) annual responses. Each of these responses is estimated to take 1 hour to complete for an estimated annual burden of 630 annual burden hours.


The proposals in the Operator Qualification, Cost Recovery, Accident and Incident Notification, and Other Pipeline Safety Proposed Changes NPRM would amend 191.22 to require operators to notify PHMSA upon the occurrence of the following: construction of 10 or more miles of a new or replacement pipeline; construction of a new LNG plant or LNG facility; reversal of product flow direction when the reversal is expected to last more than 30 days; if a pipeline is converted for service under § 192.14, or has a change in commodity as reported on the annual report as required by § 191.17.

These notifications are estimated to be rare but would fall under the scope of Operator Notifications required by PHMSA as a result of this proposed rule. PHMSA estimates that this new reporting requirement will add 10 new responses and 10 annual burden hours to the currently approved information collection for a combined new burden estimate of 640 (previously estimated 630 +newly added 10) responses and 640 (640 responses x 1 hour) annual burden hours.


13. Estimate of the total annual costs burden.

PHMSA expects for a senior engineer will to handle their company’s registry information. PHMSA estimates the engineer’s hourly wages at $64.75 per hour. Based on this information; PHMSA estimates that this requirement will cost the community of impacted operators a total of $41,440 per year ($64.75* 640 hours).


14. Estimates of costs to the Federal Government.

PHMSA expects to incur no additional costs due to the collection of this information.


  1. Explanation of the program change or adjustments.

The Pipeline Safety: Operator Qualification, Cost Recovery, Accident and Incident Notification, and Other Pipeline Safety Proposed Changes NPRM would amend 191.22 to require operators to notify PHMSA upon the occurrence of the following: construction of 10 or more miles of a new or replacement pipeline; construction of a new LNG plant or LNG facility; reversal of product flow direction when the reversal is expected to last more than 30 days; if a pipeline is converted for service under § 192.14, or has a change in commodity as reported on the annual report as required by § 191.17.

PHMSA estimates that this new reporting requirement will add 10 new responses and 10 annual burden hours to the currently approved information collection.


16. Publication of results of data collection.

PHMSA will publish basic information at www.phmsa.dot.gov. “Basic Information” will be focused on summary data such as:


  • # of operators per state/county

  • # of operators by transported commodity

  • # of operators for all commodities

  • # of miles for each commodity

  • # of miles for each operator


17. Approval for not displaying the expiration date of OMB approval.

PHMSA is not requesting approval to not displaying the expiration date.


  1. Exceptions to the certification statement.

There are no exceptions to the certification statement.



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