2137_0047_2017 Supporting_Statement

Department of Transportation

Office of the Chief Information Officer

Supporting Statement

Pipeline Safety: Transportation of Hazardous Liquids by Pipeline: Recordkeeping and Accident Reporting

OMB Control No. 2137-0047

INTRODUCTION

The Pipeline and Hazardous Materials Safety Administration (PHMSA) requests approval from the Office of Management and Budget (OMB) for an extension, without change, of an approved collection entitled “Pipeline Safety: Transportation of Hazardous Liquids by Pipeline: Recordkeeping and Accident Reporting” (OMB Control No. 2137-0047). The current expiration date for this information collection is August 31, 2017.

Part A. Justification

1. Circumstances that make collection of information necessary.

Hazardous liquid pipeline operators must keep records to ensure that their pipelines are operated safely. Operators must also report accidents. This information collection promotes the U.S. DOT’s Safety and Environmental Strategic Goals by identifying areas which would benefit from targeted regulatory actions to decrease incidents involving hazardous liquid low-stress lines.

The requirements for accident reporting and recordkeeping are found in 49 CFR Part 191 and 195. The PHMSA delegation of authority is found in 49 CFR 1.97 which allows for PHMSA to exercise the authority vested in the Secretary in under Chapter 601 of title 49, U.S.C.

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

The information collection provides PHMSA with the information necessary to evaluate the risk posed by these lines. PHMSA will use the information provided in the reports to more accurately assess the risks to hazardous liquid pipeline infrastructure, understand emerging safety related trends, and identify opportunities for improving the regulatory system for hazardous liquid pipelines.

3. Extent of automated information collection.

PHMSA Form 7000.1 Hazardous Liquid Accident Report may be submitted electronically on-line on the PHMSA website. PHMSA encourages the use of electronic technology. PHMSA expects at least 90 percent of data collection and reporting to be completed electronically.

4. Efforts to identify duplication.

There is no duplication, as the information collected is unique to specific situations.

5. Efforts to minimize the burden on small businesses.

The burden has been made as simple as possible. PHMSA expects impacted operators to be large and small businesses. For PHMSA to be able to effectively carry out its legislative mandate and monitor overall pipeline safety, it is essential that both large and small operators of pipelines provide accident reports.

6. Impact of less frequent collection of information.

It is not possible to conduct the collection less frequently and still ensure the necessary level of safety to life and property inherent in transporting hazardous materials. PHMSA would not be able to adequately assess potential risks associated with these pipelines, which could potentially be detrimental to the pipeline safety and the protection of the environment. Therefore, less frequent information collection could compromise the safety of the U.S. pipeline system and the environment.

7. Special circumstances.

This collection of information is generally conducted in a manner consistent with the guidelines in 5 CFR 1320.5(d)(2). There are three anticipated potential special circumstances regarding information collection: (1) A special circumstance could occur if an operator has more than one low-stress pipeline incident or accident within an officially recognized business quarter; (2) An operator may have an accident or incident in the same quarter as their annual report is submitted; and (3) More than a single safety-related condition within a single business quarter is also possible. Operators’ safety measures and vigilance can avoid such circumstances. As such, PHMSA does not mandate information collection occur twice within a single quarter.

8. Compliance with 5 CFR 1320.8.

PHMSA published a notice in the Federal Register on May 13, 2016 [81 FR 29943] requesting comments on this information collection.

9. Payments or gifts to respondents.

There is no payment or gift provided to respondents associated with this collection of information.

10. Assurance of confidentiality.

PHMSA does not have the authority to guarantee confidentiality.

11. Justification for collection of sensitive information.

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

12. Estimate of burden hours for information requested.

Estimated Annual Burden Hours:

52,429 hours

Written plans for HL operator telephonic notification of accident (447 responses/ 2,682 hours).

49 CFR 195.52 (c) requires operators to have a written procedure to calculate and provide reasonable initial estimate of the amount of released product whenever there is a reportable accident as described in 49 CFR 195.50.

PHMSA assumes that approximately 335 HL pipeline operators will be impacted by the requirement for operators to have and use a procedure to calculate and report a reasonable initial estimate of released product. Since these operators submit 447 annual reports, PHMSA estimates that each report represents a separate facility and therefore, a separate procedure. PHMSA estimates that it will take approximately 6 hours to develop and maintain each procedure on an annual basis. The total burden will be approximately 2,682 hours (447 * 6) each year.

Accident Reporting (PHMSA Form 7000-1) (400 responses/4,000 hours)

49 CFR 195.54 requires operators to file an accident report, as soon as practicable, but not later than 30 days after discovery of the accident, on DOT Form 7000-1 whenever there is a reportable accident as described in 49 CFR 195.50.

PHMSA estimates that 400 accident reports (responses) are submitted each year.

PHMSA estimates that all reports (400) will take approximately 10 hours to file. This results in a burden hour estimate of 4,000 hours (400 responses * (10)

“Incorporation by Reference of Industry Standard on Leak Detection” (50 responses/100 hours)

49 CFR 195.444 requires operators of Hazardous Liquid pipelines to comply with API RP 1130 which was incorporated by reference into the Pipeline Safety Regulations in 49 CFR 195.3. This standard requires recordkeeping activities that pertain to computational pipeline monitoring (CPM) leak detection systems.

PHMSA estimates that there are 50 operators in the U.S. using CPM systems. PHMSA expects there to be 50 respondents and 50 responses annually. Each of these responses will require approximately 2 hours of an engineer’s time to prepare and record the CPM test results for an overall industry burden of 100 hours (50 responses x 2 hours) for to this information collection.

Recordkeeping Requirements for HL Operators (335 responses/45,647 hours)

49 CFR 195.505, 195.507, and 195.509 require Hazardous Liquid pipeline operators to have written documentation of various operator qualification requirements. The records must be kept, maintained, and available for review by the Administrator of PHMSA or by a state agency participating under 49 U.S.C. Chapter 601 if the program is under the authority of that state agency.

49 CFR 195.505 requires operators to have and follow a written qualification program. 49 CFR 195.507 provides a breakdown of the specific recordkeeping requirements. Operators are required to keep and maintain the following records for each of their employees subject

(1) Identification of qualified individual(s);

(2) Identification of the covered tasks the individual is qualified to perform;

(3) Date(s) of current qualification; and

(4) Qualification method(s).

Records supporting an individual's current qualification shall be maintained while the individual is performing the covered task. Records of prior qualification and records of individuals no longer performing covered tasks shall be retained for a period of five years.

PHMSA assumes that approximately 335 HL pipeline operators will be impacted by the requirement to develop and maintain these records. PHMSA estimates that each of these operators will spend approximately 136 hours annually creating and maintaining these records resulting in an overall burden of 45, 647 hours annually.

The overall burden estimate for this information collection is 52, 429 [Telephonic plan (2,682 hours) + Accident Reporting (4,000 hours) + Leak Detection (100 hour) + Recordkeeping (45,647)]

13. Estimate of total annual costs to respondents.

The expected costs associated with the burden hours are assumed to be filled out by a senior engineer whose fully-loaded hourly cost (i.e., salary plus overhead) is estimated to $64 x 52,429 hours = $3,355,456.00.

14. Estimate of cost to the Federal government.

PHMSA spends an estimated cost of $61,325 to operate and maintain this information collection. Operations and maintenance includes PRA compliance, interface improvements, database management, planning, revisions, and customer service.

	Monthly Average (Hrs)	Hourly Rate	Annual Hours	Total Costs
Salary Costs	2	$38.82/hr	24	$930
Contracting Costs Haz. Liquid Accident Forms	39	$128.50/hr	470	$60,395
TOTAL				$61,325

15. Explanation of program changes or adjustments.

PHMSA is not revising this information collection at this time.

16. Publication of results of data collection.

The results of the accident reports will be summarized and posted on PHMSA’s website.

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

PHMSA is not seeking approval to not display the expiration date.

18. Exceptions to certification statement.

There is no exception to PHMSA’s certification of this request for information collection approval.

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