2137-0627_Supporting Statement_2019

2137-0627_Supporting Statement_2019.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-2018-0078



INTRODUCTION

The Pipeline and Hazardous Materials Safety Administration (PHMSA) requests approval from the Office of Management and Budget (OMB) for a revision of a currently approved collection entitled “National Registry of Pipeline and LNG Operators” currently under OMB Control No. 2137-0627. The current expiration date for this information collection is July 31, 2020.


The amendment of this information collection is necessary due to the following PHMSA action that will affect the current collection of information:


  • Adds 10 responses and 10 burden hours for National Registry 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.


2. 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 forms and the purpose of the resulting information are identified below:


Operator Assignment Request Form (PHMSA F 1000.1)

The information provided in this form is broken into four different steps as detailed below:


Step 1 “..Basic Report Information”

This step allows for the operator to provide basic information that PHMSA will use to determine whether the requesting operator has regulated assets and currently exists in the registry. PHMSA will also use this information to distinguish relationships between companies and reduce the potential for assigning unnecessary OPIDs to companies.

Step 2 “…Description of Pipelines and/or Facilities”

PHMSA will use this information to collect asset type and location to determine oversight authority (PHMSA region staff or State partners). Once the oversight authority is determined, PHMSA will contact the appropriate entity to assist in the approval process for issuing OPIDs.


Step 3 “…PHMSA-Required Pipeline Safety Program …. Information”

PHMSA will use this information to quickly identify whether the requesting operator’s program is part of any programs for existing operators ( i.e., whether the requesting operator is operationally related to other operators under PHMSA jurisdiction). PHMSA will use this information to efficiently coordinate future inspections.


Step 4 “Provide Contact Information”

PHMSA will use this information to maintain direct lines of communication with key Operator personnel. Contact information is invaluable and vital to the efficient handling of pipeline emergencies and regulatory compliance.



Operator Registry Notification Form (PHMSA F 1000.2)

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.

Summary

This 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.


3. Extent of automated information collection. Operators will be required submit the required forms (OPID Assignment Request and National 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 published a notice in the Federal Register [83 FR 39508] on August 9, 2018. PHMSA received one comment from Vectren Corporation. Vectren Corporation supports the information collection, but notes that it could be improved by more detailed reporting instructions. PHMSA placed detailed instructions for completing the Operator Assignment Request and the National Registry Notification forms in the docket.


9. Payments or gifts to respondents.

PHMSA will not provide payments or gifts to respondents.


10. Assurance of confidentiality.

PHMSA does not issue any assurance of confidentiality. The requirements of this information collection do not include anything of a sensitive nature or of any matters considered confidential.


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.

Current Number of Responses: 679

Proposed Number of Reponses: 689

Current Burden Estimate: 679 hours

Proposed Burden Estimate: 689 hours


The following burden breakdown has been revised to include the burden increase resulting from Part J notifications in the National Registry Notification (PHMSA F 1000.2) PHMSA expects that the currently-approved burden for this information collection will increase by 10 responses and 10 burden hours for notifications.


OPID Assignment Burden

PHMSA expects an estimated 234 new operators to apply for an OPID annually. This includes 24 OPID registrations from operators of underground natural gas storage facilities. PHMSA estimates that each operator will take approximately 1 hour to complete the OPID Assignment form (PHMSA F 1000.1). Therefore, PHMSA estimates an annual burden of 234 hours (1 hour * 234 operators) for the OPID Assignment burden.


Operator Notification Burden

PHMSA usually receives notification from 445 operators, annually, when certain events occur. This includes 25 notifications, annually, from operators of underground natural gas storage facilities. PHMSA expects this burdend to increase by 10 responses this year. PHMSA estimates that each Operator Notification form (PHMSA F 1000.2) will take approximately 1 hour to complete. Therefore, PHMSA estimates an annual burden of 455 hours (1 hour*455 notifications) for the Operator Notification burden.


Summary

Therefore, PHMSA estimates the combined annual burden for OPID Assignment and Operator Notification at 689 hours (234 burden hours for OPID Assignment + 455 burden hours for OPID Notifications).


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 $44,612.75 per year ($64.75* 689 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.


PHMSA intends to revise the National Registry Notification form (PHMSA F 1000.2) and its instructions. PHMSA proposes changing the name of the form from ‘‘Operator Registry Notification’’ to ‘‘National Registry Notification’’ to match the wording of the PHMSA regulations requiring the notifications. PHMSA proposes adding ‘‘Underground Natural Gas Storage’’ as an additional facility type in ste ps 1 and 3 of the form. During fiscal year 2018, PHMSA began partnering with additional state agencies to inspect and enforce PHMSA regulations for underground natural gas storage facilities. Adding ‘‘Underground Natural Gas Storage’’ as an additional facility type is essential for routing the notification to the proper state agency. There are eight safety programs in a type C notification, but only three apply to underground natural gas storage facilities. PHMSA proposes modifying the type C portion of the form to indicate the safety programs required for underground natural gas storage facilities. Operators report various types of construction projects to PHMSA in type F notifications. PHMSA proposes adding a single-select field to describe the main purpose of the construction project. The type J notification section assumes that all LNG construction builds new facilities. PHMSA proposes modifying the type J section to recognize that a notification may be submitted for rehabilitation or replacement of LNG facilities. In step 3 of the form, PHMSA collects data about the location of the facilities covered by the notification. When the notification covers onshore gas gathering, gas transmission, or hazardous liquid pipelines, step 3 data includes the county(ies) for the pipelines. PHMSA uses this county data to associate the notification to a specific portion of the operator’s pipeline system. When the notification covers onshore gas gathering, gas transmission, hazardous liquid facilities, or offshore pipelines or facilities, county data is not collected. PHMSA proposes modifying the form to collect county data for onshore gas gathering, gas transmission, and hazardous liquid facilities, and offshore pipelines and facilities. This change would allow PHMSA to associate each notification to a specific portion of the operator’s pipeline system.


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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