2019_EFV_2137-0631_ Supporting Statement (2)

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Department of Transportation

Pipeline and Hazardous Materials Safety Administration

Office of Pipeline Safety

SUPPORTING STATEMENT

Excess Flow Valves – New Customer Notifications

OMB Control No. 2137-0631

Docket No. PHMSA-2019-0137

INTRODUCTION

This is to request the Office of Management and Budget’s (OMB) three-year approved clearance for an information collection under OMB Control No. 2137-0631 entitled, “Excess Flow Valves – New Customer Notifications.”

Part A. Justification

1. Circumstances that make the collection of information necessary.

Excess Flow Valves (EFVs), which are safety devices installed on natural gas pipelines to reduce the risk of accidents, are required for new or replaced gas service lines servicing single-family residences (SFR) as defined in §192.383(a). This includes new or replaced service lines serving branched SFRs, multi-family residences, and small commercial entities consuming gas volumes not exceeding 1,000 Standard Cubic Feet per Hour (SCFH). PHMSA also requires the use of curb valves (manual service-line shut-off valves) for those service lines with meter capacities exceeding 1,000 SCFH.

The mandate in 49 U.S.C. 60110(c) requires the Secretary of Transportation to prescribe regulations requiring operators to notify customers in writing about EFV availability, the safety benefits derived from installation, and costs associated with installation. The regulations are to provide that, except where installation is already required by law, the operator will install an EFV that meets prescribed performance criteria at the customer’s request, if the customer pays all costs associated with installation, maintenance, and replacement.

Excavation activities often sever gas service lines causing loss of life, injury, or property damage by fire or explosion despite the prevalence of one-call damage prevention programs. The National Transportation Safety Board (NTSB) has recommended excess flow valves (EFVs) as a means to mitigate the consequences of service line incidents. EFVs restrict the flow of gas by closing automatically when a service line is severed, thus mitigating the consequences.

Notifications giving customers information on EFVs may encourage the increased use of EFVs and lead to a reduction in fatalities, injuries, and property damage that can result from excavation-related incidents on gas service lines.

This information collection request supports DOT’s safety performance goal of reducing total incidents for gas and hazardous liquid pipelines which directly supports the DOT’s safety strategic objective of enhancing public health and safety by working toward the elimination of transportation-related deaths and injuries.

This information collection supports the DOT strategic goal of safety by reducing the number of fatalities, injuries, and amount of property damage.

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

Notices will be used by operators to inform their customers of their right to request the installation of EFVs . Operators will be required to maintain records proving that the notifications have been sent to existing and new customers. Records will be reviewed by OPS and State agencies to investigate operators’ compliance with the notification rule.

3. Extent of automated information collection.

PHMSA encourages the use of automation. Operators are free to send customers written notices electronically. Operators have multiple options for fulfilling this requirement, including adding a short statement to customer bills, incorporating a public awareness message on the company website, incorporating the notification on bill stuffers or in new customer packets, and posting a notice in a prominent location (for master-meter/small LPG operators).

The operators do not submit any information to OPS but keep records that include a copy of the notice. Records will be reviewed by OPS and State agencies to investigate operators’ compliance with the notification requirement. Operators are encouraged to keep electronic records to reduce additional burden.

4. Describe efforts to identify duplication.

OPS is unaware of any data collected by another agency that is similar in nature.

5. Efforts to minimize the burden on small businesses.

PHMSA expects impacted operators to include both large and small businesses and therefore the requirements will impact small businesses. Provisions have been made for master meter operators, typically small business, to allow them to reduce the burden of sending individual customer notificaitons by posting general notifications in prominent locations frequented by customers.

6. Impact of less frequent collection of information.

This information can not be collected less frequently as it is only required on occasion. Completing this task less frequently could result in new customers being unaware of their right to request the installation of EFVs and potentially lead to safety hazards.

7. Special Circumstances.

There are no special circumstances associated with this collection of information.

8. Compliance with 5 CFR 1320.8(d).

PHMSA published a notice and request for comments in the Federal Register (84 FR 37004) on July 30, 2019. PHMSA did not receive any comments pertainting to the renewal of this information collection.

9. Payment or gifts to respondents.

Payments made or gifts given to respondents are not applicable to this information collection.

10. Assurance of confidentiality.

This information collection does not include anything of a sensitive nature or of any matters considered private. Therefore, we do not foresee any need to assure confidentiality of the information to be collected.

11. Justification for collection of sensitive information.

The information requested is not sensitive in nature.

12. Estimate of burden hours for information requested.

Estimated Number of Respondents: 4,448.

Estimated Annual Burden Hours: 4,448.

Responses	Burden per Response	Total Burden
3,119 master-meter operators	1 hour	3,119 hours
1,329 gas distribution operators	1 hour	1,329 hours
4,448 Responses		4, 448 Hours

Operators of natural gas pipelines are required to notify customers of their right to request the installation of EFVs. PHMSA estimates that approximately half of the 6,237 operators categorized as either master-meter operators or small LPG systems will be impacted, resulting in 3,119 affected operators. This estimate is based on the premise that only half of these operators have systems that can accommodate an EFV. PHMSA also estimates that 1,329 gas distribution operators will be impacted. Therefore, PHMSA estimates a total impacted community of 4,448 (3,119 master-meter/small LPG operators and 1,329 gas distribution operators).

PHMSA estimates that each impacted operator will take approximately 30 minutes per year to complete this notification and an additional 30 minutes per year to maintain the associated records

PHMSA estimates that each impacted operator will take approximately 30 minutes per year to complete this notification and an additional 30 minutes per year to maintain the associated records resulting in an overall burden estimate of 4,448 (4,448 operators * 1 hour).

13. Estimate of the total annual costs burden.

While this information collection does not require operators to purchase any additional materials or equipment, PHMSA recognizes the salary costs associated with this requirement. Based on the May 2018 industry-specific occupational and wage estimates provided by the U.S. Department of Labor’s Bureau of Labor Statistics (https://www.bls.gov/oes/current/naics3_486000.htm), median hourly wage of an engineering manager (for NAICS 486000 – pipeline transportation) ^a is estimated as $77.50. Using an estimated fringe benefit of approximately 35 percent, the recordkeeping requirements for the gas operators are prepared at the average rate of $104.63 per hour.

PHMSA estimates the total annual cost of this provision to be $465,394.24 per year (4,448 operators * 1 hour/operator * $104.63/hour.

14. Estimates of costs to the Federal Government.

Costs to the Federal Government are minimal. Reviewing operators’ records to ensure that the notice contains the appropriate material and is being sent out as required is done during routine operator inspections and does not require additional cost to the government.

15. Explanation of the program change or adjustments.

There are no program changes or adjustments.

16. Publication of results of data collection.

The information will not be published for statistical purposes.

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

OPS is not seeking such approval.

18. Exceptions to the certification statement.

There is no exception.

a https://www.bls.gov/oes/current/naics3_486000.htm