Department of Transportation
Office of the Chief Information Officer
Supporting Statement
“Annual and Incident Reports for Gas Pipeline Operators”
OMB Control No. 2137-0522
Docket No. PHMSA-2019-0172
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 “Incident and Annual Reports for Natural Gas Pipeline Operators” (OMB Control No. 2137-0522). The current expiration date for this information collection is May 31, 2024.
The revision of this information collection includes the following changes:
Clarifies several instructions and modifies the reporting of well counts within Form PHMSA F 7100.4-1, “Underground Natural Gas Storage Facility Annual Report.”
Adds a new part to Form PHMSA F7100.2-1, “Annual Report for Natural and Other Gas Transmission and Gathering Pipeline Systems” to collect the method used to determine high consequence areas (HCAs) and the type of risk model used for miles of gas transmission pipeline in HCAs.
Revises the instructions to Form PHMSA F7100.2, “Gas Transmission and Gathering Systems Incident Report” to clarify the requirement for operators to report relief valve lifts and compressor station emergency shutdown events when the systems function as expected.
Part A. Justification
1. Circumstances that make collection of information necessary.
The reports contained within this information collection support the Department of Transportation’s strategic goal of safety. Annual summary reports help to inform PHMSA and the public of release incident risks and trends. The National Transportation Safety Board (NTSB), the U.S. Department of Transportation’s Office of the Inspector General, and the General Accounting Office all urged PHMSA to collect this information. The information is an essential part of PHMSA’s overall effort to minimize natural gas storage, transmission, gathering, and distribution pipeline failures.
The requirements for annual reporting and telephonic notification of incidents are in 49 CFR Part 191. 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.
The specific legislative authority cites for the requirements in 49 CFR Part 191 include49 U.S.C. 60102, 60103, 60104, 60108, 60117, 60118, 60124 and the recently revised 60139.
2. How, by whom, and for what purpose is the information used.
PHMSA uses this information collection to gather annual data and failure information from natural gas pipeline operators. The term “natural gas pipeline operators” includes Gas Transmission operators, Gas Distribution operators, and LNG pipeline facility operators.
PHMSA collects annual information from gas pipeline operators via annual reports. The annual report form has query fields regarding incident cause categories, impacts, failure mechanisms, locations, and other details about natural gas pipeline incidents. PHMSA uses the information to track incidents and help guide future regulations to reduce future pipeline incidents. The annual report forms are identified as follows:
Underground Natural Gas Storage Annual Report
Gas Transmission Annual Report
LNG Annual Report
The information from annual reports are used for identifying existing or potential pipeline safety problems, to develop statistical and data/safety reports, and to develop benefit-cost analyses pertaining to pipeline safety.
3. Extent of automated information collection.
PHMSA requires operators to submit all required reports electronically with an exception for those operators to whom electronic submissions would pose an undue burden and hardship. Pipeline operators are encouraged to file annual reports on-line at www.opsweb.phmsa.dot.gov.
4. Efforts to identify duplication.
PHMSA is the only federal agency that collects information related to distribution pipeline failures. No similar information is requested by the government or industry on distribution pipeline failures that occur between the point-of-sale to a distribution company and a customer’s meter.
The information collection on gas transmission and gathering pipelines is extremely limited in terms of scope and population of gas pipeline operators covered. The Department of Interior (DOI) collects information that is in some ways similar to that collected by PHMSA, but the information DOI collects does not cover all gas transportation or gathering pipelines.
5. Efforts to minimize the effects on small business.
For PHMSA to be able to effectively carry out its legislative mandate and monitor natural gas pipeline safety, it is essential that both large and small operators of pipelines provide annual reports. PHMSA will make exception in cases where it is not feasible for operators to submit electronically.
6. Impact of less frequent collection of information.
The biennial report to Congress mandated by 49 U.S.C. 60124(b) would not have current information without the annual report data. Less frequent information collection could compromise the safety and economic viability of the U.S. pipeline system.
7. Special circumstances.
There are no special circumstances within this request.
8. Compliance with 5 CFR 1320.8.
On December 17, 2020, PHMSA published a 60-day Notice (85 FR 82028) in the Federal Register soliciting comments on the proposed revisions to this information collection. During the 60-day comment period, PHMSA received comments from the National Association of Pipeline Safety Representatives and a joint comment from the American Gas Association, the American Petroleum Institute, the American Public Gas Association, and the Interstate Natural Gas Association of America.
The comments received have been summarized and addressed in the 30-Day Notice (86 FR 26600) published in the Federal Register on May 14, 2024.
Additionally, PHMSA maintains an “open-door” policy with its stakeholders where continual engagement on ways to improve pipeline safety are routine. In this vein, PHMSA has participated in various discussions where updates on this information collection were provided. PHMSA included updates on this information collection in its regulatory updates presentation that is used to update stakeholders on the status of pending actions. PHMSA has taken all feedback received into consideration in the proposed adjustments.
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, however, this information collection does not include anything of a sensitive nature or of any matters considered private.
11. Justification for collection of sensitive information.
This information collection does not involve questions of a sensitive nature.
12.
Estimate of burden hours for information requested.
Current Number of Responses: 2,247 |
Proposed Number of Reponses: 2,247 |
Current Burden Estimate: 71,801 hours |
Proposed Burden Estimate: 71, 801 hours |
As the proposed changes serve primarily to provide operators clarity in how to report certain data elements, PHMSA expects that the currently-approved burden for this information collection will remain the same.
A breakdown of the estimated burden for this information collection is detailed below:
IC |
Responses |
Burden Per Response |
Total Burden |
Gas Transmission and Gathering Annual Report |
1,440` |
47 hours per report |
67,680 hours |
LNG Annual Report |
113 |
12 hours per report |
1356 hours |
Underground Storage Annual Report |
124 |
20 hours per report |
2,480 hours |
Immediate Notice of Incidents |
570 |
0.5 hours per report |
285 hours |
Total |
2,247 Annual Responses |
|
71, 801 Annual Burden Hours |
(a) Annual Reports for gas transmission and gas gathering systems, LNG Facilities, and underground natural gas storage facilities (Section 191.17) w/1677 responses
Annual reports are required for all operators of gas transmission and gathering pipeline systems, liquefied natural gas facilities and underground natural gas storage facilities. An explanation of the estimated burden for each report collection is detailed as follows:
1. Transmission Systems Annual Report (67,680 hours)
PHMSA estimates that it receives approximately 1,440 gas transmission annual reports each year. PHMSA estimates that it will take operators approximately 47 hours to compile and submit the data required to comply with this annual reporting requirement. This includes the time it will take to review instructions, gathering the data needed, completing, reviewing and submitting the requested data.
The revisions to the “Annual Report for Natural and Other Gas Transmission and Gathering Pipeline Systems” Form include reorganizing some data fields to streamline the collection of certain data elements; and collecting the number of miles and type of risk model used in high consequence areas in accordance with 49 CFR 192.903. PHMSA expects the burden associated with reporting this data to be negligible and believes that it is already absorbed by the existing burden estimate of 47 hours to complete the form.
Accordingly, PHMSA estimates the burden associated with collecting Gas Transmission and Gathering Systems annual data to be 67,680 hours (1,440 reports *47 hours per report) each year.
2. LNG Annual Report (1,356 hours)
PHMSA estimates that there are 82 LNG pipeline operators for 113 LNG facilities. PHMSA expects to receive an annual report submission for each of the 113 LNG facilities. PHMSA estimates that it will take LNG operators 12 hours to prepare each annual report submission. This includes the time it will take to review instructions, gathering the data needed, completing, reviewing and submitting the requested data. Accordingly, PHMSA estimates the information collection burden associated with the LNG annual report information collection to be approximately 1,356 hours (113 LNG reports* 12 hours per report) each year.
3. Underground Natural Gas Storage Facility Annual Report (2,480 hours)
49 CFR § 191.17 requires each operator of an underground natural gas storage facility to submit an annual report on DOT PHMSA Form 7100.4-1 by March 15, for the preceding calendar year. PHMSA estimates that there are 124 operators of underground natural gas storage facilities. PHMSA expects each of these operators to spend 20 hours, annually, to prepare annual report submissions. This includes time for reviewing instructions, gathering the data needed, reviewing the required data, and completing and submitting PHMSA Form 7100.4-1for an overall burden of 2,480 hours (124 reports *20 hours per report) for annual report submissions.
(b) Immediate Notice of Incidents (Section 191.5) w/570 Responses
Gas Pipeline operators are required to provide immediate notification of incidents as detailed in § 191.5. Based on previous years’ reporting trends, there was an annual average of 570 immediate notifications. PHMSA estimates that it will take operators approximately 30 minutes to complete these notifications. As such, PHMSA estimates the total burden associated with this information collection to be 285 hours (= 570 reports x 0.5 hours).
(c) Total Hours:
Telephonic Notification (285 hours) Annual Reports (+67,680 +1,356+2,480) = 71,801 hours.
13. Estimate of total annual costs to respondents.
PHMSA assumes that the reporting would be made by an engineering manager. Based on the industry-specific occupational and wage estimates provided by the U.S. Department of Labor’s Bureau of Labor Statistics, median hourly wage of an engineering manager (for NAICS 486000 – pipeline transportation)1 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.
The total annual estimated costs for this information collection with all of the incorporated proposals would be $7,512,538.63 (= $104.63 * 71,801 hours)
14. Estimate of cost to the Federal Government.
PHMSA spends an estimated cost of $189,969.00 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* |
7 |
$38.82/hr |
84 |
$3,260 |
Contracting Costs- Gas Annual Forms (GT, LNG, UNGS) |
129.25 |
$120.38/hr |
1551 |
$186,709 |
TOTAL |
|
|
|
$189,969.00 |
15. Explanation of program changes or adjustments.
PHMSA is revising this information collection to make minor adjustments to the following forms and instructions: PHMSA F 7100.4-1, “Underground Natural Gas Storage Facility Annual Report,” and PHMSA F 7100.2-1, “Annual Report for Natural and Other Gas Transmission and Gathering Pipeline Systems.”
The revisions to the “Underground Natural Gas Storage Facility Annual Report” Form provide clarity on submitting data and include no new data elements.
The revisions to the “Annual Report for Natural and Other Gas Transmission and Gathering Pipeline Systems” Form include reorganizing some data fields to streamline the collection of certain data elements; and collecting the number of miles and type of risk model used in high consequence areas in accordance with 49 CFR 192.903. Specifically, PHMSA has modified Form PHMSA F7100.2-1 to include new Parts B1 and T. Data will be extracted from the new Part T to automatically populate the new Part B1. PHMSA expects the burden associated with reporting this data to be negligible and believes that it is already absorbed by the existing burden estimate of 47 hours to complete the form. PHMSA estimates that the affected operators will spend approximately 15 minutes of the allotted 47 hours providing the newly requested information.
16. Publication of results of data collection.
PHMSA will summarize the incident and annual reports post the results on PHMSA’s website.
17. Approval for not displaying the expiration date for OMB approval.
PHMSA will display the expiration date.
18. Exceptions to certification statement.
There are no exceptions to the certification statement.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Modified | 0000-00-00 |
| File Created | 2021-07-29 |