Department of Transportation
Office of the Chief Information Officer
Supporting Statement
“Annual Reports for Gas Pipeline Operators”
OMB Control No. 2137-0522
RIN 2137-AF53
INTRODUCTION
The Pipeline and Hazardous Materials Safety Administration (PHMSA) requests approval from the Office of Management and Budget (OMB) for 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 March 31, 2026.
The revision of this information collection is necessary due to the following PHMSA action that will affect the current collection of information:
Pipeline Safety: Safety of Gas Distribution Pipelines and Other Pipeline Safety Initiatives
Increases annual burden by 4,492 responses and 26,952 hours to collect limited data from operators of small LPGs.
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 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.
49 USC 60117 requires that:
“To enable the Secretary to decide whether a person transporting gas or hazardous liquid or operating a pipeline facility is complying with this chapter and standards prescribed or orders issued under this chapter, the person shall –
(1) maintain records, make reports, and provide information the Secretary requires; and
(2) make the records, reports and information available when the Secretary requests.”
The regulations set forth in 49 CFR 192 require operators to make various notifications upon the occurrence of certain events. The provisions covered under this ICR involve notification requirements for operators who utilize alternative or expanded technologies and analyses when conducting tests and inspections. These notification requirements are necessary to ensure safe operation of transmission pipelines, ascertain compliance with gas pipeline safety regulations, and to provide a background for incident investigations.
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
Type R Reporting-Regulated Annual Report
The information from annual reports is 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.
Data derived from required notifications is used to assist Federal pipeline safety inspectors and State pipeline safety inspectors participating in the gas pipeline safety program. From these notifications, the inspectors will be able to ascertain compliance with regulations. The information will also help to ensure safe pipeline construction, operation, and maintenance, and it will provide important information needed in incident investigations. Further, the information retained will form a record of pipe materials and characteristics that will assist in pipe maintenance and repair efforts by operators.
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 natural and other gas pipeline safety. No similar information is requested by the government or industry on such pipeline attributes. The data collected 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 September 7, 2023 PHMSA published a Noticed of Proposed Rulemaking (88 FR 61746) to seek public comments on the proposed data collection. The comment period closes on November 6, 2023.
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: 2,445 |
Proposed Number of Reponses: 6,937 |
Current Burden Estimate: 104,596 hours |
Proposed Burden Estimate: 131,548 hours |
49 CFR 191.17 requires operators of underground natural gas storage facilities, gas transmission systems, and gas gathering systems to submit an annual report by March 15 for the preceding calendar year.
The Gas Distribution NPRM proposes to collect limited data from operators of small LPGs. PHMSA proposes to create Form F7100.1-2, “Small LPG Annual Report Form F7100.1-2” to collect this data. Accordingly, the burden for this information collection is being revised to account for this new data collection. PHMSA estimates that 4,492 small LPG operators will spend 6 hours annually completing this new report resulting in an increase of 4,492 responses and 26,952 hours to the currently approved burden for this information collection.
A breakdown of the estimated burden for this information collection is detailed below:
IC |
Responses |
Burden Per Response |
Total Burden |
Annual Report for Gas Transmission and Gas Gathering Pipeline Operators |
1,810` |
54 hours per report |
97,740 hours |
Annual Report for Liquefied Natural Gas |
113 |
12 hours per report |
1,356 hours |
Underground Natural Gas Storage Facility Annual Report |
124 |
20 hours per report |
2,480 hours |
Annual Report for Type R (Reporting-Regulated) Gas Gathering Pipeline Systems |
130 |
21 hours per report |
2,730 hours |
Notifications for Gas Transmission Operators |
268 |
1.082 hours |
290 hours |
Small LPG Annual Report |
4,492 |
6 hours |
26, 952 hours |
Total |
6,937 Annual Responses |
|
131,548 Annual Burden Hours |
(a) Annual Reports for gas transmission and gas gathering systems, LNG Facilities, Small LPG systems, and underground natural gas storage facilities (Section 191.17) w/6,669 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 (97,740 hours)
PHMSA estimates that it receives approximately 1,810 gas transmission annual reports each year. PHMSA previously estimated that it would take operators of natural gas transmission and gathering systems approximately 42 hours, per response, to satisfy the reporting requirement. This includes time for reviewing instructions, gathering the data needed, completing, reviewing and submitting the requested data. Based on the proposed revisions PHMSA estimates that completing the Gas Transmission and Gathering Annual report will require an additional 7 hours per report, annually, to include the newly requested data on the number of one-call tickets and the number of excavation damage events in each CGA DIRT root cause category. This change results in an increased burden of 54 hours per report. Accordingly, PHMSA estimates the burden associated with collecting Gas Transmission and Gathering Systems annual data to be 97,740 hours (1,810 reports *54 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.
4. Type R Reporting Regulated Gas Gathering Annual Report (2,730 hours)
49 CFR§ 192.8 designates “Type R” gathering lines as lines that are not regulated gathering lines under 49 CFR Part 192 but are subject to incident and annual reporting requirements in 49 CFR Part 191. PHMSA created new DOT Form PHMSA F7 100.2-3 for Type R gas gathering systems that are not subject to the safety requirements in 49 CFR Part 192. Type R operators are required to submit DOT Form PHMSA F7 100.2-3 by March 15, for the preceding calendar year. PHMSA estimates that there are 130 Type R operators who are subject to this requirement. PHMSA estimates that it will take operators approximately 21 hours annually to complete this report. This includes time for reviewing instructions, gathering the data needed, reviewing the required data, and completing and submitting the mandatory report. This will result in an overall annual burden of 130 responses and 2,730 (130 reports *21 hours per report) hours.
5. Small LPG Annual Report (26,952 hours)
The Gas Distribution NPRM proposes to collect limited data from operators of small LPGs. PHMSA proposes to create Form F7100.1-2, “Small LPG Annual Report Form F7100.1-2” to collect this data. Accordingly, the burden for this information collection is being revised to account for this new data collection. PHMSA estimates that 4,492 small LPG operators will spend 6 hours annually completing this new report resulting in an overall annual burden of 4,492 responses and 26,952 (4,492 reports * 6 hours per report) hours.
(b) Notification Requirements for Gas Transmission Operators w/268 (290 hours)
PHMSA expects approximately 268 gas transmission operators to make various notifications annually. PHMSA estimates that it will take most respondents a little over 1 hour (approx. 1.0892 hours) to make the required notifications making the total added burden to this information collection due to these new notification requirements 290 hours annually.
Total Hours:
Annual Reports (+97,740 +1,356+2,480+2,730+26,952) + Notifications for Gas Transmission Operators (290) = 131,548 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 reporting 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 $13,763,867.24 (= $104.63 * 131,548 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 include 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 |
129.25 |
$120.38/hr |
1551 |
$186,709 |
TOTAL |
|
|
|
$189,969.00 |
15. Explanation of program changes or adjustments.
This ICR is being revised to reflect proposed regulatory changes in the Pipeline Safety: Safety of Gas Distribution Pipelines and Other Pipeline Safety Initiatives NPRM.
This NPRM proposes to collect limited data from operators of small LPGs by way of Form F7100.1-2, “Small LPG Annual Report Form F7100.1-2”. The burden for this information collection is being revised to account for this new data collection.
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 | 2023-09-19 |