[Federal Register: December 31, 2003 (Volume 68, Number 250)]
[Notices]
[Page 75720-75725]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr31de03-191]
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DEPARTMENT OF TRANSPORTATION
Research and Special Programs Administration
[Docket No. RSPA-98-4957]
Request for Public Comments and OMB Approval of Existing
Information Collection
AGENCY: Research and Special Programs Administration (RSPA), DOT.
SUMMARY: As required by the Paperwork Reduction Act of 1995, the
Research and Special Programs Administration, Office of Pipeline Safety
published its intention to revise forms RSPA F 7100.1, Incident Report
for Gas Distribution Systems, and Form RSPA F 7100.1-1, Annual Report
for Gas Distribution Systems, (68 FR 33759, June 5, 2003). Several
operators, two trade associations representing natural gas distribution
pipeline operators, one state utility commission, and one individual
provided comments. The purpose of this additional notice is to provide
the public an additional 30 days to comment on the proposed revisions
to the natural gas distribution incident and annual reporting forms,
including the form instructions.
DATES: Comments on this notice must be received by January 30, 2004, to
be assured of consideration.
FOR FURTHER INFORMATION CONTACT: Shauna Turnbull by telephone at (202)
366-3731, by fax at (202) 366-4566, by e-mail at
shauna.turnbull@rspa.dot.gov, or by mail at the DOT/RSPA Office of
Pipeline Safety, DPS-13, 400 Seventh Street, SW., Washington, DC 20590.
ADDRESSES: Copies of the proposed information collection and the
revised forms and instructions can be viewed in this docket at http://dms.dot.gov.
You may also visit the Dockets Facility, U.S. Department
of Transportation, Plaza 401, 400 Seventh Street, S.W., Washington,
D.C. 20590-0001. Comments should identify the docket number of this
notice, RSPA-98-4957, and can be mailed directly to: Office of
Information and Regulatory Affairs OIRA), Office of Management and
Budget (OMB), 726 Jackson Place, N.W., Washington, D.C. 20503, ATTN:
Desk Officer for Department of Transportation (DOT).
SUPPLEMENTARY INFORMATION:
Filing Information
The Dockets facility is open from 10 a.m. to 5 p.m., Monday through
Friday, except federal holidays. You should submit an original and one
copy of a comment. If you wish to receive confirmation of receipt of
your comments, you must include a stamped, self-addressed postcard. To
file written comments electronically, after logging onto http://dms.dot.gov
, click on ``Electronic Submission.'' You can read comments
and other material in the docket at: http://dms.dot.gov General information about our pipeline safety program is available at: http://.
ops.dot.gov.
Background
Operators of pipeline systems subject to the Research and Special
Programs Administration/Office of Pipeline Safety (RSPA/OPS) natural
gas distribution systems pipeline safety regulations are required to
report annually, and for each reportable incident, certain information
about those systems. RSPA/OPS uses this information to compile a
national pipeline inventory, to identify and determine the scope of
safety problems, and to target inspections. The information provides
the basis for more efficient and meaningful analyses of RSPA/OPS gas
distribution pipeline incident and annual data.
RSPA/OPS uses pipeline incident and annual data to identify safety
issues and to target risk-based inspections. The data are collected
from incidents reported by operators on RSPA Form F 7100.1, Incident
Report--Gas Distribution Pipelines. Operators are required to file an
incident report form within thirty days after a reportable incident
occurs. Annual information is collected from operators reporting on
RSPA Form F 7100.1-1, Annual Report `` Gas Distribution Pipelines.
Operators are required to file annual report forms with RSPA/OPS by
March 15th for the preceding calendar year.
RSPA/OPS published a notice in the Federal Register on June 5, 2003
(68 FR 33759) inviting comments on proposed revisions to the gas
distribution pipeline operator incident and annual reports and
associated instructions. These revisions require operators to submit
information necessary for the normalization of incident information for
safety trend analysis. The proposed changes are intended to make
information collection more useful to the public, government agencies,
and industry.
Summary of Comments
In response to the Federal Register notice of June 5, 2003 (68 FR
33759) RSPA/OPS received comments from the American Gas Association
(AGA), the American Public Gas Association (APGA), the State of
Colorado Public Utilities Commission (CPUC), Southern Connecticut Gas
and the Connecticut Natural Gas Corporation (Connecticut), Consolidated
Edison Company of New York, Inc. (Con Edison), Southwest Gas
Corporation (Southwest), Atmos Energy Corporation (Atmos), and Mr. John
Erikson, Pipeline Safety Consultant (Mr. Erikson). The comments and
RSPA/OPS responses are summarized below for the proposed incident and
annual report forms and instructions.
Incident Report Form RSPA F 7100.1
Operator Time Burden
AGA expects that, at least for the first year, the operator burden
for completing the forms will exceed the estimated 12 hour completion
time and cost burden. Gas distribution pipeline operators usually
computerize the collection of incident and annual report form data.
Approximately five percent of the workforce may have to be trained
to manage the new data format. One operator estimated that $40,000
would be spent to reprogram the data systems that collect, record,
validate, retrieve, and process this information. APGA states that
asking for extraneous information will increase compliance costs.
RSPA/OPS Response: RSPA/OPS agrees with the comment that the amount
of time to complete the forms was underestimated in the notice. We have
considered the extra impact of computerization and the cost of
increased training, and have doubled the amount of estimated time to
[[Page 75721]]
complete the required incident and annual report forms.
RSPA/OPS believes that the time differential for filing a revised
incident report compared to the existing incident report is small,
because the form is completed for only one of the 25 cause categories
for any given incident. Furthermore, because only a small percentage of
distribution operators have reportable incidents, the cumulative total
time for filing the revised annual information with RSPA/OPS will not
increase significantly.
The revised natural gas distribution pipeline operator annual
report is substantially unchanged, with the major revision being the
addition of the new table for mileage by decade of installation. The
increased time to file the new information for mileage by decade of
installation should not be substantial for most companies, because the
information will be readily available in existing computerized systems
for those decades for which the information is available. When the
information is not available, RSPA agrees that mileage should be
tabulated in the ``Unknown'' category, in lieu of an extensive and
costly information gathering effort. For those operators with
computerized systems, there would be an initial cost for conversion to
provide the information in the tabulated format, but RSPA/OPS believes
the cost would be minimal and the value of collecting the information
outweighs completion time or conversion costs. Smaller companies
without computerization of the information would generally have little
mileage to tabulate. This would result in a minimal increase in
preparation time relative to the time required to complete the current
form.
Operator Cost Burden
AGA stated that:
* * * [p]roper trending of incidents needs to account for
inflationary cost increases. The $50,000 [property damage] incident
reporting threshold has not been increased for more than ten years.
The effect of inflation over a period of time involving the past
decades can be considerable.
For example, a $50,000 loss in 1989 dollars would be equivalent to
$61,543 in 1998. Conversely, if inflation is ignored, a $50,000
incident today can be compared to a $40,622 incident in 1989. Thus,
when adjusted for inflation, natural gas distribution incidents
decreased from 105 in 1989 to 98 in 1998. Accordingly, AGA suggests
that, as part of a future rulemaking, OPS consider raising the monetary
threshold for incident reporting to a higher limit. Additionally, any
reporting of intrastate incidents meeting lower cost thresholds (e.g.,
$5,000) should be identified and segregated from the $50,000 incidents.
RSPA/OPS response: RSPA/OPS interprets AGA's comment to mean that
if operators were required to report incidents with property damage of
$50,000 in 1989, they would estimate the change in the consumer price
index and report only incidents with a real cost of $50,000 in 2003.
Although this would save operators a small amount of money in reduced
paperwork costs, it would cause a great loss to RSPA/OPS in terms of
safety information. For instance, if there were 10 fewer incidents
reported per year, this would save operators 120 hours per year if each
incident took 12 hours to report. At $80 per hour, the total savings
would be less than $1,000 per year. However, if the information from
any incident helped RSPA/OPS identify a potential problem that could
prevent one major incident in the future, the value of this information
would potentially prevent an incident that could cost millions of
dollars in property damage, as well as preventing potential injuries or
fatalities.
RSPA/OPS feels the small burden of reporting incidents resulting in
$50,000 or more in property damage is outweighed by the benefit of the
information provided. Due to the relative scarcity of pipeline
incidents, the information that is gained from any one incident is very
valuable and justifies the minimal expense to the operators.
Data Clarity and Intended Use
APGA observed that if data elements and instructions are unclear,
incorrect data submissions will make it less likely that statistically
significant conclusions could be drawn from the information. APGA
supports data collection if the data is readily available and
beneficial, but urges RSPA/OPS not to collect data unless it can
identify how it will be used in analyses. Moreover, APGA urges RSPA/OPS
to provide information on the intended use for each data element
requested.
RSPA/OPS response: RSPA/OPS agrees that unclear instructions could
result in incorrect submissions and our goal is to ensure that all
instructions are as clear as possible. However, practicality and
resource constraints prohibit line-by-line justification of each
requested data element. Current RSPA/OPS forms are based on the work of
two separate data teams that extensively evaluated reporting needs,
taking into consideration the American Society of Mechanical Engineers
(ASME) cause categories contained in standard ASME B31.4. These cause
categories have already been adopted for natural gas transmission
incident and hazardous liquid accident report forms beginning in 2002,
along with the adopted stakeholder best practices. RSPA/OPS based its
submission requirements on this information and concludes that its data
requests are reasonable and cost of compliance is minimal.
Item Labeling
AGA, Con Edison, and Southwest recommend renumbering subsections to
correct sequential item identification. Various minor renumbering
suggestions were made to improve form flow. For brevity's sake, they
are not individually outlined in this summary.
RSPA/OPS response: Renumbering and reformatting suggestions are
accepted as general recommendations for proper formatting and increased
clarity.
Latitude/Longitude
AGA and APGA request definition of the phrase ``projections and
datum used in collecting this data.'' Both associations ask for clear
identification of where this information is to be entered on the form
or elimination of the phrase from the form instructions.
AGA alleged that many local distribution company operators may not
have latitude and longitude information and the information would more
likely be used by cross-country pipeline operators. AGA also noted that
while Tiger/Line Data tools were considered helpful in locating
latitude and longitude, AGA believes it is important for operators to
understand how the data would be used so they could support RSPA/OPS
data trending efforts. AGA recommends the inclusion of form
instructions that demonstrate how latitude/longitude data would be
used.
APGA tested logon time to the tiger.census.gov website (http://tiger.census.gov/cgi-bin/mapbrowse-tbl
) to determine the time required
to pinpoint the latitude and longitude of the APGA office using a
broadband internet connection. This effort required approximately ten
minutes and provided an address to seven decimals. However, the form's
space allotment does not provide enough room for numbers of this size.
APGA believes there is no known or proven geographical trend in
incidents. If no potential use for this data can be identified, APGA
urges RSPA/OPS to delete it from the form and instructions. If,
however, RSPA/OPS chooses to continue to ask for the data, it should
specify how many decimals to include
[[Page 75722]]
and provide sufficient space on the form.
Southwest stated that the additional request for latitude and
longitude requires an increase in man-hours of approximately ten to
thirty minutes using the website, depending on the location to
research. Southwest finds the website non-user friendly and states that
returned results were only marginally accurate because gas lines are
not shown on base maps. Southwest believes these fields should be
removed if they are not going to be significant in analysis.
APGA and Southwest question the value of collecting latitude/
longitude data and its application for incident analyses.
RSPA/OPS Response: We have eliminated the request for projections
and datum used in collecting latitude/longitude information. However,
RSPA/OPS requests latitude and longitude information for the specific
purpose of obtaining a location description to pinpoint the site of the
incident. Without this information, RSPA/OPS would not be able to
geographically locate most incidents.
Furthermore, RSPA/OPS is often requested by Congress to provide
maps of gas pipeline incidents, necessitating this data collection.
RSPA/OPS is also working to create risk-based tools to assist in
targeting solutions where problems occur, to identify risks in highly-
populated corridors, and to identify future risks in expected growth
corridors. Latitude and longitude information further provides macro
level information necessary to develop these risk-based tools.
RSPA/OPS is requiring latitude and longitude to be stated in
decimal degrees with a minimum of five decimal places. No projection is
required. Form instructions have been clarified to further explain how
latitude and longitude should be reported. In the event operators lack
GIS capability, latitude and longitude is readily available on the
Internet. As APGA noted, and tests by RSPA/OPS confirm, trials to
access the Tiger/Line were successful within ten minutes or less. Note,
however, that operators are not required to use the Tiger/Line site.
Many similar Internet tools are available that will facilitate
provision of latitude/longitude coordinates.
Federal Land Incident
AGA and Southwest allege that it is the responsibility of RSPA/OPS
to obtain federal land location, and not that of the operator.
Definitions for ``federal land'' provided for the incident and annual
reports are cited as inconsistent. A recommendation was made to use the
same definition in both instructions.
RSPA/OPS Response: RSPA/OPS requires Federal Land identification
for incidents that occur on federal lands to comply with 30 U.S.C. 185.
RSPA/OPS has revised the definition in the form instructions to state:
``All lands owned by the United States except lands in the National
Park System, lands held in trust for an Indian or Indian tribe, and
lands on the Outer Continental Shelf.''
Type of Leak or Rupture
AGA stated: ``[t]ype of leak or rupture asks the operator for a
puncture diameter in inches. There may be situations where the puncture
is not circular in shape. If this data is to be used to calculate areas
of the puncture opening, rectangular dimensions should also be sought
for punctures that approach a rectangular shape.''
RSPA/OPS response: It is not the intent of RSPA/OPS to restrict
measurements to circular dimensions. For the purposes of this data
collection, provide length in inches of a representational cross
section of the leak or rupture, or diameter, whichever best suits the
shape of the puncture. We further clarify this in the instructions.
Leak Reporting
APGA stated:
OPS asks operators to report the type of leak or rupture. The
instructions for this section are confusing. In the instructions OPS
includes a note to operators not to report leaks that are either
inconsequential or incidental to the operation of the pipeline and
which can be repaired under routine daily maintenance. Neither of
these types of leaks would be involved in an incident, therefore
would not be reported on the incident form under any circumstances.
The instructions would be more clear if this note would simply state
that the operator should only report information about the one leak
that the operator has determined to be the proximate cause of the
incident.
RSPA/OPS response: RSPA/OPS agrees with the comment and is
clarifying the instructions accordingly.
Pinhole Leaks
Southwest comments:
* * * RSPA/OPS has not defined what constitutes a pinhole. If
operators are left to interpret this, each operator will have its
own definition of a pinhole--that will vary from operator to
operator. This in effect will minimize the usefulness of any type of
meaningful analysis because of the various criteria used to
establish the date. Southwest suggests that RSPA/OPS define what
constitutes a pinhole.
RSPA/OPS Response: RSPA/OPS agrees with the comment concerning the
need for a definition of ``pinhole'' and will define a ``pinhole'' as
one that is hard to see with the naked eye characterized as being a
small hole made as by a pin.
Consequences--Reporting Reasons
Connecticut commented on the section of the form titled
``Consequences.'' The current report has a heading for the same type of
information, titled ``Reasons for Reporting.'' Those reasons align
directly with criteria in 49 CFR Part 191--to make clear for reporting
purposes why the Operator is reporting the incident. The proposed
change in the section heading from ``Reasons for Reporting'' to
``Consequences'' substantially alters the meaning and causes confusion
with the current report. Connecticut recommends the section heading be
retained as ``Reasons for Reporting.'' Additional recommendations
include retaining all the areas under ``Reasons for Reporting'' as in
the existing report and in alignment with Part 191 reporting criteria.
The two proposed additions, ``gas ignited'' and ``evacuation,'' are
not specific Part 191 reporting criteria and can be open to
interpretation and confusion. Connecticut asks, ``[i]f during a planned
purging operation, an operator ignited and burned off gas, would that
trigger a report, since ``gas ignited'' is now one of the
``consequences, or if 3 people were evacuated from a home by the Fire
Department because of a gas odor due to a pilot light out (non-
jurisdictional), would that trigger a Report?''
RSPA/OPS response: All the items in this revised section are not
triggers (i.e., gas ignited and evacuation) for filing a natural gas
distribution incident. The ``Consequences'' title has been adopted to
align with the gas transmission form and the hazardous liquid accident
form revisions that also adopted the revised heading for this section.
A ``reason for reporting'' is readily discernable regardless of what
the section heading is labeled. For consistency with the natural gas
transmission and hazardous liquid incident and accident forms, RSPA/OPS
therefore retains the proposed ``Consequences'' title for this section.
The ``gas ignited'' and ``evacuation'' events will not trigger a
report filing, because these revisions do not change the reporting
criteria.
Estimated Property Damage/Loss
AGA asks that cost of relighting gas services shut off due to
incidents be included in the instructions for estimated costs because
all property
[[Page 75723]]
damages related to the incident should be reported. Southwest requests
clarification if relighting costs are to be included in the total
dollars for property damage.
RSPA/OPS response: We agree and we will clarify that relighting
costs are to be included in the instructions.
Gas Ignited--Explosion or No Explosion
The current form instructions require operators to report whether
gas ignited with or without an explosion, but do not clarify at what
point in time ``explosion'' is considered to have occurred or what
constitutes a fire or explosion. AGA and Southwest suggest adoption of
definitions based on National Fire Protection Association (NFPA)
standards.
APGA states that an unconfined cloud of natural gas cannot explode
(i.e., causing a shock wave that causes damage outside the immediate
area of the gas cloud). If gas is ignited within a confined space
(e.g., within a building) it can cause the building to explode. APGA
does not understand how RSPA/OPS would treat an incident differently
depending on whether property damage was caused by fire or explosion of
a structure. Given the confusion about what is or is not an explosion,
any analysis relying on this data element is unlikely to provide
statistically significant results. APGA suggests that the term
``explosion'' not be included on the form, but instead that RSPA/OPS
ask whether the gas ignited or did not ignite. Con Edison recommends
re-labeling the field ``Gas Ignited--No Explosion'' to ``Gas Ignited''.
RSPA/OPS Response: To provide needed clarity, RSPA/OPS has
relabeled block 5d on the form to ``Gas Ignited,'' adding two checkbox
options, one appearing as ``explosion'' and the other as ``no
explosion.'' Block 5e has been relabeled as ``Gas Did Not Ignite,''
adding checkbox options ``explosion'' and ``no explosion.'' RSPA/OPS
did not propose to adopt a definition of ignition, fire, or explosion
based on NFPA standards. We will continue to rely on the common
understanding of these terms as reflected in NFPA and other documents
and standards.
Evacuation Reason
RSPA/OPS asks operators to estimate the number of persons evacuated
as a result of the incident. Commenters noted that evacuation is
sometimes performed by firemen, police, or other emergency officials,
in which case the operator may not know how many persons were
evacuated. Even when the operator requests evacuation, obtaining an
accurate count of the number of persons is not and should not be a
priority. RSPA/OPS should clarify that the operator is not expected to
expend significant time and effort to determine this number. Southwest
requests clarification of which field should be selected as the default
when the reason for evacuation or who ordered it is not known. If there
is no default field, a supplemental report will have to be sent to
RSPA, possibly contradicting the idea behind the Paperwork Reduction
Act of 1995. A similar comment stated that supplemental report filing
may contract the intent of the Paperwork Reduction Act of 1995
regarding incidents with cause of plastic pipe failure not always
determined or known at the time that the report is submitted.
RSPA/OPS Response: The operator is not expected to expend
significant time and effort to determine the numbers of people involved
during an evacuation. An indication of order of magnitude is sufficient
(1, 10, or closest hundred, thousand, etc.) Local companies should have
contact with local emergency responders and officials as part of their
standard operating procedures, and obtaining this information could be
as simple as calling officials and speaking with responders.
Filing supplemental report information is routine where additional
information not available at the time of incident becomes available.
Furthermore, RSPA/OPS was urged by the General Accounting Office and
others to seek complete incident information beyond that which is known
at initial reporting.
Incident Origin--Failure Occurred On
Con Edison recommends that another option labeled ``Saddle Tee'' be
added because it may be confusing as to whether the failure occurred on
the body of pipe, joint, component, or other.
RSPA/OPS Response: RSPA/OPS believes that the general public will
be best served by utilizing the ``Other'' option along with the form
allowance for a write-in cause. This will allow RSPA/OPS to consider
future additions based on frequency of write-in causes.
Corrosion
AGA and Southwest point out that current form fields only allow
operators to answer yes or no to the question of whether the pipe was
previously damaged in the area of corrosion. Operators would be able to
correctly indicate unknown if a field were provided or if instructions
included the caveat that a ``no'' response would be inclusive of an
``unknown'' response.
RSPA/OPS response: RSPA/OPS has added an ``Unknown'' field for this
element.
Other Outside Force Damage--Fire/Explosion as Primary Cause
AGA believes that instructions on reporting fire or explosion
occurring as a result of the pipeline failure, but not as a cause of
the failure, should read:
If a fire/explosion occurred as a result of the failure, but was
not a primary cause of the failure, do not check item 10 of this
section. Part A, items 5d and/or 5f should already be checked to
show that the fire/explosion occurred.
Southwest believes that the instructions given for completing this
section are inaccurate, and currently lead the operator to the section
referencing corrosion. If it is the intent of the form to cover the
possibility of fire and/or explosion due to corrosion, Southwest
explains that there could be other causes of failure (fatigue, stresses
due to rocks or other infrastructure), and suggests that RSPA/OPS
revisit the instructions for clarity and relevance.
Con Edison recommends that an item be added for ``Electric Wire
Down or Electric Fault in a Manhole.'' The current form instructions
appear to cover only one possibility, namely a fire and/or explosion
due to corrosion. There could be other causes of failure due to a
downed electric wire or an electric fault in a manhole, which are more
common type incidents.
RSPA/OPS response: RSPA/OPS agrees with the comments and has
revised the instructions.
Test Medium
RSPA/OPS requires operators to specify the test medium used to
establish the Maximum Allowable Operating Pressure (MAOP) and provides
check boxes for ``water,'' ``natural gas,'' ``inert gas,'' and
``other.'' If RSPA/OPS elects to include this data element in the final
revised form, APGA recommends that ``air'' be included as one of the
options since the vast majority of distribution piping is tested with
air prior to being placed into service. APGA questions whether
knowledge of the test medium is necessary for any analysis.
RSPA/OPS Response: RSPA/OPS agrees that information on the test
medium is not necessary for analysis. We have eliminated this data
element.
Equipment or Operations
RSPA/OPS offers the cause option, ``Ruptured or leaking seals/pump
packing.'' APGA finds this confusing as pumps are not a common
component on gas distribution systems. The
[[Page 75724]]
association also questions whether this refers to pumps only, or if
seal or packing leaks on valves, couplings, regulators, meters and
other equipment should be included. Unless RSPA/OPS requires that the
cause categories be identical across all three incident forms (liquid,
gas transmission, and distribution), the field should be deleted. If
the pump identification is retained on the form, RSPA/OPS should
recognize that confusion about its proper application may make it more
difficult to draw statistically significant conclusions about causes of
equipment and operations failures.
Con Edison believes this section refers more appropriately to
hazardous liquid operations, especially ``pump packing.'' They
recommend changing this item to address more common equipment failures,
such as ``Mechanical Device Not Installed Properly.'' There are many
mechanical connectors being used on plastic pipe systems that may not
be properly installed, and could lead to an incident. There should be a
provision for this. Although there is a box to check off for ``Poor
Workmanship,'' there appears to be no follow-up to this category when a
mechanical device is involved.
RSPA/OPS Response: RSPA/OPS recognizes that pump packing is not a
common element in the natural gas distribution pipeline industry.
Therefore, we change this cause category from ``Ruptured or leaking
seals/pump packing'' to ``Leaking Seals.''
Annual Report Form RSPA F 7100.1-1
Federal Land Incident
With regard to leaks reported on annual reports, AGA asks RSPA/OPS
to clarify the exclusion that ``Federal Buildings such as Federal court
houses and warehouses are not to be reported in the incident on Federal
lands.'' Southwest asks whether the exclusion also applies to leaks
reported on the annual report.
RSPA/OPS Response: RSPA/OPS has corrected the definition in the
form instructions to state: ``All lands owned by the United States
except lands in the National Park System, lands held in trust for an
Indian or Indian tribe, and lands on the Outer Continental Shelf.'' We
have eliminated the exclusion of federal buildings because determining
whether buildings were federally owned would be an unnecessary burden
on pipeline operators and would serve no analytical purpose.
Miles of Main and Numbers of Services by Decade of Installation
RSPA/OPS asks operators to submit data on the decade of
installation of mains and services. AGA and APGA state that this
information may not be readily available to operators, and ask RSPA/OPS
to clarify that operators are not required to undertake a massive
records search to develop the data. APGA offers that operators should
be able to list mains and services as ``unknown'' if the data is not
readily available.
APGA notes that RSPA/OPS recently began collecting this data from
gas transmission and hazardous liquid operators. Transmission and
liquid operators are more likely to have the information readily
available because these pipelines tend to be constructed in major
projects in a particular decade. Distribution mains and services are
installed in smaller increments. Every day an operator may be
installing new mains and services, retiring mains and services, and
replacing small sections of its piping network. Depending on the record
keeping systems, developing the requested installation-by-decade data
could require significant time and effort.
Southwest believes that the new requirement will require an
increase in the number of hours required to collect distribution data--
approximately a day or two longer than is required to complete the
current distribution annual report.
Atmos questions the value of such information. Until the value of
the data is better justified, Atmos prefers that the proposed changes
not be made.
RSPA/OPS Response: The lack of information about overall age of the
national pipeline infrastructure has been a major data gap identified
by RSPA/OPS, the National Transportation Safety Board, the Department
of Transportation Office of the Inspector General, the General
Accounting Office, and others. RSPA/OPS also emphasizes that operators
are not required to undertake a massive records search to develop the
data if it is not readily available. RSPA/OPS seeks best estimates only
and does not expect operators to conduct costly manual searches.
However, we believe that information on most lines should be available.
RSPA/OPS believes the value of the data will increase over time and its
accuracy will improve. In the long term, mileage by decade will be of
significant value.
Average Length of Service Line
Mr. Erikson reports that the use of the RSPA/OPS Annual Report data
for analyses is necessary in his safety consultancy, and therefore
accuracy and usability of the data is of high interest. Mr. Erikson
recommends that RSPA/OPS cease asking for average length of service
line. Few, if any, operators know this length, and nearly one-sixth of
operators reported an average length of zero feet. Experience with
operators points to the fact that numbers reported are often a guess,
rendering the information unreliable.
RSPA/OPS Response: The estimated average length of service line
data element is the sole source for mileage of services nationally.
RSPA/OPS uses this information to survey per decade changes in the
overall environment. We also use the information to characterize the
overall infrastructure. Therefore, this data element will be retained.
Leak Cause
RSPA/OPS proposes to revise the categories for leaks eliminated
and/or repaired during the year. However, APGA asks that RSPA/OPS
recognize that many operators collect leak repair data using forms and
procedures provided to the field crews. Many operators use computer
software to store this data. These forms, procedures, and software will
have to be modified to reflect the new categories and the new
procedures must be explained to field personnel. APGA urges RSPA/OPS to
provide adequate lead-time to allow operators to modify their forms,
procedures, and software to start tracking new categories. A minimum of
six months between the date that RSPA/OPS promulgates changes to leak
categories and the start of the year for which new annual reports will
be used to collect leak repair data is deemed reasonable.
RSPA/OPS Response: RSPA/OPS acknowledges that time is needed to
revise systems to tabulate the new information on the revised annual
report form. Accordingly, we will request the information annually
beginning March 15, 2005 for calendar year 2004.
Altering Leak Cause Categories
CPUC provided RSPA/OPS with an extensively revised instruction
guide and proposed form for annual report completion to ensure leakage
data that would be useful for Colorado regulatory analysis purposes.
The proposed form is a tool that alters past definitions used to
classify ``leaks'' into different ``Leak Cause'' categories. CPUC's
recommended instructions are provided with the intent to provide
clarity and correlation with past leak cause data collection efforts.
Because in-depth
[[Page 75725]]
failure investigations are conducted for each ``incident'' as defined
under 49 CFR 191.3 during the 30-day incident reporting period, a
failure investigation into the cause of a leak under normal gas
distribution system operating conditions is usually determined by the
operator's field technician. Therefore, instructions should help
clarify which leak category the field technician must focus on for the
purposes of the annual report.
CPUC suggests that the data collection and reporting using the
proposed form should coincide with a full calendar year of leak repair
data to ensure meaningful data reporting and analysis. Partial calendar
year or ``Unknown'' data classification will result in inconsistent
data collection and questionable conclusions.
RSPA/OPS Response: The data collection for the natural gas
distribution annual report has historically been, and will remain, per
calendar year for the preceding calendar year. As stated above, we
request the revised forms to be filed annually beginning March 15,
2005, for calendar year 2004.
Combining Categories
Southwest questions combining equipment leaks and operation leaks
into one category. As explained in the instructions for the annual
report, equipment leaks are leaks resulting from malfunctioning valves,
regulators, couplings, etc. Operation leaks are leaks resulting from
inadequate procedures or safety practices, failure to follow correct
procedures, or other operator errors. These categories are distinct and
justify separation into their own category. Southwest believes that
separating these into distinct categories will better enable RSPA/OPS
to perform a proper analysis of the data.
RSPA/OPS Response: RSPA/OPS agrees that the categories are distinct
and justify separation into their own category. Accordingly, the form
and instructions are changed to separate Equipment leaks and Operation
leaks.
Abstract of Proposed Information Collection and Request for Comments
The forms to be revised are two of the four gas pipeline reporting
forms authorized by Information Collection OMB 2137-0522, Incident and
Annual Reports for Gas Pipeline Operators. The proposed revisions
represent the final phase of an ongoing process to revise all incident
and annual reports. RSPA/OPS revised the natural gas transmission
operator annual report forms in 2001 for collection beginning in 2002.
Title of Information Collection: Incident and Annual Reports for
Gas Pipeline Operators--Revision of Natural Gas Distribution Incident
Report (RSPA F 7100.1) and the Annual Report Form for Gas Distribution
Systems (RSPA F 7100.1-1)
OMB Number: 2137-0522.
Respondents: Natural Gas Distribution Pipeline Operators.
Estimated Number of Respondents: 1,200.
Estimated Total Annual Burden on Respondents: 30,240 hours.
Comments are invited on:
(a) The need for the proposed collection of information for the
proper performance of the functions of the agency, including whether
the information will have practical utility;
(b) the accuracy of the agency's estimate of the burden of the
proposed collection of information, including the validity of the
methodology and assumptions used;
(c) ways to enhance the quality, utility, and clarity of the
information to be collected; and
(d) ways to minimize the burden of the collection of information on
those who are to respond, including the use of appropriate automated,
electronic, mechanical, or other technological collection techniques.
Issued in Washington, DC, on December 24, 2003.
Stacey L. Gerard,
Associate Administrator for Pipeline Safety.
[FR Doc. 03-32201 Filed 12-30-03; 8:45 am]
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