2137-0598 Supporting.Statement

Pipeline Safety: Incorporation by Reference of

Industry Standard on Leak Detection

Justification: 2137-0598

1. Circumstances that make collection of information necessary:

Sections 195.134 and 195.444 of the Federal pipeline safety regulations require operators of hazardous liquid pipeline facilities installing new computational pipeline monitoring (CPM) leak detection systems or replacing components of existing CPM systems to comply with section 4.2 of the American Petroleum Institute's recommended practice API 1130 "Computational Pipeline Monitoring for Liquid Pipelines" (API 1130). API 1130 section 4.2 provides information collection and maintenance guidance on many factors such as measurement capabilities, communications reliability, pipeline operating condition, and product type. PHMSA reviews the information during pipeline inspection. The information supports the pipeline inspection and improves pipeline safety by providing early detection of a pipeline leak. A copy of API 1130 is available in the docket. The existing authorization to collect the information was expiring on June 30, 2007. An emergency extension was requested and approved by OMB until September 30, 2007. This is a request for renewal without change.

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

The information will be used by operators, PHMSA and State agencies to ensure the integrity of computational pipeline monitoring systems. Computational Pipeline Monitoring (CPM) systems use an algorithmic approach to detect hydraulic anomalies in pipeline operating parameters. PHMSA does not require these systems. However, if theses systems are used , the operators must maintain system records in accordance with the specified requirements.

3. Extent of automated information collection:

By nature these systems are fully automated.

4. Efforts to identify duplication:

There is no duplication, as the recordkeeping is not required by any other source. Each operator system is unique and information derived from one may not be inferred to another.

5. Methods used to minimize burden on small businesses or other small entities:

The use of these systems is at the discretion of the operator. PHMSA expects impacted operators to be large rather than small businesses because of the infrastructure and requirements to deploy such a system. PHMSA knows of no small entity that currently has or plans to acquire a CPM. Additionally record keeping is required only when a new test is done. This is once every five years.

6. Consequences to Federal program or policy activities if collection were conducted less frequently.

PHMSA would be unable to appropriately and properly assess the effectiveness of the CPM system. The system provides alarms and displays other related data to the pipeline operator to aid in decision-making. Without recordkeeping and system calibration, the reliability of they CPM system could not be established. Less frequent information collection could compromise the safety and economic viability of the U.S. pipeline system.

7. Special circumstances affecting conduct of information collection activity:

Not applicable.

8. Efforts to consult with persons outside the agency to obtain their views:

A notice and request for comments was published in the Federal Register on May 29, 2007 under Docket No. PHMSA-98-4957 (72 FR 29578) inviting public comment on the renewal of this information collection. The comment period closed on July 16, 2007. No comments were received for this information collection.

A notice and request for comments was published in the Federal Register on July 17, 2007 under Docket No. PHMSA-98-4957 (72 FR 39135) inviting public comment on the renewal of this information collection. The comment period closed on Aug 16, 2007. No comments were received for this information collection.

9. Explanation of decision to provide any payment or gift to respondents:

Not applicable.

10. Assurance of confidentiality provided to respondents:

Not applicable.

11. Justification for collection of sensitive information:

Not applicable.

12. Estimate of burden hours for information requested:

Number of Respondents:

50, which is the number of pipeline operators currently using computational Pipeline Monitoring Systems.

Number of Responses:

50. Each operator maintains one system of records.

Number of Annual Burden Hours:

100. The number of annual burden hours was calculated as follows:

PHMSA estimates that there are 50 operators in the U.S. using CPM systems. It takes approximately 2 hours of an engineers time to record and prepare the test results for an industry total of 100 hours (50 x 2 hours = 100 hours).

13. Estimate of total annual costs to respondents:

An engineering manager is estimated to perform the update at an average pay rate of $64.75 per hour.¹

The total cost for the recordkeeping is estimated to be 6,475.00

14. Estimate of cost to the Federal government:

PHMSA will be reviewing the information in the course of facility inspections. The additional time necessary to review the records will be minimal.

15. Explanation of program changes or adjustments:

Operators incurred significant time in collecting initial mapping information. This renewal requires operators to update annually the nation's pipeline transportation systems. Pipeline's transportation system remains static on an annual basis.

16. Plans for tabulation, statistical analysis and publication:

PHMSA does not have plans to collect or display this information. The recordkeeping supports individual systems.

17. Display of expiration date of OMB Approval:

Approved OMB number is displayed in 49 CFR 195.

18. Exceptions to certification statement:

There are no exceptions to the certification statement.

1 Based on the 2004 U.S. Department of Labor’s Bureau of Labor Statistics National Industry-Specific Occupational Employment and Wage Estimates. The median hourly wage of an engineering manager (for NAICS 486000 – pipeline transportation) is estimated to be $47.96. With an estimated fringe benefit of 35%, the fully loaded cost of an engineering manager in the pipeline industry is $64.75 per hour.