Notice2023-07491
Pipeline Safety: Information Collection Activities: Voluntary Adoption of API RP 1173 for Gas Distribution Systems
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
April 11, 2023
Issuing agencies
Transportation Department
Abstract
In compliance with the Paperwork Reduction Act of 1995, this notice announces that the information collection request abstracted below is being forwarded to the Office of Management and Budget (OMB) for review and comment. A Federal Register notice with a 60-day comment period soliciting comments on the information collections was published on September 6, 2022.
Full Text
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<title>Federal Register, Volume 88 Issue 69 (Tuesday, April 11, 2023)</title>
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[Federal Register Volume 88, Number 69 (Tuesday, April 11, 2023)]
[Notices]
[Pages 21742-21746]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2023-07491]
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DEPARTMENT OF TRANSPORTATION
[Docket No: PHMSA-2022-0060]
Pipeline Safety: Information Collection Activities: Voluntary
Adoption of API RP 1173 for Gas Distribution Systems
AGENCY: Pipeline and Hazardous Materials Safety Administration (PHMSA),
DOT.
ACTION: Notice and request for comments.
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SUMMARY: In compliance with the Paperwork Reduction Act of 1995, this
notice announces that the information collection request abstracted
below is being forwarded to the Office of Management and Budget (OMB)
for review and comment. A Federal Register notice with a 60-day comment
period soliciting comments on the information collections was published
on September 6, 2022.
DATES: Interested persons are invited to submit comments on or before
May 11, 2023.
ADDRESSES: The public is invited to submit comments regarding these
information collection requests, including suggestions for reducing the
burden, to Office of Management and Budget, Attention: Desk Officer for
the Office of the Secretary of Transportation, 725 17th Street NW,
Washington, DC 20503. Comments can also be submitted electronically at
<a href="http://www.reginfo.gov/public/do/PRAMain">www.reginfo.gov/public/do/PRAMain</a>.
FOR FURTHER INFORMATION CONTACT: Angela Hill by telephone at 202-680-
2034 or by email at <a href="/cdn-cgi/l/email-protection#5839363f3d34397630313434183c372c763f372e"><span class="__cf_email__" data-cfemail="8cede2ebe9e0eda2e4e5e0e0cce8e3f8a2ebe3fa">[email protected]</span></a>.
SUPPLEMENTARY INFORMATION:
I. Background
Title 5, Code of Federal Regulations (CFR) section 1320.8(d),
requires the Pipeline and Hazardous Materials Safety Administration
(PHMSA) to provide interested members of the public and affected
agencies the opportunity to comment on information collection and
recordkeeping requests before they are submitted to OMB for approval.
In accordance with this regulation, on September 6, 2022, PHMSA
published a Federal Register notice (87 FR 54590) with a 60-day comment
period soliciting comments on its intent to request OMB's approval of a
one-time information collection titled: ``Voluntary Adoption of API RP
1173 for Gas Distribution Systems.'' The proposed information
collection would provide the data necessary to prepare the report
required by section 205 of the Protecting Our Infrastructure of
Pipelines and Enhancing Safety (PIPES) Act of 2020 for gas distribution
systems.
During the 60-day comment period, PHMSA received comments from the
Pipeline Safety Management Systems (PSMS) Industry Team, Atmos Energy
Corporation (Atmos Energy), American Gas Association (AGA),
Distribution Contractors Association (DCA), Natural Gas SMS
Collaborative, NiSource Inc., MDU Utilities Group (MDUG), American
Public Gas Association (APGA), Southwest Gas Corporation, and CMS
Energy Corporation, a parent holding company of Consumers Energy
Company. Commenters were overall supportive of the intent of section
205. Note AGA, DCA and APGA are also members of the PSMS Industry Team.
Similarly, the operator companies may be members of one or more of the
other entities commenting. In addition to agreeing with comments of the
PSMS Industry Team, AGA, DCA and APGA and some operators provided
additional comments unique to their respective associations. Where AGA,
DCA, APGA, or operator comments were in-line with the PSMS Industry
Team, only the PSMS team comment is discussed. If AGA, DCA, APGA, or
individual operator companies included unique comments in their
separate responses, they are noted accordingly. Overall, PHMSA largely
incorporated the PSMS Industry Team's comments. The comments and
PHMSA's responses, organized by topic, are summarized and addressed
below.
II. Comment Summary
A summary of comments and PHMSA responses are detailed below.
A. Estimated Burden and Cost Related Questions
Comment: The PSMS Industry Team stated that the information
collection as written in the 60-day notice was overly complicated,
burdensome, and confusing. The PSMS Industry Team stated the burden
required to complete the questionnaire as drafted would be extensive,
far exceeding the one-hour allocation outlined in the PHMSA 60-day
notice. The PSMS Industry Team recommended that PHMSA utilize the
existing annual survey already in place and facilitated by the PSMS
Industry Team rather than creating new or disparate collection efforts.
The PSMS Industry Team did not give specific estimates in the docket
comments of burden hours to complete the draft form proposed in the 60-
day notice or modified version but specified that its recommendations
would meet the intent of section 205 while reducing the burden on
industry. PHMSA reached out to the PSMS Industry Team by email for
further input on burden estimates. In response, the PSMS Industry Team
specified that the PHMSA proposal as written in the 60-day notice could
take about 2-4 hours per SMS program element as it would require
individual operator employees to coordinate with other departments or
groups in the organization to determine work burdens, staff hours
worked or monetary costs. Based on their estimate of 2-4 hours per
element, the estimated burden for PHMSA's proposed GD-SMS-2022 Form in
the 60-day notice would be 26,280-52,560 hours (2-4 hours per element x
10 elements x 1,314 responses). In contrast, the PSMS Industry Team
specified that a version that aligns more with their survey and removes
the detailed cost and labor hour questions could be more on the order
of 3 hours to complete with the rationale that an individual could
answer most of the questions without coordination or discussion with
other internal work groups on cost or hours by SMS Program Element.
Based on this estimate, the PSMS Industry Team's survey would result in
an estimated burden of about 3,942 hours (1,314 responses x 3 hours).
For costs, the PSMS Industry Team stated that the proposed GD-SMS-
2022 Form in the 60-day notice requests implementation percentages,
costs, and manpower hours for each Program Element in RP 1173 instead
of assessing steps in the SMS implementation journey as outlined in the
Pipeline SMS Maturity Model. The PSMS Industry Team recommended that
the questionnaire solicit information on the number of distribution
operators who have made leadership commitments, conducted a gap
analysis, identified gaps or improvement opportunities, prioritized gap
closures, actively participated in external sharing events, developed a
management review process and conducted a review, assessed safety
culture, and evaluated SMS maturity. The PSMS Industry Team specified
that each of these actions are steps in the implementation journey,
increasing an operator's SMS maturity from basic RP 1173 conformance to
system effectiveness. The PSMS Industry Team's Annual Survey asks
operators to detail their level of participation in these discrete
steps and has tracked responses since 2017. The PSMS Industry Team
stated that PHMSA's draft form in the 60-day notice only sought to
quantify the costs or hours to implement these elements, ignoring the
more complex questions of implementation progress, effectiveness, and
maturity. Further, the PSMS Industry Team stated that PHMSA's
[[Page 21743]]
draft form does not recognize that for many operators that have
implemented RP 1173, parsing out these implementation costs and effort
hours specific to this standard is not realistic. The PSMS Industry
Team indicated that as Pipeline SMS implementation is embedded in every
aspect of daily operations, attributing specific cost figures to
individual program elements is infeasible, impractical, and should be
removed.
Atmos Energy stated that Questions 8b and 8c suggest that Pipeline
SMS is ``implemented'' at a certain point in time and has a definite,
discernible dollar amount that can be quantified and amassed for that
implementation. Atmos Energy further stated that even if the data could
be accurately captured, it would not provide a meaningful company
comparison for PHMSA. Atmos Energy noted that the amount of time and
costs that a company has expended and is still expending on instituting
and continuing to develop PSMS would be dependent on the results of a
gap analysis against the company's existing safety culture, the size
and complexity of the organization, and time and pace at which the
organization began its Pipeline SMS journey. Atmos Energy also stated
that the questions and instructions do not provide guidance as to what
factors or components should be included or excluded in these
calculations, which would leave that determination up to the individual
operator, only further precluding the gathering of usable comparative
data. In summary, Atmos Energy stated that tracking and reporting
quantifiable implementation efforts and costs do not align with the
continuous improvement and ongoing development tenants of Pipeline SMS
nor do they accurately reflect a company's safety culture or
priorities.
AGA stated that identifying implementation costs and hours specific
to each element is not realistic for many large, multi[hyphen]state
operators. Like the PSMS Industry Team's comments, AGA recommended
capturing data outlined in the Pipeline SMS Maturity Model. Like Atmos
Energy's comment, AGA specified concern regarding whether the
information being requested in Questions 8 and 9 could be accurately
captured, and whether it would provide a meaningful operator
comparison. AGA stated that the proposed form failed to define
``implementation'' and asking operators to disclose when elements were
``fully implemented'' or ``complete'' does not reflect the guiding
principles of SMS implementation or continuous improvement.
The Natural Gas SMS Collaborative stated that direct cost figures
do not effectively represent the efforts an operator may have put forth
in support of safety management implementation and recommended PHMSA
consider utilizing measures of maturity to effectively represent the
operators' level of commitment and investment in Pipeline SMS.
NiSource commented that an effective management system serves as
the foundation of an operating model and NiSource experiences a
distribution of costs across operations that may be prioritized based
on their SMS Processes and Procedures. NiSource noted that these costs
are spread and shared across the organization. NiSource provided some
specific recommendations as alternatives if PHMSA chose not to adopt
industry comment recommendations through the PSMS Industry Team and the
Natural Gas SMS Collaborative, but otherwise supported the comments and
alternatives proposed by those entities.
MDUG, which consisted of at least four Operator Identification
Numbers (OpIDs) and over 1 million customers served at the time of the
60-day notice comment submittal, stated that it would not be able to
accurately assess either the number of staff hours or the
implementation costs by element. MDUG proposed removing question 8b
(associated with staff hours) in the 60-day version and proposed the
following in place of 8c (associated with costs): ``Prior to the
decision to implement API RP 1173, did your organization do a cost
analysis of the impact of internal or external resources?''
PHMSA Response: PHMSA would like to thank all the entities for
taking the time to submit comments. Regarding concerns with burden and
cost, PHMSA has largely accepted the alternatives proposed by the
commenters. For example, implementing an SMS program based on API RP
1173 requires the operator to maintain procedures for Management of
Change (MOC) to be applied to significant technology, equipment,
procedural, and organizational changes. Section 204 of the PIPES Act
directs PHMSA to update regulations to ensure that gas distribution
operators include a detailed MOC process in their procedural manual for
operations, maintenance, and emergencies. The regulation update will
have to also address emergency response plans and record keeping
requirements which are two of elements of API RP 1173. However, after
considering the comments, PHMSA agrees that the alternatives proposed
that align more closely with the industry's annual survey would still
provide the information needed to complete the section 205 Report to
Congress.
Regarding the PSMS Industry Team's recommendation that PHMSA
utilize the existing annual survey facilitated by the Pipeline SMS
team, PHMSA believes that it must proceed with the information
collection to better support the preparation of the report required by
section 205. However, industry is welcome to provide data from industry
developed surveys.
Given that PHMSA has revised the questions to closely align with
the PSMS Industry Team recommendations, PHMSA has adjusted the
estimated annual burden hours to reflect the input provided by the PSMS
Industry Team.
PHMSA appreciates NiSource's and the Natural Gas Collective's
suggestions for alternate questions if PHMSA chose not to adopt certain
industry recommendations submitted in their comments. Since PHMSA
largely incorporated the PSMS Industry Team recommendations, PHMSA did
not incorporate the alternatives provided by NiSource. As part of the
PSMS Industry Team comments and alternative questions that PHMSA
incorporates, there is a question that touches on SMS maturity level.
More specifically, question 16 in the 30-day Notice asks, ``Are you
maintaining a method to evaluate PSMS maturity?'' In its comments,
NiSource raised some interesting nuances that need to be considered for
larger and complex operators just as APGA raised some interesting
nuances for very small operators described later in this notice. PHMSA
believes, by incorporating the alternative questions in the form, the
necessary information can be collected from distribution operators of
all sizes.
PHMSA accommodated MDUG's suggestion to remove question 8b
associated with staff hours by incorporating the PSMS Industry Team's
suggested questions. PHMSA also accommodated MDUG's concern with
question 8c associated with costs by incorporating the PSMS Industry
Team's suggested questions. More specifically, the new question 8 asks
``Have you performed a gap assessment or other comparable exercise to
compare your pipeline safety and safety culture efforts to the concepts
of safety management systems described in API RP 1173?'' The follow-up
question 9 asks about barriers preventing an operator from implementing
an SMS program. Among the options for barriers/challenges is financial
considerations.
[[Page 21744]]
B. Suggestions To Enhance the Quality, Utility, and Clarity of the
Collected Information
PHMSA also received comments that made general suggestions to
enhance the overall quality and clarity of the collection information.
Some aspects are included in the comments above with others described
below.
1. Refine Questions To Better Track Progress and Feasibility in
Alignment With RP 1173 Principles
Comments: The PSMS Industry Team and other commenters noted
confusion with some of the terms used such as question 8 asking about
element implementation and question 9 asking in what year the SMS
program was fully implemented with elements selected in 8a. Commenters
suggested that either PHMSA include the agency's definition of terms
``fully implemented'' and ``initiated'' to support more accurate
response or adjust questions in a way to ask operators if they have
completed steps along the implementation journey, as reflected in the
PSMS team survey, or their perceived maturity towards the PSMS Maturity
Model.
PHMSA Response: PHMSA would like to thank the commenters and SMS is
a continuous improvement journey. The concept of an element being
initiated was to indicate when it started in the Plan-Do-Check-Act
(PDCA) cycle for a given operator. Fully implemented was meant to
indicate when it at least made it through one PDCA cycle. However,
PHMSA agrees fully implemented can still be confusing. PHMSA has
modified the form to align with the questions recommended by the PSMS
Industry Team.
2. Feasibility of the Form and API RP 1173 for Very Small Operators
Comment: APGA discussed the feasibility of API 1173 and Safety
Management Systems in general for very small operators. APGA proposed a
very small operator be defined as a pipeline operator that:
(a) Serves less than 20,000 natural gas distribution customers: and
(b) Has total deliveries less than 10 billion cubic feet (BCF)
annually.
APGA commented that the principles of API RP 1173 are applicable to
pipeline operators of all sizes. However, APGA stated that implementing
all the prescriptive requirements and practices, as currently written,
is not feasible for very small operators.
For more context, APGA noted the following: A natural gas utility
serving around 20,000 services typically employs less than 50
individuals, including employees who offer customer support for
billing, office administrators, accountants, human resources managers,
supervisors, and field personnel. Ultimately a utility of this size
will only have approximately 10 to 15 individuals working on or near
the pipelines. There are 970 natural gas operators that operate less
than 20,000 services, almost all of which are publicly owned natural
gas systems. These natural gas distribution operators are committed to
incorporating safety management system principles into their daily
operations but believe the requirements and recommendations of API RP
1173 PSMS were not written in a truly scalable way for operators of
their size.
APGA further commented that in the Annual Industry PSMS Survey, all
pipeline operators are asked what barriers are in place that are
preventing their voluntary adoption of API RP 1173. APGA stated that
staffing, manpower, resources, and time are the leading reasons
provided by those not yet implementing API RP 1173, such as those that
would meet the ``very small operator'' designation. APGA commented that
some operators also express frustration in understanding the
justification for their implementation of API RP 1173. APGA noted that
these public gas systems serve relatively few customers and operate
minimal pipeline mileage. APGA stated that often their systems are
newer, fully constructed of plastic pipe, and have relatively few
leaks. APGA further stated that for them, the justification for
developing a full PSMS program per API RP 1173 seems both unrealistic
and unnecessary to further the safety of their system.
APGA also noted that it has tools to assist small operators in
understanding, adopting, and implementing pipeline safety management
practices which are explained further in their comments posted in the
docket. APGA stated that translating the intent of API RP 1173 in a
manner that is relatable and actionable for ``very small operators'' is
important for voluntary adoption of safety management systems
principles. APGA noted their support of the PSMS Industry Team.
APGA did not comment specifically on changes to the form that can
best accommodate very small operators other than agreeing with the PSMS
Industry Team comments on realigning the questions in a way that focus
first on the principles of SMS in general before jumping into whether
operators are aware of and specifically following elements of API RP
1173.
PHMSA Response: PHMSA thanks APGA for the comments and has decided
to realign the questions in line with PSMS Industry Team comments. As
PHMSA noted in the 60-day notice, while the act mandate pointed
specifically to API RP 1173, there are other variations available and
implemented, including a customized SMS.
3. Operator Name vs. Operator ID
Comment: Atmos Energy commented that Question 1 directs operators
to respond separately for each OpID on record. Atmos Energy stated that
large multistate operators would have to file multiple submissions from
different operator IDs assigned for distribution and transmission
facilities and would further result in repetitive responses for PHMSA
to review. Atmos Energy noted that they have eleven OpIDs, which would
require the completion of eleven forms, with much of the information
across those forms being repetitive. Atmos Energy requested that this
question be limited to operator name as opposed to operator
identification.
PHMSA Response: PHMSA thanks Atmos Energy for the comment. While
PHMSA acknowledges some operators have multiple OpIDs, limiting to just
an operator name would cause challenges for data collection and data
accuracy. For instance, it may not always be clear that an operator
submission covers all OpIDs associated with that operator. Also, if
there are any variations across OpIDs in any of the questions, PHMSA is
interested in identifying and learning about those differences to
inform our report to Congress. For example, number of customers served
will likely be different for each OpID. Therefore, PHMSA is still
requesting a separate report for each OpID.
4. Feasibility of Implementation
Comment: Atmos Energy commented that question 13 in the 60-day
version of the form appeared to ask companies to provide a
justification for their decision not to implement PSMS. Question 13
specifically asked ``If you do not plan on implementing an SMS program,
what are the primary reasons for not implementing?'' Atmos Energy noted
its commitment to the implementation of PSMS, while specifying that
they recognize that PSMS, through RP 1173, is intended to serve as
guidance for operators and its adoption is voluntary. Atmos Energy also
noted if the intent of the question is aimed at determining what
components may presently act as potential obstacles to an
organization's voluntary adoption of PSMS, Atmos Energy requests that
PHMSA clarify that intent in the question.
[[Page 21745]]
MDUG proposed removing question 10 completely. Question 10 asked
``If you have not implemented an SMS program, (a) are you currently in
the process of implementing one and (b) how much progress have you made
with implementing the 10 or more (if applicable) elements of the
program?'' with a yes and no answer, a percentage of implementing by
element. MDUG suggested adding an additional question after 15: ``If
you have used the API maturity scale to assess your SMS program, what
is your overall score (on a scale of 1-5)?''
PHMSA Response: The original purpose of the question was to help
provide input on the number of companies implementing a pipeline SMS
and the feasibility of an operator of a natural gas distribution
company to implement a pipeline SMS in line with the PIPES Act 2020
section 205 language. PHMSA modified this question to align with the
PSMS Industry Team recommendation. The question now asks ``What
barriers are preventing you from implementing an SMS program per API RP
1173 or other SMS? (Select all that apply).'' The question now appears
as question 9 in the 30-day notice version.
It should be noted that PHMSA added an NA (not applicable) option
to the Industry Team recommended version to indicate if an operator is
in the process of implementing SMS as part of the response to the new
question 9. The Industry Team's recommended version of question 8
``Have you performed a gap assessment or other comparable exercise to
compare your pipeline safety and safety culture efforts to the concepts
of safety management systems described in API RP 1173?'' suggested to
skip question 9 if the answer was yes. However, PHMSA believes question
9 would collect data on whether an operator performed an initial gap
assessment. PHMSA added some language in the instructions to make the
intent clearer.
PHMSA believes it accommodated MDUG's request to remove question 10
by incorporating the PSMS Industry Team's version of the questions.
PHMSA did not specifically add MDUG's suggested question on maturity
level score but did include a question on whether a submitter is
maintaining a method to evaluate PSMS maturity in line with the PSMS
Industry Team's version of the questions.
5. Comments Related to Damage Prevention and the Potential of
Geographic Information Systems (GIS) Mapping
Comment: The Distribution Contractors Association (DCA) noted that
PHMSA solicited comments on ``additional information that would be
appropriate to collect to inform the reduction in risk to people,
property, and the environment due to excavation damages.'' DCA
commented that accurate mapping of underground utility pipelines has
become a challenging and difficult task, and rather than restricting a
user to limited features on a static map, GIS mapping allows for
viewing customizable combinations of data layers in a single dynamic
tool. DCA specified that underground facility damage prevention
practices are more critical than ever particularly in light of the 2021
Infrastructure Investment and Jobs Act and notes that encouraging the
use of readily available GIS mapping technologies is clearly an
effective way to ensure for the accurate locating of underground
facilities. DCA commented that as a part of PHMSA's information
collection effort, gathering as much information as possible regarding
the current use of GIS mapping by pipeline operators would be
appropriate when considering ways to reduce risks associated with
excavation activities.
PHMSA Response: PHMSA would like to thank the DCA for being a
member of the PSMS Industry Team and providing comments on the
importance of accurate mapping, the use of GIS, and in general
following underground facility damage prevention laws and best
practices. While PHMSA agrees with DCA's comments and is engaged in
initiatives for damage prevention through prevention through
organizations such as the Common Ground Alliance. That portion of the
60-day information collection request was partly a carryover of
language from other information collection efforts and has been removed
from this 30-day notice to avoid confusion. PHMSA still encourages all
operators and contractors to follow damage prevention laws and best
practices. As it relates to API 1173, PHMSA also commends API for
developing contractor guidance as a complement to API RP 1173. For more
information, see <a href="https://pipelinesms.org/contractor-guidance/">https://pipelinesms.org/contractor-guidance/</a>. If there
are any aspects of GIS mapping or contractor engagement in general that
could be useful to convey in the process of this information
collection, operators are welcome to include those aspects.
III. Summary of Impacted Collections
Section 1320.8(d), title 5, Code of Federal Regulations, requires
PHMSA to provide interested members of the public and affected entities
an opportunity to comment on information collection and recordkeeping
requests. This notice identifies a one-time information collection that
PHMSA will submit to OMB for approval.
The following information is provided for this information
collection: (1) Title of the information collection; (2) OMB control
number; (3) Current expiration date; (4) Type of request; (5) Abstract
of the information collection activity; (6) Description of affected
public; (7) Estimate of total annual reporting and recordkeeping
burden; and (8) Frequency of collection. PHMSA requests comments on the
following information:
Title: Voluntary Adoption of API RP 1173 for Gas Distribution
Systems.
OMB Control Number: Will request from OMB.
Current Expiration Date: TBD.
Type of Request: Approval of an information collection.
Abstract: This information collection request covers the collection
of data from operators of natural gas distribution pipeline systems to
ascertain how many gas distribution operators are voluntarily
implementing API RP 1173, progress being made for those that have
implemented or are implementing a pipeline SMS, and feasibility to
implement a pipeline SMS based on size of the operator. PHMSA proposes
collecting this information via the proposed GD-SMS-2022 form. PHMSA
estimates that it will take each respondent approximately 3 hours to
complete the proposed form.
Affected Public: Natural gas distribution pipeline operators.
Annual Burden:
Estimated number of responses: 1,314.
Estimated annual burden hours: 3,942.
Frequency of Collection: Once.
Comments are invited on:
(a) The need for this information collections 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
[[Page 21746]]
who are to respond, including the use of appropriate automated,
electronic, mechanical, or other technological collection techniques.
Authority: The Paperwork Reduction Act of 1995; 44 U.S.C. chapter
35, as amended, and 49 CFR 1.48.
Issued in Washington, DC, on April 5, 2023, under authority
delegated in 49 CFR 1.97.
Alan K. Mayberry,
Associate Administrator for Pipeline Safety.
[FR Doc. 2023-07491 Filed 4-10-23; 8:45 am]
BILLING CODE 4910-60-P
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