2137-0635 GTGGUNGS Instuctions for Intentional Gas Releases Supporting Statement

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE CHIEF INFORMATION OFFICER

PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION

OFFICE OF PIPELINE SAFETY

SUPPORTING STATEMENT

“Incident Reports for Natural Gas Pipeline Operators”

OMB Control No. 2137-0635

PHMSA-2025-0021

Introduction

The Pipeline and Hazardous Materials Safety Administration (PHMSA) requests approval from the Office of Management and Budget (OMB) for the revision of a currently approved information collection entitled “Incident Reports for Natural Gas Pipeline Operators” under OMB Control No. 2137-0635. The current expiration date for this information collection is June 30, 2026.

PHMSA is revising this information collection to:

• Revise the instructions for Form PHMSA F 7100.2 INCIDENT REPORT – GAS TRANSMISSION, GAS GATHERING, AND UNDERGROUND NATURAL GAS STORAGE FACILITIES to provide clarity on reporting the intentional release of gas through relief valves and emergency shutdown devices. 

PHMSA expects the burden on respondents to decrease due to this revision.

Part A. Justification

1. Circumstances that make the collection of information necessary.

The reports contained within this information collection support the Department of Transportation’s strategic goal of safety. Gas pipeline releases can cause human injuries, fatalities, economic losses, and environmental damage. Rapid reporting, detailed incident reports, and annual summary reports all 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 transmission, gathering, and distribution pipeline failures.

The requirements for reporting 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 to be used.

PHMSA uses this information to gather incident and failure information from gas pipeline operators, which includes operators of both gas distribution and gas transmission pipelines, and operators of liquefied natural gas facilities. These operators are required to provide immediate notification, in accordance with § 191.5, following pipeline incidents as defined in § 191.3. PHMSA uses these immediate notifications to address ongoing safety issues related to an incident.

In addition, PHMSA requires gas pipeline operators to submit incident reports. These incident reports enable PHMSA to identify and evaluate existing and potential pipeline safety problems and perform safety trend analyses. The information is also essential for FERC reporting compliance.

The incident reports are identified as follows:

Gas Distribution Incident Report

Gas Transmission Incident Report

LNG Incident Report

Type R Reporting-Regulated Gas Gathering Incident Report

The information from incident 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. PHMSA estimates that approximately 95% of submissions are completed electronically. Pipeline operators are encouraged to file the incident reports on-line at www. 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 transmission or gathering pipelines.

5. Efforts to minimize the burden on small businesses.

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 incident and annual reports. For those operators to whom electronic submissions would pose an undue burden and hardship, PHMSA allows alternative options for submission.

6. Impact of less frequent collection of information.

Incident Reporting: PHMSA would not be able to assess the rate and locations of incidents to the gas distribution/transmission and gathering pipelines without this information collection.

7. Special Circumstances.

There are no special circumstances within this request.

8. Compliance with 5 CFR 1320.8(d).

PHMSA published a 60-day Federal Register (85 FR 82028) notice on December 17, 2020. In response to that notice, PHMSA received a joint comment from AMERICAN GAS ASSOCIATION, AMERICAN PETROLEUM INSTITUTE, AMERICAN PUBLIC GAS ASSOCIATION, GPA MIDSTREAM ASSOCIATIO, and the INTERSTATE NATURAL GAS ASSOCIATION OF AMERICA, also known as The Associations. PHMSA responded to the comment in a 30-day Federal Register notice published on August 13, 2025 (90 FR 39033).

9. Payment 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.

The reporting requirements of this information collection do not involve questions of a sensitive nature.

12. Estimate of burden hours for information requested.

Current Number of Reponses: 999	Proposed Number of Responses: 840
Current Burden Estimate: 4,456 hours	Proposed Burden Estimate: 2,927 hours

Incident Reporting for Gas Distribution, Gas Transmission, and LNG Operators w/ 344 responses (2,616 hours)

Based on the most recent incident report data trends, PHMSA estimates to receive, on average, 218 (65 gas distribution, 96 gas transmission, 27 gas gathering, 3 underground natural gas storage, 22 Type R, and 5 LNG) incident report submissions annually. PHMSA expects each operator to spend 12 hours preparing and submitting each incident report. This includes the time for reviewing instructions, gathering the data needed, and completing and reviewing the collection of information. This results in an overall annual burden of 2,616 hours (218 reports *12 hours per report) for gas incident reporting.

PHMSA is revising the instructions for Form PHMSA F 7100.2 INCIDENT REPORT – GAS TRANSMISSION, GAS GATHERING, AND UNDERGROUND NATURAL GAS STORAGE FACILITIES to provide clarity on reporting the intentional release of gas through relief valves and emergency shutdown devices. 

Immediate Notice of Incidents (Section 191.5) w/ 622 Responses (311 hours)

Gas Pipeline operators are required to provide immediate notification of incidents as detailed in § 191.5. Based on previous years’ reporting trends, PHMSA expects to operators to make 622 of these 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 approximately 311 hours ( 622 notifications x 0.5 hours).

This results in an overall annual burden of 2,927 hours for this information collection.

Table 1: Estimated Burden

IC	Responses	Burden Per Response	Total Burden
Gas Distribution Incident Report	65	12 hours	780 hours
Gas Transmission, Gathering and UNGS Incident Report	126	12 hours	1,512 hours
Type R Reporting Regulated Incident Report	22	12 hours	264 hours
LNG Incident Report	5	12 hours	60 hours
Immediate Notice of Incidents	622	0.5 hours	311 hours
Total	840 annual responses		2,927 annual burden hours

13. Estimate of the total annual costs burden.

Preparing incident reports will require input from a diverse array of occupations, including technical input, legal review, database development/entry, and senior executive approval. PHMSA developed a weighted average labor cost based on wage rates for several relevant occupational categories that are likely to be involved in the reporting process. Table 2 below shows the calculations used to derive the average labor cost utilized by PHMSA. 

Table 2: Estimated Labor Costs (2021 $)

Occupation Code	Occupation Category	Mean Wage Rate	Total Labor Cost	Estimated % of Reporting Hours
13-1041	Compliance Officers	$36.45	$52.44	40%
23-1011	Lawyers	$71.17	$102.40	20%
17-2171	Petroleum Engineers	$70.06	$100.80	20%
11-1000	Top Executives	$59.31	$85.33	10%
15-1240	Database and Network Administrators and Architects	$52.50	$75.53	10%
Total	Average Loaded Wage Rate	$57.89	$83.30	100%

Source: U.S. Department of Labor’s BLS May 2021 Occupational Employment and Wage Statistics (2018 Data), www.bls.gov/oes/tables.htm. [NAICS code: 486200 - Pipeline Transportation of Natural Gas] 

Note: The wage rate was scaled upward to account for the total cost of performing these tasks. Wages composed an estimated 69.5% of total employee costs for private industry workers https://www.bls.gov/news.release/archives/ecec_06182019.pdf 

 

For each category of labor cost, PHMSA calculated those values based on the BLS data indicating that wages constitute 69.5 percent of total labor cost. For example, the total labor cost for compliance officers (second row of Table 2) is computed as follows: $36.45 / 69.5% = $52.44. 

Based on these calculations, PHMSA estimates an average loaded wage rate of $83.30 per hour. This figure was calculated from the wage rates for the various occupation codes in North American Industry Classification System (NAICS) 486200 – Pipeline Transportation of Natural Gas.

The cost burden associated with this information collection is estimated to $83.30 x 2,927 hours = $243,819.

14. Estimates of costs to the Federal Government.

PHMSA spends an estimated cost of $184,445 to operate and maintain this information collection. Operations and maintenance includes PRA compliance, interface improvements, database management, planning, revisions, and customer service.

Table 3: Costs to the Federal Government

Cost Category	Monthly Average (Hrs)	Hourly Rate	Annual Hours	Total Costs
Salary Costs	7	$38.82/hr	84	$3,260
Contracting Costs- Gas Incident Forms (GT, GD, LNG)	117.5	$128.50/hr	1,410	$181,185
Total	124.5 hours	167.32/hr	1,494 hours	$184,445

15. Explanation of the program change or adjustments.

PHMSA is revising the instructions for Form PHMSA F 7100.2 INCIDENT REPORT – GAS TRANSMISSION, GAS GATHERING, AND UNDERGROUND NATURAL GAS STORAGE FACILITIES to provide clarity on reporting the intentional release of gas through relief valves and emergency shutdown devices.

16. Publication of results of data collection.

The results of the accident reports will be summarized and posted on PHMSA’s website.

17. Approval for not displaying the expiration date of OMB approval.

PHMSA is not seeking approval to not display the expiration date.

18. Exceptions to the certification statement.

There is no exception to PHMSA’s certification of this request for information collection approval.