[UPDATE, 7/9/09: PHMSA has advised that the volume measure for reporting incidents is to be 3,000 MCF.]
The NPRM for amending reporting requirements will change the method by which operators submit all reports to PHMSA. Proposed changes to 49 CFR 191.7 and 195.58 require that all required reports be submitted electronically through the PHMSA website at http://opsweb.phmsa.dot.gov.
Currently incident and annual reports can be submitted online for all operators, as well as integrity management reports for gas transmission. The proposed rule would add safety related condition reports and all required LNG reports to this process. The current report forms will need to be modified for the collection of new data and new forms will have to be created for the LNG operator reports.
The docket for the proposed rule has draft versions of the revised forms, but not the incident form, see the previous post for that docket. Also in the docket is a report on the preliminary regulatory analysis of the rule change. The docket can be accesses at http://www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=PHMSA-2008-0291
The analysis report details many of the costs for the proposed rule. An interesting aspect is the increase in the number of incident reports for for natural gas operators of approximately 308 reports in the first year. After that it is anticipated that the additional number of incident reports will be 34 per year. The overall industry costs seem minimal, approximately $17,000 to $28,000 the first year and about $2,000 to $3,000 per year after that.
Along with the change to electronic reporting, code sections 191.19 and 195.62, specifying how to get the reports will be removed. Other code changes will remove instructions on submitting the reports by fax (facsimile) and hard copy.
If electronic submission creates an “undue burden” on an operator they may submit a written request to PHMSA for an alternative reporting method. The request must describe the reasons for the burden and hardship. PHMSA estimates that between 55 and 80 percent of operators already submit annual reports electronically and that industry has the technology to submit all reports in this manner.
The comment deadline is August 31, 2009. Go to the docket link above to submit your comments.