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Interpretation Response #PI-76-036 ([Hillsdale Mobile Home Park] [Dr. Jules Larner])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Hillsdale Mobile Home Park

Individual Name: Dr. Jules Larner

Country: US

View the Interpretation Document

Response text:

September 10, 1976

Dr. Jules Larner
Hillsdale Mobile Home Park
885-13 S. Orange Grove Boulevard
Pasadena, California 91105

Dear Dr. Larner:

This refers to your letter of July 9, 1976, requesting "an extension" to meet the corrosion control
requirements of 49 CFR 192.457(b). Although compliance with your request would involve the
granting of a "waiver" within the meaning of Sec. 3(e) of the Natural Gas Pipeline Safety Act of
1968 (49 USC 1672(e)), we have not accepted your letter as a petition for waiver since you have
not stated why you are unable to comply with Section 192.457(b) by the August 1, 1976,

The August 1 deadline was established in 1971, allowing operators at least 5 years to make the
necessary arrangements for compliance. It is our policy not to grant waivers except upon a
showing of cogent reasons why a general safety standard should not be followed in a particular
situation or an alternative standard is more appropriate. In contrast, it appears from your letter
that you are taking steps to achieve compliance as soon as possible.

We have enclosed a copy of our recently published notice on corrosion control which may be
helpful to you in complying with the requirements.


Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations



July 9, 1976

California Public Utilities Commission
San Francisco, Calif. 94102
Attn: Mr. David La Hue

With this letter, we are requesting an extension beyond the Aug. 1, 1976 date of compliance of
the Natural Gas Pipeline Safety Act of 1968 as it pertains to the Hillsdale Mobile Home Park,
6300 Roseville Rd., Sacramento, Calif. 95842, of which we are the owners.

We have already had a Soil Resistivity Test with the following findings:

Soil Resistance Category % of Readings

1K--5K Low 85.8

5K--10K Medium 4.2

Insulating unions are in the process of being installed.

A gas leak survey and the required installations will follow.

We will appreciate your cooperation.


Regulation Sections

Section Subject
192.457 External corrosion control: Buried or submerged pipelines installed before August 1, 1971